The Global Stablecoin Market Enters a Period of Accelerated Compliance: A Comparative Analysis of the Regulatory Frameworks in the United States and Hong Kong

The U.S. Senate and Hong Kong's Legislative Council took key steps toward stablecoin regulation almost simultaneously this week: the U.S. overwhelmingly passed the procedural motion of the GENIUS Act, clearing the way for the first federal stablecoin bill; Hong Kong passed the third reading of the Stablecoin Bill, becoming the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. The high degree of overlap in the legislative rhythm of the East and the West is not only an accidental collision of timing, but also reflects the strategic competition for the future financial discourse.

The potential of the stablecoin market is huge: trading volume may exceed one trillion dollars by 2030.

According to market statistics, the current global stablecoin market value has approached $250 billion, growing over 22 times in the past 5 years. From the beginning of 2025 to now, the on-chain transaction volume has exceeded $3.7 trillion, with the annual total expected to approach $10 trillion. Dollar stablecoins represented by USDT and USDC are widely used for trading remittances in emerging markets, with some regions even surpassing traditional payment systems in usage scale. Stablecoins have jumped from being fringe assets to key nodes in global payment networks and sovereign competition.

Based on professional assessment models and in conjunction with current regulatory signals and institutional funding attitudes, it is expected that under the premise of maintaining a stablecoin turnover rate that remains basically unchanged, in an optimistic scenario where the global compliance framework is gradually rolled out and widely adopted by institutions and individuals, the global stablecoin market supply will reach $3 trillion by 2030, with monthly on-chain transaction volumes reaching $9 trillion and annual transaction totals potentially exceeding $100 trillion. This means that stablecoins will not only be on par with traditional electronic payment systems but will also occupy a structurally foundational position in the global settlement network. In terms of market capitalization, stablecoins will become the "fourth type of foundational currency asset" after government bonds, cash, and bank deposits.

It is worth noting that under this growth trend, the reserve structure of stablecoins will also have a significant feedback effect on the macroeconomy. The existing scale of stablecoins has absorbed approximately 3% of upcoming short-term U.S. Treasuries, ranking 19th among overseas U.S. Treasury holders.

Considering that the GENIUS Act explicitly requires 100% of highly liquid US dollar assets as reserves, short-term US Treasuries are seen as the main option (more than 80% of the current reserve assets of mainstream stablecoins are related to US Treasuries). If the 50% allocation is estimated, the market capitalization of $3 trillion would correspond to at least $1.5 trillion of short-term U.S. debt needs. This is close to the current holdings of U.S. bonds by major overseas sovereign buyers such as China or Japan, and stablecoins are expected to become the "biggest hidden creditor" of the U.S. treasury.

Comparison of Regulatory Frameworks for Stablecoins in the US and Hong Kong: Consensus Amidst Divergence

Although the United States and Hong Kong differ in legislative paths and some details, there is a high consensus on fundamental principles such as "fiat currency anchoring, full reserves, and licensed issuance."

The GENIUS Act restricts "paid stablecoins", that is, stablecoins that are pegged to fiat currencies such as the US dollar, promise 1:1 redemption, and do not carry interest income, emphasizing their non-security attributes, with the intention of preventing stablecoins from evolving into financial products with investment attributes. Hong Kong, on the premise of ensuring a full 1:1 pegging, has not restricted interest income and anchoring structure for the time being, seeking to open up a new track in the U.S. dollar-dominated stablecoin market and reserve room for future innovation.

In terms of reserve requirements, both the United States and Hong Kong are required to fully anchor highly liquid assets, but the GENIUS Act clearly restricts the types of qualified reserve assets, including T-Bills, cash and repurchase agreements, and requires monthly audits. Hong Kong also requires audit and segregated custody, but the types of reserve assets are not fully restricted.

In terms of institutional structure, the GENIUS Act adopts a "federal-state" dual-track system, providing three paths for stablecoin issuance: banks or their subsidiaries can apply to issue stablecoins, regulated by banking authorities such as the Federal Reserve and FDIC; non-bank institutions can apply to the OCC to become federally licensed issuers, or obtain licenses through state regulatory agencies. In Hong Kong, the Monetary Authority issues licenses uniformly, requiring that regardless of whether the stablecoin issuer is located in Hong Kong, any entity that anchors to the Hong Kong dollar or actively provides services to the Hong Kong public must apply for a license.

In terms of managing overseas issuers, the GENIUS Act clearly prohibits unlicensed overseas stablecoins from circulating in the U.S. market, authorizing the Treasury to establish a "non-compliant stablecoin list" and blocking their circulation pathways through U.S. digital asset service providers; Hong Kong, on the other hand, mainly focuses on stablecoins pegged to the Hong Kong dollar while maintaining an open attitude towards non-Hong Kong dollar stablecoins.

Behind these institutional differences, they reflect the different demands of the two places in the positioning of stablecoins. The U.S. focuses on maintaining the dominance of the U.S. dollar and serving the needs of fiscal structural financing, and promotes stablecoins to become an extension of the U.S. dollar on the chain. Hong Kong, on the other hand, hopes to attract global Web3 projects without compromising local financial stability, leaving room for policy flexibility in many details, aiming to create a controlled, open and compatible Asia-Pacific compliance innovation testing ground.

How Will Stablecoin Regulation Affect the Web3 Ecosystem?

The real significance of the implementation of stablecoin regulation lies in providing the foundation for payment and settlement for the large-scale adoption of Web3.

In the DeFi field, although mainstream stablecoins have become important settlement assets for on-chain financial innovation, they have lacked a clear legal status and accountability mechanism in the past, making it difficult for institutions to participate directly. If stablecoin regulatory frameworks such as the Genius Act are implemented one after another, stablecoins provided by compliant issuers will become the core of "compliant DeFi", and more KYC, AML and asset identification modules will be embedded in the protocol, and decentralized finance will gradually evolve into an "auditable on-chain financial network".

In the Web3 payment system, the implementation of stablecoin supervision will break the gray boundary between payment scenarios and asset circulation in the past, making stablecoins truly move from "transaction intermediary" to "payment channel". It is observed that since Visa announced that the cumulative stablecoin settlement volume exceeded US$225 million, a number of payment technology companies have successively embedded stablecoins into their merchant settlement processes, while Web3 wallets have used stablecoins as the default payment asset to expand micropayment scenarios such as recharge, tipping, and subscription. On-chain payments are changing from "crypto-circle transfer tools" to "enterprise-level financial interfaces", and compliance is a necessary prerequisite for this transformation.

A deeper change lies in the reshaping of the global clearing structure: stablecoins are pegged to fiat currencies at a 1:1 level, opening up the connection between the local currency and on-chain assets, while at the same time not relying on the bank account system, and can achieve "peer-to-peer" liquidation. This means that in the future, stablecoins may replace traditional banks as capital circulation hubs in scenarios such as cross-border payment, on-chain trade financing, and digital dividend distribution of physical assets.

In the past, when the industry discussed the large-scale popularization of Web3, it often focused too much on technological breakthroughs and user experience, while neglecting the key factor of the legitimacy of underlying assets. Today, compliant stablecoins provide the "last piece of the puzzle": they are both transaction assets recognized by the system and possess programmability for on-chain circulation; they are digital mirrors of USD and HKD, and can be directly applied in DeFi protocols and NFT transactions.

In fact, stablecoins are not an adjunct of Web3, but one of the core drivers driving them into the mainstream. With the support of compliant stablecoins, from digital transactions of physical assets to on-chain payroll, from cross-border clearing to Web3 payment interfaces, stablecoins will become "infrastructure assets" that will promote the large-scale popularization of the on-chain economy.

! East and West compete for the right to speak for stablecoins: the U.S.-Hong Kong legislative tide reshapes the new global financial order