The "Stablecoin Bill" of Hong Kong, China was passed by the Legislative Council of Hong Kong on May 2025, 5. It still needs to be signed by the Chief Executive and published in the Gazette before it can take effect. It is expected that the transition period arrangements will be completed within 21, and the first batch of compliant stablecoins may be launched in early 2025.
The US Stablecoin Act, the GENIUS Act, was formally proposed by Senator Bill Hagerty in February 2025, aiming to establish a dual-track regulatory framework for the federal and state governments. On May 2, 2025, the US Senate voted to "end debate" with 5 votes, entering the formal legislative process. The next step is to vote in the House of Representatives and be signed by the President. If both houses pass, it may be signed by the President and take effect as early as the end of May 20.
The EU Stablecoin Act, the Crypto-Asset Market Regulation Act (MiCA), was passed by the European Parliament in April 2023. It will take effect in stages. The first stage (stablecoin-related provisions): effective on June 4, 2024, covering the regulatory rules for electronic money tokens (EMT) and asset reference tokens (ART). The second stage (other crypto asset service terms): fully implemented on December 6, 30.
Based on the public information we have collected, we conducted a comprehensive comparative analysis of the stablecoin-related requirements in Hong Kong, China, the United States, and the European Union from the perspectives of legislative purpose, regulatory scope, regulatory body, issuing entity, issuance procedure, regulatory requirements, usage scenarios, and extraterritorial supervision.
1. Purpose of legislation
Hong Kong, China is mainly aimed at strengthening the supervision of stablecoins to protect the interests of investors and the stability of the financial system. As an emerging digital asset, the widespread use of stablecoins may have a potential impact on Hong Kong's financial system, such as affecting the transmission of monetary policy and the security of the payment system. Legislation aims to regulate the issuance and use of stablecoins and prevent financial risks.
The core goal is to balance financial stability and innovation, consolidate the status of an international financial center, promote offshore RMB stablecoins as a "digital bridge" for cross-border payments, and attract global Web3 projects to land. The feature is to emphasize compatibility and openness, and reserve space for future stablecoin innovations (such as interest income and multi-currency anchoring).
The United States aims to promote financial innovation while ensuring financial stability. The use and development of stablecoins in the United States provide new ways and tools for financial transactions, but there are also potential systemic risks. The bill attempts to find a balance between encouraging innovation and maintaining stability, and provides a framework for the legal and safe operation of stablecoins.
The core goal is to maintain the hegemony of the US dollar, prevent systemic risks, promote payment stablecoins to become an extension of the "on-chain dollar", and serve the US fiscal financing needs (such as absorbing short-term US debt). The characteristics are to explicitly exclude the compliance of non-US dollar stablecoins and limit the financial attributes of stablecoins (such as prohibiting interest).
The EU's legislative objectives include protecting investors, maintaining financial stability and promoting financial innovation. As crypto assets, including stablecoins, are increasingly traded and used within the EU, the framework hopes to regulate market order through unified regulatory standards, prevent fraud and market manipulation, and create a favorable regulatory environment for legal crypto asset transactions and stablecoin issuance.
The core goal is to establish a unified regulatory framework to protect consumers and market integrity, promote the application of distributed ledger technology (DLT), maintain financial stability in the euro area, and prevent the transmission of crypto asset risks to the traditional financial system. The characteristic is to incorporate stablecoins into the existing financial services legislation system based on the principle of "responsible innovation".
II. Scope of Supervision
The scope of regulation of stablecoins in Hong Kong, China is mainly for specific stablecoins, that is, stablecoins that are pegged to legal tender or whose value stabilization mechanism is related to legal tender. These stablecoins are usually used in payment, transaction medium and other scenarios, and have a high degree of relevance to the financial system, so they are the focus of regulation. Coverage includes legal tender-pegged stablecoins (such as Hong Kong dollars and US dollars), including issuance, reserve management, advertising and promotion activities. Algorithmic stablecoins are not explicitly prohibited, but must meet reserve requirements.
The United States has a broad definition of stablecoins, including any digital asset that attempts to maintain its value linked to a specific asset. This covers stablecoins that are linked to assets such as fiat currencies and precious metals. At the same time, it also involves various aspects such as the issuance, circulation and related financial service providers of stablecoins. The coverage is limited to payment stablecoins anchored to the US dollar, requiring 1:1 redemption and no interest attributes; non-US dollar stablecoins are restricted in compliance. Security stablecoins are regulated separately by the SEC, and algorithmic stablecoins are not included in the framework.
The EU regulatory scope includes all types of crypto assets, among which stablecoins, as an important category, are subject to stricter regulatory provisions. Its supervision not only focuses on stablecoins themselves, but also involves the issuance, trading, custody and related market infrastructure of stablecoins. The coverage scope includes electronic money tokens (EMT, such as euro stablecoins) and asset reference tokens (ART, such as multi-currency stablecoins), and algorithmic stablecoins are explicitly excluded. Central bank digital currencies (CBDCs) and stablecoins issued by public institutions are not applicable.
III. Regulatory Body
Hong Kong, China is uniformly licensed and regulated by the Hong Kong Monetary Authority (HKMA), and the Securities and Futures Commission (SFC) collaborates in anti-money laundering reviews. The Hong Kong Monetary Authority (HKMA) is one of the main regulatory bodies and plays a key role in the regulation of stablecoins. At the same time, other financial regulatory agencies such as the Hong Kong Securities and Futures Commission may also participate in the supervision work based on the specific business activities of stablecoins, such as stablecoin transactions involving securities.
The regulatory bodies in the United States are relatively complex, including the Office of the Comptroller of the Currency (OCC), the Federal Reserve, etc. Federal and state dual-track supervision, banking institutions are supervised by the Federal Reserve and the FDIC, and non-bank institutions can choose federal (OCC) or state licenses. The OCC is mainly responsible for the supervision of financial institutions such as banks, and has the right to supervise situations involving banks' participation in stablecoin business; the Federal Reserve regulates the systemic risks that stablecoins may bring from a macro-prudential perspective. In addition, the Securities and Exchange Commission (SEC) may also regulate activities related to stablecoins with securities attributes.
At the EU level, institutions such as the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) play a coordinating role in the regulation of stablecoins. At the level of each member state, financial regulatory agencies in each country, such as the German Federal Financial Supervisory Authority (BaFin), are responsible for the specific implementation of regulation. Regulatory agencies in each member state are responsible for issuing licenses, allowing operations throughout the EU through the "license passport" system, and the European Securities and Markets Authority (ESMA) coordinates cross-border issues.
IV. Issuing Entity
| Jurisdiction | capital requirements | Reserve Management | Governance and transparency |
| China Hong Kong | Minimum HK$2500 million or 1% of circulation | 1:1 fiat currency reserves, isolated custody of highly liquid assets | Local registration, senior management stationed in Hong Kong, regular disclosure of audit results |
| 美国 | No uniform capital threshold | 100% highly liquid US dollar assets (cash, short-term US bonds, etc.), high-risk investments are prohibited | Monthly reserve audits, regular reviews by federal agencies |
| EU | Dynamic adjustment according to business scale | EMT requires 1:1 cash or deposit support, and ART requires diversified low-risk assets | White paper public disclosure, annual risk assessment |
China Hong KongThe issuer must be a financial institution or enterprise that complies with Hong Kong's financial regulatory requirements. These entities need to have sufficient capital strength to deal with the risks that may arise from the issuance of stablecoins, such as ensuring the safety of stablecoin reserve assets. At the same time, they also need to comply with Hong Kong's financial regulatory standards in terms of corporate governance and risk management.
美国The requirements for the issuer are relatively strict. Generally speaking, the issuer of stablecoins needs to obtain the corresponding financial license. For example, if the stablecoin involves banking activities, such as the custody of the stablecoin's reserve assets, the issuer may need to obtain a banking license or cooperate with a bank. In addition, the issuer must meet the US Anti-Money Laundering (AML) and other compliance requirements.
EUStablecoin issuers are required to be registered in the EU and comply with EU prudential supervision requirements. This includes regulations on capital requirements, business rules, governance structure, etc. of the issuer. Only entities that meet these requirements can legally issue stablecoins within the EU.
V. Issuance Procedure
Hong Kong, China, must submit an application to HKMA to issue stablecoins, including a white paper, a reserve management plan, anti-money laundering measures, etc. During the transition period, existing issuers must apply for a license. During the application process, a detailed stablecoin issuance plan must be provided, including the stablecoin's value anchoring mechanism, the management method of reserve assets, risk control measures, etc. The Hong Kong Monetary Authority will review the application materials, and the formal issuance of stablecoins can only be carried out after the review is passed.
The entities that issue stablecoins in the United States need to register and apply in accordance with the requirements of U.S. financial supervision. Banking institutions are directly subject to existing supervision, while non-bank institutions need to apply to the OCC or state regulators and pass monthly compliance reviews. During the application process, the relevant regulatory authorities must be provided with the issuance plan and compliance plan of the stablecoin. For example, if it involves banking-related business, it may be necessary to apply for approval from the Office of the Comptroller of the Currency. Regulators will conduct strict reviews of applications to ensure that the issuance of stablecoins meets the financial regulatory objectives of the United States.
The issuer of the EU stablecoin needs to prepare issuance documents in accordance with the EU's regulatory requirements and apply for registration and authorization with the relevant regulatory authorities. These documents include the white paper of the stablecoin, which details the technical architecture, value stabilization mechanism, usage scenarios, etc. of the stablecoin. After receiving the application, the regulatory agency will evaluate it according to the EU's unified regulatory standards to decide whether to approve the issuance. After approval in any member state, it can operate throughout the EU, and documents such as technical standards and reserve certificates must be submitted. Non-compliant projects must be withdrawn during the transition period.
VI. Regulatory requirements
China Hong KongIn terms of reserve assets, the issuer of stablecoins must have sufficient legal tender or other high-quality assets that meet the requirements as reserves of stablecoins to ensure the stability of the value of stablecoins. At the same time, there are also requirements for the transparency of stablecoin transactions. The issuer needs to regularly disclose information such as the reserve assets and transaction data of stablecoins. In addition, in terms of anti-money laundering and combating terrorist financing, the issuer of stablecoins must establish a sound compliance system to identify and verify user identities.
美国Emphasize the stability and security of stablecoin reserve assets, and require the issuer to properly manage and audit the reserve assets. In terms of transparency, the issuer of stablecoins needs to disclose to the public information such as the total amount of stablecoins issued, the composition and value of reserve assets, etc. At the same time, it is necessary to comply with the strict anti-money laundering and anti-terrorist financing regulations of the United States, and monitor and report suspicious transactions.
EUIt is stipulated that the issuer of stablecoins must ensure that the reserve assets of stablecoins match the issuance volume of stablecoins, and the reserve assets must be independently audited. In terms of information disclosure, the issuer is required to provide investors and regulators with accurate and complete information, including technical details and risk factors of stablecoins. At the same time, the supervision of stablecoins in anti-money laundering and combating terrorist financing has been strengthened, and the issuer is required to take effective measures to prevent related risks.
| Dimensions | China Hong Kong | 美国 | EU |
| Reserve Audit | Regular independent audits,
Quarterly disclosure of reserve composition |
Monthly public audit,
Under federal scrutiny |
Annual audit,
Reserves need to be isolated and managed |
| Redemption Protection | Redeem at par within 1 day | Redeem within 72 hours | EMT needs to be redeemed immediately, and ART needs to have a clear redemption mechanism |
| Anti-money laundering | Strictly follow the Anti-Money Laundering Regulations and customer due diligence | Incorporate bank-level AML/CFT standards | Full implementation of the travel rule and monitoring of large transactions |
7. Scenarios and Supervision
Hong Kong, China focuses on expanding cross-border trade settlement, DeFi compliance clearing and retail payment scenarios, and encourages the integration of stablecoins with the real economy. The use scenarios of stablecoins are mainly concentrated in legal and compliant fields such as financial transactions and cross-border payments. As an international financial center, Hong Kong can use stablecoins for fund transfers between financial institutions and cross-border trade settlements for enterprises. However, some use scenarios that may pose risks, such as illegal financial transactions, will be strictly regulated and restricted.
The United States promotes the use of stablecoins for on-chain payments, treasury financing, and cross-border remittances, and restricts their access to securities or commodity markets. Stablecoins are allowed to be used in a variety of financial transaction scenarios, including retail payments, securities trading settlements, etc. The use of stablecoins in the United States can improve the efficiency of financial transactions and reduce transaction costs. But at the same time, regulators will monitor the use of stablecoins to prevent them from being used for illegal activities such as money laundering and terrorist financing.
The EU focuses on retail payments and financial infrastructure, and supports stablecoins as a supplement to the "digital euro". The use scenarios of stablecoins in the EU include payment, investment, etc. In the payment field, stablecoins can be used for cross-border payments and e-commerce payments, etc. In the investment field, stablecoins can be used as part of an investment portfolio, but only under the premise of complying with EU financial regulatory requirements. The EU pays attention to the risk assessment of stablecoin usage scenarios to ensure that they will not harm financial stability and consumer interests.
8. Strategic Intentions
Hong Kong, China intends to attract global innovative projects through flexible regulation, promote the internationalization of offshore RMB, and build an Asia-Pacific Web3 hub. For stablecoins issued overseas but traded and promoted in Hong Kong, Hong Kong financial regulators will regulate them based on their possible impact on Hong Kong's financial system. If the activities of overseas stablecoins pose a threat to Hong Kong's financial stability, investor interests, etc., Hong Kong regulators may take corresponding regulatory measures, such as requiring information and restricting transactions.
The United States intends to consolidate the hegemony of the U.S. dollar in the digital age, using stablecoins to absorb the demand for U.S. debt and suppress competition from non-dollar stablecoins. U.S. regulators will advocate the exercise of regulatory power over stablecoins issued overseas but involving U.S. investors or having a significant impact on the U.S. financial system. With its strong financial position and the principle of long-arm jurisdiction, the United States may require overseas stablecoin issuers to comply with relevant U.S. laws and regulations, or restrict their business activities within the United States.
The EU intends to maintain the financial sovereignty of the eurozone through unified supervision, prevent the spillover of crypto risks, and balance innovation and security. The EU will regulate stablecoins that are issued overseas but provide services within the EU or have an impact on the EU financial system based on their risk level. If the operation of overseas stablecoins does not meet EU regulatory standards, EU regulators may take measures, such as prohibiting them from conducting business in the EU or requiring them to make rectifications, to ensure the safety and stability of the EU financial market.
The stablecoin systems of the three major jurisdictions reflect different strategic orientations: Hong Kong focuses on openness and compatibility, the United States strengthens the dominance of the US dollar, and the European Union pursues unity and security. In the future, compliant stablecoins will become the infrastructure of the on-chain economy, but their regulatory competition may also exacerbate the fragmentation of the global financial system. Enterprises need to choose a compliance path based on their business focus. For example, Hong Kong can be selected for cross-border scenarios, US dollar clearing focuses on the United States, and the European market must comply with MiCA standards.