A New Era of Stablecoin Regulation: East and West Legislation Driving the Reshaping of the Global Financial Landscape

This week, the U.S. Senate and the Hong Kong Legislative Council made significant progress in stablecoin regulation almost simultaneously. The U.S. overwhelmingly passed the procedural motion for the GENIUS Act, clearing the way for the first federal stablecoin legislation. Meanwhile, Hong Kong passed the third reading of the Stablecoin Bill, becoming the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing regime. This high level of consistency in legislative pace is not merely coincidental; it reflects the fierce competition for future financial discourse.

Explosive Growth of the Stablecoin Market

The current global market value of stablecoins has approached $250 billion, growing more than 22 times in the past five years. From the beginning of 2025 to now, on-chain transaction volume has surpassed $3.7 trillion, and it is expected to reach nearly $10 trillion for the whole year. Dollar-based stablecoins are widely used for trading and remittances in emerging markets, with some regions even surpassing traditional payment systems in terms of usage scale.

In an optimistic scenario, the global stablecoin market supply is expected to reach 3 trillion USD by 2030, with monthly on-chain transaction volumes reaching 9 trillion USD, and annual transaction totals possibly exceeding 100 trillion USD. This means that stablecoins will stand alongside traditional electronic payment systems and occupy an important position in the global clearing network. Stablecoins are expected to become the "fourth type of base currency asset" after government bonds, cash, and bank deposits.

It is worth noting that the reserve structure of stablecoins may have a significant impact on the macroeconomy. Currently, stablecoin reserves have absorbed about 3% of the upcoming short-term U.S. Treasury bonds. If estimated with a 50% allocation ratio, a market value of 30 trillion dollars would correspond to at least 15 trillion dollars in short-term U.S. Treasury bond demand, approaching the holdings scale of major overseas sovereign buyers of U.S. Treasuries.

Similarities and Differences Between the Regulatory Frameworks of the United States and Hong Kong

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 anchoring, full reserves, and licensed issuance."

The GENIUS Act focuses on "payment stablecoins," which are stablecoins pegged to fiat currencies, committed to a 1:1 redemption without interest income. Hong Kong, on the premise of ensuring a full 1:1 peg, has not yet restricted interest income and pegging structures, leaving room for future innovation.

In terms of reserve requirements, both places require sufficient anchoring of high liquidity assets, but the GENIUS Act has specific limitations on the types of eligible reserve assets. In terms of institutional framework, the United States adopts a "federal-state" dual-track system, while Hong Kong is unifiedly licensed by the Monetary Authority.

For overseas issuers, the United States explicitly prohibits unlicensed foreign stablecoins from circulating in the U.S. market, while Hong Kong mainly focuses on stablecoins pegged to the Hong Kong dollar and maintains an open attitude towards non-Hong Kong dollar stablecoins.

These differences reflect the distinct demands for stablecoin positioning in the two regions. The United States is committed to maintaining the dominance of the US dollar, promoting stablecoins as an extension of on-chain dollars; Hong Kong, on the other hand, hopes to attract global Web3 projects while ensuring local financial stability, creating a controlled yet open compliance innovation testing ground in the Asia-Pacific.

The Impact of Stablecoin Regulation on the Web3 Ecosystem

The implementation of stablecoin regulation provides a foundation for payment and settlement for the large-scale adoption of Web3. In the DeFi space, compliant issued stablecoins will become the clearing core of "compliant DeFi," with protocols embedding more KYC, AML, and asset identification modules. Decentralized finance may evolve into a "verifiable on-chain financial network."

In the Web3 payment system, stablecoins will move from being a "transaction intermediary" to a "payment channel". Many payment technology companies have begun to integrate stablecoins into merchant settlement processes, and Web3 wallets are expanding various micropayment scenarios with stablecoins as the default payment asset. On-chain payments are transitioning from "transfer tools within the crypto circle" to "enterprise-level financial interfaces."

Deeper changes are reflected in the restructuring of the global clearing system. Stablecoins bridge the connection between fiat currencies and on-chain assets, while not relying on the traditional banking account system, enabling peer-to-peer settlement. This means that in scenarios such as cross-border payments, on-chain trade financing, and RWA dividends, stablecoins may replace traditional banks as the central hub for the flow of funds.

Compliant stablecoins provide the "final piece of the puzzle" for Web3: they are both transaction assets recognized by the system and possess programmability for on-chain circulation. With the support of compliant stablecoins, from RWA asset trading to on-chain salary payments, from cross-border clearing to Web3 payment interfaces, stablecoins are expected to become the "infrastructure asset" that drives the large-scale proliferation of the on-chain economy.