This article is authorized to be reproduced from Xiao Za Lawer, with copyright belonging to the original author.
In 2014, Tether launched the first mainstream stablecoin USDT (also known as Tether), pegged to the US dollar at a 1:1 ratio, marking the official birth of stablecoins. After going through an exploratory phase, a rapid growth period, and a crisis and adjustment phase, stablecoins have once again revived and entered a rapid growth trajectory since the second half of 2023. As of July 2025, the total market capitalization of global stablecoins has exceeded $250 billion.
The United States holds significant influence in the global financial system, with stablecoins pegged to the US dollar (such as USDT and USDC) dominating in market capitalization, circulation, and application scenarios. The US has made beneficial attempts in stablecoin regulation, which has a demonstrative effect on the global market. On June 17, 2025, the US Senate passed the "Guidance and Establishment of the National Stablecoin Innovation Act" (also known as the "Genius Act"), aimed at establishing a regulatory framework for US dollar-pegged stablecoins. The bill still needs to be passed by the House of Representatives and signed by the President to take effect.
As an international financial center, Hong Kong has actively explored and practiced in the stablecoin field in recent years, passing the "Stablecoin Act" in May 2025, which will take effect on August 1, 2025. Comparing the regulatory legal systems of stablecoins in Hong Kong and the United States has important practical significance and strategic value.
Hong Kong: Single centralized regulation. The Hong Kong Monetary Authority (HKMA) issues licenses and regulates three types of activities: issuing fiat currency stablecoins in Hong Kong, issuing stablecoins pegged to the Hong Kong dollar overseas, and promoting fiat currency stablecoins to the public in Hong Kong. The regulatory scope breaks geographical limitations; even if the issuer is located overseas, as long as the stablecoin claims to be pegged to the Hong Kong dollar or is promoted to the Hong Kong market, a license must be applied for.
United States: Federal-state tiered regulation. Federal agencies such as the Federal Reserve and the Office of the Comptroller of the Currency (OCC) regulate issuers with a market capitalization exceeding $10 billion; smaller issuers are regulated at the state level but must meet federal minimum standards. The bill also establishes a "Stablecoin Certification Review Committee" (SCRC) specifically to assess the issuance qualifications of large technology companies, preventing them from monopolizing the market using their advantages and user data.
Hong Kong: In Hong Kong, the "stablecoins" managed by the "Stablecoin Act" are "designated stablecoins," which are (1) value pegged or referenced to one or more official currencies (such as the Hong Kong dollar, US dollar, etc.); (2) value referenced to accounting units or forms of economic value designated by the Financial Secretary (i.e., HKMA) (such as Special Drawing Rights (SDR), gold, etc.); (3) other digital value representations explicitly designated by the HKMA through a gazette announcement. Any issuance of designated stablecoins in Hong Kong, or designated stablecoins issued outside Hong Kong but pegged to the Hong Kong dollar, or even promoting designated stablecoins to the public in Hong Kong globally, must apply for a license from the HKMA and comply with relevant regulatory requirements.
According to the Hong Kong "Stablecoin Ordinance," stablecoins issued in Hong Kong can be pegged to the Hong Kong dollar as the core anchor, and stablecoins pegged to other fiat currencies such as the US dollar and Chinese yuan are also allowed. Each stablecoin pegged to a different currency must apply for a separate license to ensure compliance. Stablecoins can be pegged to a single fiat currency such as the Hong Kong dollar, US dollar, and Chinese yuan, or to a basket of fiat currencies.
United States: In the US, stablecoins are "payment stablecoins," which are (1) virtual assets used or designated for payment or settlement, and (2) the issuer is obligated to conduct value conversion, redemption, or repurchase of stablecoins in fixed currency; or the issuer claims to maintain or create reasonable expectations that the value of the stablecoin will maintain a constant ratio relative to a fixed fiat currency amount.
Hong Kong: The Hong Kong "Stablecoin Ordinance" does not explicitly grant stablecoin holders priority claims in the event of the issuer's bankruptcy. The regulatory framework in Hong Kong focuses more on protecting user rights through asset segregation, mandatory audits, and redemption guarantee mechanisms (redemption at face value within a reasonable time).
United States: The US "Genius Act" explicitly states that stablecoin holders have "priority rights" in the event of the issuer's bankruptcy, meaning that the claims of stablecoin holders take precedence over all other creditors. The US also requires issuers to clearly disclose redemption policies and fees, ensuring that users can redeem stablecoins in a timely manner.
Hong Kong: The minimum paid-up capital requirement for applying for a stablecoin license in Hong Kong is HKD 25 million, or an equivalent amount in another currency that can be freely converted into Hong Kong dollars or in another currency approved by the Financial Secretary for the implementation of this provision. Reserve assets must be independently custodied, using highly liquid, low-risk financial instruments (such as cash or high-quality bonds), and ensuring that their value fully matches the face value of the stablecoins. Licensed institutions must process redemption requests at face value under reasonable conditions, prohibiting the setting of barriers or delays in fulfilling redemption obligations.
United States: The bill does not explicitly specify a specific "minimum threshold" amount, but the reserve requirements for highly liquid assets, the federal and state regulatory framework, and compliance and transparency requirements together constitute a high entry barrier. Each state in the US has requirements for the management of customer funds and redemptions by money service providers. For example, New York State requires: (1) any stablecoin regulated by the New York Department of Financial Services (NYDFS) must have 100% highly liquid assets as reserves; (2) issuers must establish clear stablecoin redemption policies, allowing stablecoin holders to redeem stablecoins at face value from the issuer in a short time; (3) reserve accounts must not be confused with the issuer's own assets and must be audited at least once a month by an independent registered accountant in the US.
Hong Kong: For licensed stablecoin holders, the regulatory requirements implemented in Hong Kong are as strict as those for traditional financial institutions. The "Stablecoin Ordinance" requires that licensees establish and implement sound and appropriate control systems to prevent and combat potential money laundering or terrorist financing activities related to stablecoin activities. The 2022 revised "Anti-Money Laundering and Counter-Terrorist Financing Ordinance" stipulates control systems for stablecoin licensees, corporations providing virtual asset services to licensees, and recognized institutions to prevent and combat potential money laundering or terrorist financing activities related to stablecoin activities.
United States: The US Financial Crimes Enforcement Network (FinCEN) has explicitly stated that cryptocurrencies that can be exchanged for fiat currency should be recognized as "currency" and that stablecoin issuers are subject to anti-money laundering regulation as "money service providers." Entities engaged in stablecoin business in the US, especially those involved in the transfer of funds and currency exchange, must establish a comprehensive anti-money laundering compliance system and assume anti-money laundering obligations.
From regulatory frameworks to operational details, the differences between Hong Kong and the United States in the field of stablecoins are not a matter of "superiority or inferiority," but rather beneficial attempts that are both similar and innovative. With the development of cross-border payments and the acceleration of digital asset globalization, clarifying the similarities and differences between Hong Kong and the United States in the field of stablecoins helps identify potential cooperation spaces and risk points, promoting the healthy and sustainable development of the global stablecoin ecosystem.
Entities issuing stablecoins must ensure compliance, apply for licenses, and operate legally according to relevant laws. Compliance is a prerequisite for the issuance and operation of stablecoins, not a remedial measure after the fact; compliance is not only a regulatory requirement but also a necessary condition for stablecoin issuers to establish legal relationships with relevant government agencies and users, continuously enhancing their business capabilities.
Related Reading: Bank of England Governor Warns Against Private Issuance of Stablecoins
Original text: “Comparison of Stablecoin Bills: Hong Kong vs. United States”
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