The East and West have taken a key step in the regulation of stablecoins, and a new global financial order is on the horizon.

This week, the U.S. Senate and the Hong Kong Legislative Council made significant progress almost simultaneously in stablecoin regulation. The U.S. Senate overwhelmingly passed a procedural motion for the GENIUS Act, paving the way for the first federal stablecoin legislation in the United States. Meanwhile, the Hong Kong Legislative Council 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 rhythms between the East and West is not merely a coincidence of timing, but reflects the struggle for future financial discourse power.

The stablecoin market size is rapidly expanding

According to statistics from data platforms, the current global stablecoin market capitalization has approached $250 billion, growing more than 22 times in the past 5 years. Since the beginning of 2025, the on-chain transaction volume has surpassed $3.7 trillion, and it is expected to approach $10 trillion for the whole year. USD-based stablecoins have been widely used for trading and remittances in emerging markets, with usage in some regions even exceeding that of traditional payment systems. Stablecoins have leaped from being marginal assets to key nodes in the global payment network and sovereign competition, with the United States and Hong Kong accelerating legislation almost simultaneously, marking the entry of the global stablecoin market into a period of compliance acceleration.

Based on the current rhythm of regulatory signals and institutional capital attitudes, and under the premise of keeping the turnover rate of stablecoins basically unchanged, some research institutions predict: in an optimistic scenario where the global compliance framework is gradually established and both institutions and individuals widely adopt it, the global supply of stablecoins will reach $3 trillion by 2030, with monthly on-chain transaction volume reaching $9 trillion and annual transaction volume potentially exceeding $100 trillion. This means that stablecoins will not only stand alongside traditional electronic payment systems but will also occupy a structural foundational position in the global clearing network. In terms of market capitalization, stablecoins will become the "fourth type of base currency asset" after government bonds, cash, and bank deposits, serving as an important medium for digital payments and asset circulation.

What is more noteworthy is that under this growth trend, the reserve structure of stablecoins will also have a feedback effect on the macro economy. Currently, the scale of stablecoins has absorbed about 3% of the short-term U.S. Treasury bonds that are about to mature, ranking 19th among overseas U.S. Treasury bond holders.

Considering that the GENIUS Act explicitly requires 100% high liquidity USD assets as reserves, short-term U.S. Treasuries are seen as a primary option. If estimated based on a 50% allocation ratio, a market value of $3 trillion would correspond to at least $1.5 trillion in short-term U.S. Treasury demand. This scale is already close to the current U.S. Treasury holdings of certain major economies, and stablecoins are expected to become important creditors to the U.S. Treasury.

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

Although the United States and Hong Kong differ 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," which are stablecoins that are pegged to fiat currencies like the US dollar, promise a 1:1 redemption without interest income, and emphasize their non-securities nature, aiming to prevent stablecoins from evolving into financial products with investment attributes. Meanwhile, Hong Kong has not yet restricted interest income and pegging structures, seeking to carve out a new niche in the US dollar-dominated stablecoin market while reserving space for future innovations.

In terms of reserve requirements, both the US and Hong Kong require sufficient backing with highly liquid assets, but the GENIUS Act explicitly limits the types of eligible reserve assets, including short-term government bonds, cash, and repurchase agreements, and mandates monthly audits; Hong Kong also requires audits and segregated custody, but the types of reserve assets are not fully specified.

In terms of institutional framework, the GENIUS Act adopts a "federal-state" dual-track system, providing three paths for stablecoin issuance: banks or their subsidiaries can apply for stablecoin issuance, regulated by banking regulatory agencies such as the Federal Reserve and FDIC; non-bank institutions can apply to the OCC to become federally licensed issuers, or obtain a license through state regulatory agencies. In Hong Kong, the Monetary Authority issues licenses uniformly and requires that whether the stablecoin issuer is located in Hong Kong or not, as long as it is pegged to the Hong Kong dollar or actively provides services to the Hong Kong public, it must apply for a license.

In terms of managing foreign issuers, the GENIUS Act explicitly prohibits unlicensed overseas stablecoins from circulating in the U.S. market, authorizing the Treasury to establish a "Non-Compliant Stablecoin List" and to block 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 and remains open to non-HKD stablecoins.

Behind these institutional differences lies a reflection of the differing demands for stablecoin positioning in the two regions. The United States primarily aims to maintain the dominance of the dollar and serve the structural financing needs of its fiscal system, promoting stablecoins as an extension of on-chain dollars; whereas Hong Kong hopes to attract global Web3 projects without compromising local financial stability, leaving room for policy flexibility in many details, with the goal of creating a controlled yet open and compatible compliance innovation testbed in the Asia-Pacific region.

The Impact of Stablecoin Regulation on the Web3 Ecosystem

The real significance of the regulation of stablecoins lies in providing the foundation for payments and settlements for the large-scale adoption of Web3.

In the DeFi space, although some stablecoins have become important settlement assets for on-chain financial innovation, the lack of clear legal status and accountability mechanisms makes it difficult for institutions to participate directly. If regulatory frameworks for stablecoins, such as the Genius Act, are implemented successively, stablecoins issued by compliant issuers will become the clearing core of "compliant DeFi." Protocols will embed more KYC, AML, and asset identification modules, and decentralized finance will gradually evolve into an "auditable on-chain financial network."

In the Web3 payment system, the regulation of stablecoins will break the gray boundaries between past payment scenarios and asset circulation, allowing stablecoins to truly transition from "transaction intermediaries" to "payment channels." Observations indicate that since a certain payment giant announced that the cumulative settlement amount of stablecoins has surpassed $225 million, several payment technology companies have gradually integrated stablecoins into their merchant settlement processes; Web3 wallets are expanding micro-payment scenarios such as top-ups, tipping, and subscriptions with stablecoins as the default payment asset. On-chain payments are transforming from "cryptocurrency transfer tools" to "enterprise-level financial interfaces," and compliance is a necessary prerequisite for this transformation.

A deeper change lies in the restructuring of the global clearing system: stablecoins, which are pegged to fiat currency at a 1:1 ratio, bridge the connection between local currency and on-chain assets, while not relying on the banking account system, allowing for "peer-to-peer" settlement. This means that in the future, in scenarios such as cross-border payments, on-chain trade financing, and RWA dividends, stablecoins may replace traditional banks as the central hub for capital circulation.

In the past, we discussed the large-scale popularization of Web3, focusing too much on technological breakthroughs and user experience while neglecting the legitimacy of underlying assets. Now, compliant stablecoins provide the "final piece of the puzzle": they are both transaction assets recognized by the system and possess on-chain programmability. They are digital mirrors of the US dollar and Hong Kong dollar, and can also be directly used in DeFi protocols and NFT transactions.

In other words, stablecoins are not merely an accessory to Web3, but one of the driving forces propelling it towards the mainstream. With the support of compliant stablecoins, from RWA asset trading to on-chain salary payments, from cross-border settlement to Web3 payment interfaces, stablecoins will become the "infrastructure asset" that promotes the large-scale adoption of on-chain economies.