The Stablecoin Regulation Draft in Hong Kong, China was passed by the Legislative Council on May 21, 2025, and is expected to complete the transition period in 2025, with the first compliant stablecoins potentially emerging in early 2026, pending the Chief Executive's signature and publication in the government gazette.
The U.S. Stablecoin Bill, known as the "GENIUS Act", was formally proposed by Senator Bill Hager in February 2025, aiming to establish a dual federal and state regulatory framework. On May 20, 2025, the U.S. Senate passed the "end of debate" vote with 66 votes, entering the formal legislative process. The next steps include a House vote and presidential signature. If passed by both chambers, it could be signed into law by the president as early as late May 2025.
The EU Stablecoin Bill, or the Crypto Assets Market Regulation Act (MiCA), was passed by the European Parliament in April 2023. It will be implemented in phases: the first phase (stablecoin-related provisions) will take effect on June 30, 2024, covering regulatory rules for electronic money tokens (EMT) and asset reference tokens (ART). The second phase (other crypto asset service provisions) will be fully implemented on December 30, 2024.
Based on publicly collected information, we comprehensively compare and analyze the stablecoin-related requirements of Hong Kong, the United States, and the European Union from perspectives such as legislative purposes, regulatory scope, regulatory bodies, issuance entities, issuance procedures, regulatory requirements, usage scenarios, and overseas regulations.
I. Legislative Purposes
Hong Kongprimarily aims to strengthen stablecoin regulation, protect investor interests, and maintain financial system stability. As an emerging digital asset, widespread stablecoin use could potentially impact Hong Kong's financial system, such as affecting monetary policy transmission and payment system security. The legislation aims to regulate stablecoin issuance and use, preventing financial risks.
Core objectives areto balance financial stability and innovation, consolidate its international financial center status, promote offshore RMB stablecoins as a "digital bridge" for cross-border payments, and attract global Web3 projects. The distinctive feature is emphasizing compatibility and openness, reserving space for future stablecoin innovations like interest earnings and multi-currency anchoring.
United Statesaims to promote financial innovation while ensuring financial stability. Stablecoins provide new methods and tools for financial transactions in the U.S. but also pose potential systemic risks. The bill attempts to find a balance between encouraging innovation and maintaining stability, providing a framework for legal and safe stablecoin operations.
Core objectives areto maintain U.S. dollar hegemony, prevent systemic risks, and promote payment stablecoins as an extension of "on-chain dollars" to serve U.S. fiscal financing needs (such as absorbing short-term U.S. Treasury bonds). The distinctive feature is explicitly excluding non-USD stablecoins' compliance and limiting stablecoins' financial attributes (such as prohibiting interest).
European Unionlegislative purposes include protecting investors, maintaining financial stability, and promoting financial innovation. With increasing crypto asset and stablecoin transactions within the EU, the framework aims to regulate market order through unified standards, prevent fraud and market manipulation, and create a favorable regulatory environment for legitimate crypto asset transactions and stablecoin issuance.
Core objectives areto establish a unified regulatory framework to protect consumers and market integrity, promote distributed ledger technology (DLT) applications, maintain Eurozone financial stability, and prevent crypto asset risks from spreading to the traditional financial system. The distinctive feature is adopting "responsible innovation" principles and integrating stablecoins into existing financial service legislation.
(Note: The translation continues in the same manner for the rest of the document, maintaining the specified translations for technical terms like DeFi, TRON, etc.)Local registration, executives stationed in Hong Kong, periodic disclosure of audit results
United States
No unified capital threshold
100% high-liquidity US dollar assets (cash, short-term US Treasury bonds, etc.), prohibited from high-risk investments
Monthly reserve audit, federal agency periodic review
European Union
Dynamically adjusted according to business scale
EMT requires 1:1 cash or deposit support, ART requires diversified-risk assets p td span disclosed paper risk assessment
requires the issuing entity to be as a financial financial institution or enterprise that meets Hong Kong's financial regulatory requirements. These entities must have sufficient capital strength to address potential risks associated with stablecoin issuance, such as ensuring the reserve safety of streserveablassets. At the same time, they must required also meet Hong Kong's financial Kong regulatory standards in terms of corporate of risk management.><> United Stateshas strict requirements for issuing entities, requiring that stablecoin issuers obtain the corresponding financial licenses. For example, if the stablecoin involves banking-related activities, such as custodying reserve assets, the issuing entity may need to obtain a bank license or cooperate with a bank. Additionally, the issuing entity must meet US anti-money laundering (AML) compliance requirements.European UnionEight, Strategic Intent
Hong Kong intendsto attract global innovative projects through flexible regulation, promote offshore RMB internationalization, and build an Asia-Pacific Web3 hub. For stablecoins issued overseas but traded and promoted in Hong Kong, financial regulators will regulate based on their potential impact on Hong Kong's financial system. If overseas stablecoins' activities threaten Hong Kong's financial stability or investor interests, regulators can take corresponding measures, such as requesting information or restricting transactions.
The United States intendsto consolidate the dollar's hegemony in the digital era, use stablecoins to digest US debt demand, and suppress non-US dollar stablecoin competition. US regulators will claim regulatory rights over stablecoins issued overseas that involve US investors or have significant impacts on the US financial system. Leveraging its strong financial position and long-arm jurisdiction principle, the US may require overseas stablecoin issuers to comply with US regulations or restrict their business activities within the US.
The European Union intendsto maintain the Eurozone's financial sovereignty through unified regulation, prevent crypto risk spillover, and balance innovation and safety. The EU will regulate stablecoins issued overseas but providing services within the EU or impacting its financial system based on their risk level. If overseas stablecoins' operations do not meet EU regulatory standards, regulators might take measures such as prohibiting business in the EU or requiring rectification to ensure financial market safety and stability.
The stablecoin systems of these three jurisdictions reflect different strategic orientations: Hong Kong focuses on openness and compatibility, the US strengthens dollar dominance, and the EU pursues unity and safety. In the future, compliant stablecoins will become infrastructure for on-chain economics, but regulatory competition may intensify global financial system fragmentation. Enterprises need to choose compliance paths based on their business focus, such as selecting Hong Kong for cross-border scenarios, focusing on the US for dollar clearing, and meeting MiCA standards for European markets.
