The criticism from the outside world that "Hong Kong stablecoins cannot only have licenses" is not a sign of pessimism, but rather points out the real homework that needs to be done in the next stage.

Written by: Farmer Frank

On April 10, 2026, the Hong Kong Monetary Authority officially granted the first batch of stablecoin issuer licenses to Anchor Point Financial Technology Limited and HSBC Hong Kong. With this, Hong Kong has become one of the first global financial centers to complete the "legislation-examination-licensing" complete system loop, also meaning that the regulation of stablecoins has officially transitioned from policy design to licensed operation.

Among the flood of news, many have also noticed a thought-provoking signal: of the first batch of licensed entities, one is independently licensed by HSBC, while the other, Anchor Point Financial, is backed by a joint venture of Standard Chartered Bank (Hong Kong), Hong Kong Telecom, and Animoca Brands.

In other words, among the first entrants, HSBC and Standard Chartered are already two of the three major note-issuing banks in Hong Kong.

What does this mean?

1. From "Note-Issuing Banks" to "Stablecoin Issuers"

To be realistic, it is not surprising that the first batch of licenses went to HSBC and Standard Chartered, but the policy signals released behind this choice are worth a close reading.

This requires returning to Hong Kong's relatively unique currency issuance system. It is well known that Hong Kong's current paper currency system is primarily issued by commercial banks. Except for the HK$10 banknotes directly issued by the Hong Kong government (Monetary Authority), the HK$20, 50, 100, 500, and 1000 banknotes are issued by the three note-issuing banks: HSBC, Standard Chartered, and Bank of China Hong Kong.

In other words, regarding currency and financial infrastructure issues, Hong Kong has long accepted a very clear institutional arrangement: the frontend issuance function is undertaken by highly regulated commercial entities, while the regulatory authority controls system stability through rules, reserves, and prudential requirements.

Viewed within this framework, the first batch of stablecoin licenses being prioritized for issuers led by HSBC and Standard Chartered essentially continues the approach of "starting with the most reliable entities," aligned with Hong Kong's own monetary tradition.

For a newly institutionalized category, the first issuance of licenses is inherently a path choice for financial regulation that seeks stability, control, and error avoidance.

This is actually not difficult to understand.

Although stablecoins are dressed in the guise of "virtual assets," once they enter the institutionalized phase, regulators are never first concerned with the narrative but rather with several traditional and financial questions: Are reserve assets genuine? Is the redemption mechanism clear? Is risk isolation sufficient? Is the flow of funds controllable? Are anti-money laundering and traceability mechanisms reliable?

However, following this logic, another question naturally arises: Why is Bank of China Hong Kong absent among the three major note-issuing banks?

This matter clearly goes beyond a simple issue of qualifications or capabilities. In fact, Bank of China Hong Kong was widely regarded as an active participant in the first round of applications from August to September 2025, until October 2025, when joint statements from central authorities further clarified the policy boundaries, imposing stronger constraints on privately-issued stablecoins, especially those pegged to the Renminbi. Some institutions originally planning to participate, including Bank of China Hong Kong, Shanghai Commercial Bank, China Construction Bank (Asia), as well as large internet enterprises like Ant Group and JD.com, also shelved their plans.

Source: Fudan Research Institute

This also means that the issuance of the first batch of licenses to the two note-issuing banks is not only Hong Kong's instinct to seek stability at the initial stage but is also a realistic answer under the current cross-border policy environment, and whether Hong Kong stablecoins can go far will ultimately depend on who can truly expand this system in the next phase.

This is precisely what many discussions tend to overlook.

2. Compliance is important, but "license" ≠ "ecosystem"

In analyzing the prospects of Hong Kong stablecoins, an unavoidable reference is the development history of virtual banks in Hong Kong.

In 2019, the Monetary Authority issued virtual bank licenses to eight institutions. At that time, the market had high expectations, with many believing that the new licensing system would automatically foster new competitive dynamics and new financial experiences. By 2024, the Monetary Authority released a review report indicating that the market's overall response to the products and services offered by the eight virtual banks was positive, but it also clearly stated that the current number of virtual bank licenses was appropriate and that no new licenses would be issued for the time being.

This is a very typical reference sample. Looking back, virtual banks certainly have made some achievements, but the license did not automatically translate into market dominance, nor did it automatically translate into sustainable business models. This reveals a real issue, which is that in a financial system that already has mature profit pools, mature customer relationships, and mature settlement channels, there is often a long distance between system openness and market operability.

To put it simply, licenses can solve the issue of access but cannot solve issues related to user habits, scene coverage, business efficiency, and network effects.

The same applies to stablecoins, and the difficulty will only be higher.

After all, unlike virtual banks, stablecoins not only have to compete with the traditional financial system but also engage in a game against "established players" like USDT and USDC, which are already deeply embedded in exchanges, on-chain protocols, and wallet systems.

Ultimately, it is not enough to obtain a license to automatically have a market; the license only ensures that you may be allowed and trusted to issue stablecoins, but it does not solve other, more challenging questions: Why would users want to use your stablecoin? Why would trading platforms, wallets, merchants, market makers, and corporate financial systems be willing to accept your stablecoin? Why would funds be willing to stay, flow, and settle within your system, ultimately forming a network effect?

In other words, issuance is a qualification on the supply side; ecosystem is the answer on the demand side.

If viewed from the perspective of market competition, the real test began from the moment a license was issued, as the competitive chain of stablecoins includes at least five stages:

• Issuance, addressing "Is there one?"

• Distribution, addressing "Is it reaching users?"

• Liquidity, addressing "Is it frictionless to enter and exit?"

• Scenarios, addressing "What can be done besides holding?"

• Operations, addressing "How to ensure compliance, settlement, risk control, identity recognition, and user experience run stably in the long term?"

In these five stages, issuance is merely the first.

This is also why the external criticism of "Hong Kong stablecoins cannot only have licenses" should not be simply understood as pessimism; on the contrary, such criticism points out that Hong Kong stablecoins must genuinely undertake to address the real homework in the next stage—after licensing, if there is not enough strong distribution capability, liquidity organization capability, and scenario acceptance capability, Hong Kong stablecoins are likely to remain correct at the institutional level but struggle to achieve success at the commercial level.

Today’s global stablecoin market is no longer a market that can win users solely based on compliance labels. User habits, entry of scenarios, trading depth, settlement efficiency, wallet integration, fiat deposit and withdrawal capabilities, and developer interfaces are the key variables determining whether a stablecoin can truly thrive.

From the development trajectory of overseas markets, this shift in focus has become very obvious.

After completing the acquisition of Bridge, Stripe no longer merely treats stablecoins as a marginal payment capability, but further incorporates it into enterprise funds management and global payment systems. For example, the Stablecoin Financial Accounts launched in 2025 aimed at businesses in 101 countries, followed by Open Issuance powered by Bridge, tries to upgrade stablecoins from alternative assets to "payment capabilities that can be embedded within enterprise financial systems."

Circle's actions are similarly representative. Recently, Circle has been pushing USDC towards a more "programmable payment" direction: on one hand, it promotes self-service payments based on x402, allowing AI agents to use USDC for automated payment APIs, computational power, data, and content; on the other hand, it is advancing the standardization of very small payments machine-to-machine.

This indicates that in the eyes of the most astute payment infrastructure players, the focus of stablecoin competition is no longer solely on issuance qualifications, but on who can turn them into financial foundations that enterprises can invoke, settle, and manage.

Hong Kong has also had related practices; even before the official implementation of the "Stablecoin Regulation" last year, the licensed OSL Group launched three new products targeted at institutions: the compliant stablecoin management platform StableX, the asset tokenization service Tokenworks, and the enterprise-level cryptographic payment solution OSL BizPay. In 2026, it launched a compliant USD stablecoin, USDGO, adhering to US federal regulations and can be compliantly distributed in Hong Kong, primarily targeting cross-border e-commerce, bulk trade, and interactive entertainment.

Placed in this context, a more critical question emerges regarding Hong Kong, namely, the first batch of licenses issued addresses "who can safely enter first," but whether Hong Kong can form a truly competitive stablecoin ecosystem will depend on "who can fill in the other four tasks."

3. Issuance is not the endgame, ecosystem builders are key

From the structure of the global stablecoin market, the pattern of ecological division of labor has become increasingly clear.

The most notable feature is the high concentration at the issuance end. For example, USDT and USDC together account for over 86% of the total market value of stablecoins, but the scale advantage of issuers does not automatically equate to ecological control. The true competitiveness of stablecoins often depends not only on issuance scale but more significantly on liquidity depth, channel coverage, and scenario penetration.

For instance, although USDC has only 42% of the market value of USDT, its on-chain transfer volume, institutional payment scenarios, and developer ecosystem engagement are significantly higher. Behind this is the effect of the distribution network and scenario acceptance capability, rather than merely the issuance volume; and while PYUSD’s lawful issuer is Paxos, its expansion is genuinely driven by PayPal's account distribution capabilities.

This all indicates that issuers of stablecoins and ecosystem builders are two different combinations of capabilities:

• The issuer is responsible for reserve management, compliance risk control, and redemption mechanisms, which are the core tasks of the "issuance layer";

• The ecosystem builder is responsible for distribution channels, liquidity aggregation, scenario access, and commercial operations, which are the core tasks of the "application layer."

The two are not mutually exclusive but rather representing a collaborative relationship between upstream and downstream.

If we compare the stablecoin ecosystem to a tall building, then the issuer obtaining a license is merely receiving the foundation construction approval. What really decides how high the building can be built is the load-bearing structure of each subsequent floor, and distribution channels, transaction liquidity, payment networks, scenario access, and compliance operation capabilities are precisely part of that load-bearing structure.

Therefore, the genuine test faced by Hong Kong's stablecoins might never have been "who can obtain a license," but rather "after obtaining the license, who can truly utilize it."

This is also why the truly scarce resource for Hong Kong stablecoins in the next stage may not merely be new issuers, but rather those ecosystem platforms capable of addressing distribution, trading, payment, liquidity, and compliance operations.

In fact, even the first licensed institutions are already demonstrating this through their actions. According to reports, Anchor Point Financial plans to work with selected enterprises as distribution partners to offer its stablecoins to the public; HSBC, on the other hand, plans to reach users through the PayMe and HSBC HK Mobile Banking apps.

In other words, even for the first issuers to obtain licenses, the first response post-implementation is not "I can finally issue coins," but rather "how should I distribute them," which itself indicates that stablecoins are not a business accomplished solely by the issuer, but a system engineering effort that must rely on multi-layered ecological collaboration.

It is in this sense that what is truly scarce in the next phase for Hong Kong is not merely new issuers, but rather ecosystems capable of embedding distribution, trading, payment, liquidity, and compliance operations.

This is also the most crucial position worth recognizing in this round of discussions—integrated capability platforms that can simultaneously connect the issuance side, circulation side, and usage side may genuinely determine the height of Hong Kong's stablecoin ecosystem.

The previously mentioned Hong Kong licensed player, OSL, has already expressed its intention to actively cooperate with licensed stablecoin issuers in Hong Kong, leveraging its advantages in distribution, liquidity, and infrastructure to push related products and application scenarios into implementation. This statement implies that it is proactively positioning itself to lay the "capillary" services for this stablecoin ecosystem.

Objectively speaking, for a market that has just started and inherently requires multi-party collaboration, the scarcity of such roles may be no less than that of the issuance license itself.

Even this could be the key variable determining whether Hong Kong's stablecoin can secure a place in global competition.

Final Thoughts

Returning to a more macro perspective, the situation Hong Kong stablecoins face today is indeed challenging.

Looking towards mainland China, the policy stance is unlikely to loosen in the short term; looking overseas, the barriers of user habits and network effects are already very high. In this framework, if Hong Kong's stablecoin ecosystem remains at the level of "licensing-issuing-compliance," it is likely to repeat the plight of virtual banks—institutions built well, and data sound; yet a bigger ecosystem fails to materialize.

But conversely, this also represents where Hong Kong's window of opportunity lies.

The global stablecoin market is undergoing a profound paradigm shift, with stablecoins redefined not just as a medium of exchange within the crypto market but as the foundational infrastructure for the next generation of global payments and settlements. In this new paradigm, compliance capabilities are no longer the sole competitive dimension; distribution networks, payment scenarios, technical infrastructure, and ecosystem operation capabilities have become equally or even more critical.

As an international financial center, Hong Kong inherently possesses advantages in institutional design and compliance governance, but to translate this advantage into the competitive strength of its stablecoin ecosystem, merely relying on the first batch of licenses is clearly insufficient; it requires payment companies, technology platforms, compliance middleware, native Web3 enterprises, and local licensed institutions to layer by layer implement the more challenging and authentic tasks of distribution, liquidity, scenarios, and operations.

The path after licensing is still long, and the real competition of Hong Kong stablecoins has only just begun.

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