The Wave of Stablecoin Legislation: Reshaping the Global Financial Landscape

Recently, the U.S. Senate and the Hong Kong Legislative Council took significant actions regarding stablecoin regulation almost simultaneously. The U.S. overwhelmingly passed a procedural motion for the GENIUS Act, paving the way for the first federal stablecoin legislation. Meanwhile, Hong Kong passed the third reading of the Stablecoin Regulation Bill, becoming the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. This high degree of alignment in legislative pace between the East and West is not just a coincidence of timing, but also reflects the fierce competition for future financial discourse power.

Explosive Growth of the Stablecoin Market

The current global stablecoin market capitalization is close to $250 billion, having grown more than 22 times over the past 5 years. From the beginning of 2025 to now, the on-chain transaction volume has surpassed $3.7 trillion, and it is expected to approach $10 trillion for the whole year. USD stablecoins are widely used for trading and remittances in emerging markets, with some regions even exceeding traditional payment systems in scale.

Based on current regulatory signals and institutional funding attitudes, research institutions predict that under an optimistic scenario where the global compliance framework gradually improves and both institutions and individuals widely adopt stablecoins, the global stablecoin market supply may 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 stand alongside traditional electronic payment systems but will also occupy a structural foundation position in the global clearing network.

It is worth noting that the reserve structure of stablecoins will also have a significant impact on the macroeconomy. Currently, stablecoins 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 1.5 trillion dollars in short-term U.S. Treasury bond demand, close to the current holdings of major overseas sovereign buyers such as China and Japan.

Comparison of Regulatory Frameworks for Stablecoins in the US and Hong Kong

Although there are differences between the United States and Hong Kong in legislative paths and certain details, there is a high degree of consensus on fundamental principles such as "fiat currency anchoring, full reserves, and licensed issuance."

The GENIUS Act defines "payment stablecoins" as stablecoins that are pegged to fiat currencies such as the US dollar, promise a 1:1 redeemability, and do not carry interest income, emphasizing their non-security nature. In contrast, Hong Kong has not yet restricted interest income and pegging structures while ensuring a 1:1 full peg, leaving room for future innovation.

In terms of reserve requirements, both places require sufficient anchoring of high liquidity assets, but the GENIUS Act specifically limits the types of eligible reserve assets, including government bonds, cash, and repurchase agreements, and requires monthly audits. Hong Kong also requires audits and segregated custody, but the restrictions on the types of reserve assets are relatively lenient.

In terms of institutional framework, the GENIUS Act adopts a "federal-state" dual-track system, providing multiple pathways for stablecoin issuance. In Hong Kong, the Monetary Authority issues licenses uniformly and requires that regardless of whether the stablecoin issuer is located in Hong Kong, as long as it is pegged to the Hong Kong dollar or actively provides services to the public in Hong Kong, a license must be obtained.

These institutional differences reflect the differing demands for stablecoin positioning in the two regions. The United States primarily aims to maintain the dominance of the US dollar and serve fiscal financing needs, promoting stablecoins as an extension of on-chain US dollars. In contrast, Hong Kong hopes to attract global Web3 projects while ensuring local financial stability, creating a controlled yet open compliance innovation testing ground in the Asia-Pacific region.

The Impact of Stablecoin Regulation on the Web3 Ecosystem

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

In the Web3 payment system, stablecoin regulation will truly transition it from a "transaction intermediary" to a "payment channel." More and more payment technology companies are embedding stablecoins into merchant settlement processes, and Web3 wallets are also expanding various micropayment scenarios with stablecoins as the default payment asset. On-chain payments are shifting from a "cryptocurrency transfer tool" to an "enterprise-level financial interface."

The deeper change lies in the restructuring of the global clearing system. Stablecoins, anchored to fiat currency at a 1:1 ratio, connect local currencies with on-chain assets while not relying on the banking account system, allowing for "peer-to-peer" settlement. This means that in scenarios such as cross-border payments, on-chain trade financing, and physical asset dividends, stablecoins may replace traditional banks as the central hub of capital circulation.

Compliance stablecoins provide critical support for the widespread adoption of Web3. Driven by this, stablecoins will become the infrastructure asset that promotes the extensive application of on-chain economy, from physical asset trading to on-chain salary payments, from cross-border settlement to Web3 payment interfaces.