New Trends in Stablecoin Regulation: Acceleration of Legislative Processes in the United States and Hong Kong

As the global financial landscape continues to evolve, stablecoins, as emerging digital assets, are receiving significant attention from regulatory authorities around the world. Recently, the U.S. Congress and the Hong Kong Legislative Council have almost simultaneously advanced legislation on stablecoin regulation, which not only reflects a shared emphasis on the future of digital finance between the East and the West but also marks the formal entry of the global stablecoin market into the fast lane of compliance.

Data shows that the global stablecoin market capitalization has approached $250 billion, growing more than 22 times compared to five years ago. From the beginning of 2025 to now, the on-chain transaction volume of stablecoins has surpassed $3.7 trillion, and it is expected to approach $10 trillion for the entire year. This data highlights that stablecoins have leapt from being marginal assets to key nodes in the global payment network.

According to the predictive models of relevant research institutions, in an optimistic scenario, the global stablecoin market supply could reach $3 trillion by 2030, with monthly on-chain transaction volumes reaching $9 trillion and annual transaction totals expected to surpass $100 trillion. This means that stablecoins will not only rival traditional electronic payment systems but will also occupy a structurally foundational position in the global clearing network. In terms of market capitalization, stablecoins are expected to become the "fourth category of basic monetary assets" after government bonds, cash, and bank deposits, serving as an important medium for digital payments and asset circulation.

It is worth noting that the reserve structure of stablecoins has a significant impact on the macroeconomy. Currently, the scale of stablecoins has absorbed about 3% of the upcoming short-term U.S. Treasury bonds, ranking 19th among overseas U.S. Treasury bond holders. If estimated with a 50% allocation ratio, a market value of $3 trillion would correspond to at least $1.5 trillion in short-term U.S. Treasury bond demand. This scale is approaching the holdings of major overseas sovereign buyers such as China and Japan, making stablecoins likely to become one of the important creditors of the U.S. Treasury.

Although there are differences between the United States and Hong Kong in specific legislative paths, there is a high degree of consensus on fundamental principles such as "fiat currency pegging, full reserves, and licensed issuance." The U.S. GENIUS Act focuses on "payment stablecoins," emphasizing their non-security nature and clearly defining the types of qualifying reserve assets. Hong Kong, on the other hand, retains more space for future innovation while ensuring a 1:1 full peg.

In terms of institutional framework, the United States adopts a "federal-state" dual-track system, providing various pathways for stablecoin issuance. In contrast, Hong Kong has a unified licensing system governed by the Monetary Authority, requiring all stablecoin issuers targeting the Hong Kong public to apply for a license. These institutional differences reflect the distinct demands of the two regions regarding the positioning of stablecoins: the United States focuses on maintaining the dominance of the U.S. dollar, while Hong Kong aims to attract global Web3 projects while ensuring financial stability.

The implementation of stablecoin regulation will have far-reaching effects on the Web3 ecosystem. In the DeFi space, compliant issued stablecoins will become the clearing core of "compliant DeFi", promoting the integration of more KYC, AML, and asset identification modules into protocols. In the Web3 payment system, stablecoins will transition from being "transaction intermediaries" to true "payment channels", facilitating the shift of on-chain payments towards enterprise-level financial interfaces.

The deeper change lies in the reshaping of the global clearing structure. Stablecoins, pegged to fiat currency at a 1:1 ratio, bridge the connection between local currency and on-chain assets, while not relying on traditional banking account systems, enabling peer-to-peer clearing. This means that in scenarios such as cross-border payments and on-chain trade financing, stablecoins could replace traditional banks as the hub of capital circulation.

The emergence of compliant stablecoins provides crucial support for the large-scale adoption of Web3. It is both a transaction asset recognized by the system and possesses on-chain programmability. From RWA asset trading to on-chain salary distribution, from cross-border clearing to Web3 payment interfaces, stablecoins are becoming the infrastructure asset that drives the widespread adoption of on-chain economy. With the gradual improvement of regulatory frameworks, stablecoins are expected to become an important bridge connecting traditional finance and the digital economy, injecting new momentum into the innovation and development of the global financial system.