In the regulation of Web3, Hong Kong cannot just copy homework.

Written by: Eric, Foresight News

At the end of August 2026, Chelsea officially announced Circle as the main sponsor on the front of the jersey for the 2026/27 season, marking the first time the USDC logo appears as the main sponsor on an English Premier League jersey.

This good news has posed a challenge for Hong Kong. Circle is not a licensed stablecoin issuer in Hong Kong, leading some fans and retailers to murmur about whether wearing or selling this jersey, and seeing it on television broadcasts, might cross the red line of actively promoting unauthorized stablecoins to the public in Hong Kong as prohibited by the "Stablecoin Ordinance"?

In response, the Hong Kong Monetary Authority stated that it does not comment on individual cases, and whether it constitutes active promotion should be judged based on specific factors such as language, target audience, domain name, and promotion plan. The fact that a jersey could lead fans to check legal provisions before placing an order indicates that there is a disconnect between the rules and the market.

Circle is taking a compliance-first approach that is rare in the cryptocurrency industry, holding over fifty licenses and registrations to date. In the U.S., it was one of the first companies to acquire a New York BitLicense, and after the implementation of the GENIUS Act in 2025, it applied for and received approval for an OCC national trust bank in July 2026. In Europe, it is the first global stablecoin issuer to fully comply with MiCA, and it holds licenses in the UK, Singapore, Bermuda, and Abu Dhabi.

Additionally, with weekly disclosures of reserves, independent audits, and 1:1 redemptions, Circle is essentially the most willing company in this industry to be regulated. But this time in Hong Kong, it may have to face the question: is your jersey legal?

Similar regulatory misalignment between the UK and Hong Kong is not happening for the first time. Previously, offshore betting brands like Fun88 and ManBetX on Premier League jerseys gained market access in the UK through white-label arrangements in the Isle of Man or Malta, proudly displayed on the chests of Newcastle and Wolves. However, when the two teams traveled to China for a friendly match in 2019, they removed the sponsor logos from their jerseys temporarily due to concerns about local laws.

The Hong Kong "Stablecoin Ordinance" came into effect in August 2025 and is one of the earliest markets to establish a complete licensing framework, but the result has been high expectations followed by a low reality. Last September, there were still 36 institutions eagerly submitting applications, but by August of this year, few were even talking about it. The first two licenses were granted to Dockpoint Financial led by Standard Chartered and HSBC, but the attitudes of the two companies were worlds apart.

Standard Chartered has been proactive in advancing projects, collaborating with Circle to launch institutional-grade USDC access services in July this year, and initiating the first phase of issuance for the HKDAP stablecoin in August. In contrast, HSBC has been the reluctant participant, continuously delaying its schedule. The reasoning is simple: about 85% of HSBC’s payment revenue comes from deposit interest spreads, and stablecoins divert deposits, effectively threatening its own business. Players like Ant Group, JD.com, and Yuan Coin, who have scenarios and motivations, find it difficult to enter the market. The consensus within the industry is that those with scenarios cannot enter, while those without scenarios insist on trying to participate.

There are also several significant flaws in the regulatory framework. The ordinance's requirements for identity verification almost extend to KYC at the holder level, which is more stringent than the U.S. "GENIUS Act," directly increasing the friction costs of cross-border payments. In terms of licensing pace, the regulator has made it clear that only a limited number of licenses will be issued moving forward, combining high thresholds with strict reviews, causing market sentiment to shift rapidly from excitement to watchful waiting.

Regarding only Circle's jersey advertisement, the definition of active promotion still remains a matter of case-by-case judgment; global sports sponsorship naturally involves cross-border exposure, and a jersey that will be seen by countless Hong Kong viewers in broadcasts raises the question of whether this counts as promotion. The Monetary Authority does not provide an answer, leaving retailers to guess.

The original intention of legislation in Hong Kong is commendable, and the sequence of prioritizing banks before others has stabilized the basic trust. However, the value of stablecoins lies in cross-border circulation and network effects. If every jurisdiction demands completely localized licensing combined with full KYC, the network will fragment, and the greatest selling point of payment efficiency will be lost. A mutual recognition mechanism, equivalence assessments, and layered regulation for wholesale and retail may be more realistic solutions. For the Monetary Authority, while it is understandable not to comment on individual cases, providing clearer guidance on everyday scenarios like jerseys, advertisements, and reposts could save the market a lot of unnecessary compliance anxiety.

On the other hand, the Hong Kong dollar is already pegged to the U.S. dollar. When designing the regulations for the Hong Kong dollar stablecoin, the compliance pathways for the already mature U.S. dollar stablecoins circulating in Hong Kong were not taken into account, and this issue has now emerged. In fact, there was considerable discussion when Hong Kong launched its cryptocurrency spot ETF. Despite having legalized cryptocurrencies and competing against firms like BlackRock, Hong Kong still insisted on launching a cryptocurrency spot ETF. Now, the number of Bitcoin and Ethereum in the ETF is lower than on the first day of its listing.

Hong Kong has always been relatively cautious in financial-related legislation, but in the compliance path of this emerging industry of Web3, it has also revealed issues of lack of professionalism. Having been used to copying homework, perhaps Hong Kong should consider making some changes in Web3.