Written by: Portal Labs
On May 21, 2025, the Hong Kong Legislative Council passed the "Stablecoin Regulation Bill", paving the way for compliant stablecoin issuance in Hong Kong. Subsequently, the Web3 market, especially the Chinese (Mandarin) market, turned its attention to internet giants participating in the sandbox program.
Since June, stablecoin-related news led by JD has sparked domestic discussions. On June 17, according to Sina Finance, JD's Liu Qiangdong stated that JD hopes to apply for stablecoin licenses in all major currency countries to achieve exchange between global enterprises. On the 18th, JD Coinlink Technology CEO Liu Peng told Bloomberg Businessweek that the Hong Kong dollar and multi-currency stablecoins have been smoothly tested in the Hong Kong Monetary Authority's "sandbox", expecting to officially obtain a license and go online in early Q4 this year.
As always, whenever Hong Kong has favorable information, there are always many "domestic opening signal" voices in China, and this time is no exception. However, while expectations can exist, as practitioners, Portal Labs still believes that one should look beyond the surface and examine the underlying logic.
So, why can JD, as a Chinese internet giant, issue a stablecoin? It must be because its underlying architecture meets the conditions for stablecoin issuance in Hong Kong. (That's right, not in China, but only in Hong Kong)
From the composition of the project itself, its compliance path, initiating entity, and business positioning are extremely clear.
JD Stablecoin Project Entity
The premise for JD to advance its stablecoin project in Hong Kong is that its underlying architecture must meet the basic requirements for "issuing entities" under the Hong Kong Stablecoin Regulation. According to the Hong Kong Stablecoin Regulation Bill, the issuer must:
Be registered in Hong Kong;
Have a paid-in capital of more than 25 million Hong Kong dollars;
Have stable financial and risk control capabilities;
Be able to maintain 100% high-quality, highly liquid asset reserves;
Accept audit supervision and establish a clear redemption mechanism.
The establishment of JINGDONG Coinlink Technology Hong Kong Limited is precisely to meet these regulatory container system requirements. The company is registered in Hong Kong, with JD Technology Group as its shareholder, possessing an independent legal person status that can be financially, asset-wise, and operationally isolated from its parent company. This structural arrangement not only allows it to meet the basic qualifications of an issuer but also ensures that its business operations can independently respond to compliance in sandbox testing, risk assessment, and formal licensing processes.
From a compliance perspective, why not directly apply for a license through the JD Group? The reason is that JD, as a mainland large-scale group, cannot directly become a "locally registered issuing entity" under the Hong Kong stablecoin regulations. By establishing a wholly-owned subsidiary, it can achieve unified coordination of the group's technology and resources while accepting Hong Kong Monetary Authority supervision as an independent entity, completing the legal relationship between the issuer, reserve custody, and compliance reporting.
This arrangement is essentially no different from Circle's establishment of Circle Internet Financial LLC as the USDC issuer: the "issuer" needs an independently auditable legal identity to accept local regulation and business penetration requirements, rather than relying on the overall qualifications of the parent company.
In other words, JD is not qualified for the stablecoin sandbox because it is "in China", but because it is "in Hong Kong and meets Hong Kong regulatory requirements". This is the first principle of the project's establishment and a prerequisite for judging whether it can be replicated.
JD Stablecoin Project Design
Meeting the subject qualifications set by regulations is only the starting point for compliant stablecoin issuance. The real "ability to issue" lies in design capabilities - whether an institution can build a regulated, auditable, and redeemable stablecoin issuance and operation system.
This capability is often reflected in three dimensions: governance structure, financial capacity, and infrastructure.
Governance Structure: From Group Separation to Independent Risk Control System
According to the Hong Kong Stablecoin Regulation Bill, issuers need to meet a series of governance-level regulatory requirements: including establishing internal audit, risk control, and information disclosure mechanisms, and clearly defining director responsibility boundaries and statutory regulatory obligations. The purpose is to treat the issuer as a quasi-financial institution subject to penetrative governance scrutiny.
The key reason why JD Coinlink Technology can become a sandbox pilot institution is not that its parent company is an internet giant, but that it itself has a "quasi-financial issuer" governance structure. From public information, the company has an independent director structure in its legal documents and cooperates with local Hong Kong law for financial report audits and daily regulatory reporting. This means that its issuance behavior does not rely on the parent group's guarantee or reputation but assumes legal responsibility through its "own governance system".
Financial Structure: Compliant Reserve Mechanism and High Credit Threshold
Hong Kong's regulatory requirements for stablecoin reserves are extremely strict: not only must they be 100% anchored but must also be composed of "high-quality and highly liquid assets" such as Hong Kong dollars, bank deposits, and short-term government bonds, with a dedicated custody account for asset isolation and audit.
This threshold naturally excludes many small and medium crypto projects, with only financially robust enterprises with strong financial risk control capabilities being capable. As a large enterprise with ample daily cash flow, JD can set up equivalent reserve accounts and collaborate with financial institutions for asset custody. It is understood that during the sandbox testing period, it has established a stablecoin exchange and redemption mechanism, promising users can redeem fiat currency "at par value, without additional fees", consistent with the basic requirements of the draft.
More importantly, its stablecoin is not anchored to virtual assets but is collateralized by Hong Kong dollars or multiple currencies, further enhancing regulatory acceptability. The risk exposure behind such a reserve mechanism is relatively controllable, clearly different from crypto market solutions based on "algorithms" or "on-chain collateral".
Infrastructure Capability: Ability to Independently Complete Clearing, Verification, and Compliance
Issuing a stablecoin is not a technical innovation but a reconstruction of "compliant financial infrastructure". Within the HKMA's regulatory framework, issuers need clearing and settlement systems, identity verification processes, KYC/AML mechanisms, system audits, and emergency response capabilities. In short, a stablecoin is not just about writing a smart contract and setting up a frontend, but a system engineering project.
In this regard, JD has long accumulated rich experience in B-end scenarios such as e-commerce payment, consumer finance, and cross-border settlement. Its subsidiary JD Fintech has previously built multiple payment and account systems, capable of operating financial users in the millions. This provides a natural infrastructure foundation for the stablecoin. In other words, what JD is issuing is not a "chain token" but a "financial instrument" with a real, convertible mechanism.
In comparison, many crypto-native projects, even with overseas licenses, struggle to establish supporting infrastructure in actual operations, thus failing to meet the HKMA's core requirement of "stablecoin system full-process controllability".
JD Stablecoin Business Scenarios
The core regulatory concern is not just "can you issue" but "can you operate within the regulatory view after issuance". From this perspective, the stablecoin's use cases are not just a commercial expansion logic but a bridge of regulatory trust.
On this point, JD's stablecoin project is clearly positioned to "serve cross-border remittance and enterprise payment", cutting in from existing business systems rather than rebuilding a chain ecosystem. This approach of starting from an "extension of existing systems" perfectly aligns with the HKMA's regulatory tone emphasizing "integration with the real economy".
Enterprise Payment: Not Creating a C-end Wallet, but a B-end Settlement Tool
The JD stablecoin project is a B2B-level settlement tool. According to CEO Liu Peng's statement in the Bloomberg interview, its goal is to provide enterprise customers with more efficient exchange methods between different countries' legal currencies, reducing transfer links and exchange losses in traditional cross-border settlements.
This means that JD's stablecoin primarily serves the function of "improving enterprise exchange efficiency," with a naturally closed circulation path that is clear and controllable for users. From a regulatory perspective, this high-certainty scenario is highly acceptable: it does not involve speculation, is not aimed at retail investors, has controllable risks, and has a clear purpose - precisely the ideal "financial technology enhancement tool" rather than a "quasi-financial asset".
Offline Integration: Connecting with Existing Supply Chain Finance and Cross-border Settlement Closed Loops
JD has already deployed systems for supply chain finance, cross-border clearing and settlement, and warehouse fulfillment in cross-border business. The embedding of stablecoins is actually a natural extension of the "on-chain certificate + off-chain fulfillment" logic. Compared to the path of most Web3 projects "issuing coins first and then finding scenarios," JD already has demand-side needs, naturally generating stablecoin usage scenarios.
In other words, JD's stablecoin is not issued for the sake of issuance, but to solve pain points in existing systems: non-transparent multi-currency settlement, high handling fees, and unstable arrival times. In this system, stablecoins are not a C-end technical showcase, but a B-end efficiency booster.
Regulatory Friendly: Clear Scenario Path, Verifiable by Users, Predictable Returns
Compared to many stablecoin models that construct "anchoring relationships" through DeFi protocols and contract mechanisms, what JD provides is a set of "disclosable, reportable, and controllable" commercial application paths.
Its goal is not to build liquidity pools or token markets, but to clearly explain to regulators: this stablecoin is issued to which enterprise, for what scenario, and how it will be settled after use, with KYC, audit, and traceability mechanisms at every step. In a sense, it is more akin to an "on-chain settlement certificate running on the regulatory map" rather than a free market trading asset.
Conclusion
JD's stablecoin project proves one thing: today, as stablecoins enter the institutional track, the project's "structural adaptability" is becoming the core variable determining success.
It's not about who issues coins first, or who understands smart contracts better, but who can build a comprehensive framework that is accepted by regulators, verified by scenarios, and recognized by the market. This framework is not imagined by a white paper, but realized through:
Localized issuer and reserve segregation accounts;
Clearing and settlement systems and risk control mechanisms that meet financial-grade requirements;
Clear scenario value closed loop, especially real B-end needs.
In other words, future stablecoins are not an "extension of crypto projects," but a "new journey for infrastructure-level enterprises".
Portal Labs believes that true benefits will not come through "regulatory easing," but will be gradually released in the form of "institutional stability + rising compliance capabilities".
For enterprises looking to enter this field, the first question to ask themselves should be: Am I ready to become a financial issuer?
