Comparison of the stablecoin bills in Hong Kong, the United States, and the European Union

On May 21, 2025, the Hong Kong Legislative Council passed the third reading of the Stablecoin Bill. It still needs to be signed by the Chief Executive and published in the Gazette before it can take effect. It is expected that the transition period will be completed within 2025, and the first batch of compliant stablecoins may be launched in early 2026.

In February 2025, Senator Bill Hagerty formally proposed the US Stablecoin Act, the GENIUS Act, which aims to establish a federal and state dual-track regulatory framework. On May 20, 2025, the US Senate passed the "end of debate" vote with 66 votes in favor, entering the formal legislative process. The next step is to vote on the House of Representatives and be signed by the President. If both houses pass, it may be signed and take effect by the President as early as the end of May 2025.

The EU Stablecoin Act, namely the Crypto-Asset Market Regulation Act (MiCA), was passed by the European Parliament in April 2023. It will take effect in stages. The first stage (stablecoin-related provisions): will take effect on June 30, 2024, covering the regulatory rules for electronic money tokens (EMT) and asset reference tokens (ART). The second stage (other crypto asset service terms): will be fully implemented on December 30, 2024.

Combined with the public information collected, we conduct a comprehensive comparative analysis of the stablecoin-related requirements in Hong Kong, China, the United States, and the European Union from the perspectives of legislative purpose, regulatory scope, regulatory body, issuing body, issuance procedure, regulatory requirements, usage scenarios, and extraterritorial supervision.

1. Legislative Purpose

Hong Kong, ChinaThe main purpose is to strengthen the supervision of stablecoins and protect the interests of investors and the stability of the financial system. As an emerging digital asset, the widespread use of stablecoins may have potential impacts on Hong Kong's financial system, such as affecting the transmission of monetary policy and the security of the payment system. The legislation aims to regulate the issuance and use of stablecoins and prevent financial risks.

The core goal is to balance financial stability and innovation, consolidate the status of an international financial center, promote offshore RMB stablecoins as a "digital bridge" for cross-border payments, and attract global Web3 projects to land.

The features areEmphasis on compatibility and openness, leaving room for future stablecoin innovations (such as interest income, multi-currency anchoring).

United StatesAims to promote financial innovation while ensuring financial stability. The use and development of stablecoins in the United States provide new ways and tools for financial transactions, but there are also potential systemic risks. The bill attempts to find a balance between encouraging innovation and maintaining stability, and provides a framework for the legal and safe operation of stablecoins.

The core goal is to maintain the hegemony of the US dollar, prevent systemic risks, promote payment stablecoins to become an extension of the "on-chain US dollar", and serve the US fiscal financing needs (such as absorbing short-term US debt).

The characteristics are to explicitly exclude the compliance of non-US dollar stablecoins and restrict the financial attributes of stablecoins (such as prohibiting interest).

European UnionThe legislative purposes include protecting investors, maintaining financial stability and promoting financial innovation. With the increasing trading and use of crypto assets, including stablecoins, in the EU, the framework hopes to regulate market order through unified regulatory standards, prevent fraud and market manipulation, and create a favorable regulatory environment for legal crypto asset transactions and stablecoin issuance.

The core objective is to establish a unified regulatory framework to protect consumers and market integrity, promote the application of distributed ledger technology (DLT), maintain financial stability in the euro area, and prevent the transmission of crypto-asset risks to the traditional financial system.

II. Scope of Supervision

Hong Kong, ChinaThe scope of stablecoin supervision is mainly for specific stablecoins, that is, stablecoins that are pegged to legal currencies or whose value stabilization mechanism is related to legal currencies. These stablecoins are usually used in scenarios such as payment and transaction medium, and are highly related to the financial system, so they are the focus of supervision. CoverageFiat-pegged stablecoins (such as Hong Kong dollars and US dollars), covering activities such as issuance, reserve management, and advertising promotion. Algorithmic stablecoins are not explicitly prohibited, but they must meet reserve requirements.

The United Stateshas a broad definition of stablecoins, including any digital asset that attempts to maintain its value linked to a specific asset. This covers stablecoins that are linked to assets such as legal tender and precious metals. At the same time, it also involves various links such as the issuance, circulation, and related financial service providers of stablecoins. CoverageLimited to payment stablecoins anchored to the US dollar, requiring 1:1 redemption and no interest attributes; non-US dollar stablecoins are restricted in compliance. Security-type stablecoins are regulated separately by the SEC, and algorithmic stablecoins are not included in the framework.

The EUregulatory scope includes all types of crypto assets, of which stablecoins, as an important category, are subject to stricter regulatory provisions. Its supervision not only focuses on stablecoins themselves, but also involves areas such as the issuance, trading, custody and related market infrastructure of stablecoins. CoverageElectronic money tokens (EMT, such as the euro stablecoin) and asset reference tokens (ART, such as multi-currency stablecoins), explicitly excluding algorithmic stablecoins. Central bank digital currencies (CBDCs) and stablecoins issued by public institutions are not applicable.

III. Regulatory bodies

Hong Kong, Chinais licensed and regulated by the Hong Kong Monetary Authority (HKMA), and the Securities and Futures Commission (SFC) coordinates anti-money laundering reviews. The Hong Kong Monetary Authority (HKMA) is one of the main regulatory bodies and plays a key role in the regulation of stablecoins. At the same time, other financial regulatory agencies such as the Hong Kong Securities and Futures Commission may also participate in the regulatory work based on the specific business activities of stablecoins, such as stablecoin transactions involving securities.

The regulatory bodies in the United States are more complex, including the Office of the Comptroller of the Currency (OCC), the Federal Reserve, etc. Federal and state dual-track supervision, banking institutions are supervised by the Federal Reserve and the FDIC, and non-bank institutions can choose federal (OCC) or state licenses. The OCC is mainly responsible for the supervision of financial institutions such as banks, and has the right to supervise the situation involving banks' participation in stablecoin business; the Federal Reserve regulates the systemic risks that stablecoins may bring from a macro-prudential perspective. In addition, the Securities and Exchange Commission (SEC) may also regulate stablecoin-related activities with securities attributes.

European UnionAt the EU level, institutions such as the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) play a coordinating role in the regulation of stablecoins. At the level of each member state, financial regulatory agencies of various countries, such as the German Federal Financial Supervisory Authority (BaFin), are responsible for the specific implementation of supervision. Regulatory agencies in each member state are responsible for the issuance of licenses, and the "license pass" system allows operations throughout the EU. The European Securities and Markets Authority (ESMA) coordinates cross-border issues.

IV. Issuing Entity

Hong Kong, ChinaRequires that the issuer must be a financial institution or enterprise that meets Hong Kong's financial regulatory requirements. These entities need to have sufficient capital strength to cope with the risks that may arise from the issuance of stablecoins, such as ensuring the safety of stablecoin reserve assets. At the same time, they also need to comply with Hong Kong's financial regulatory standards in terms of corporate governance and risk management.

The United States has stricter requirements for issuers. Generally speaking, the issuer of stablecoins needs to obtain the corresponding financial license. For example, if the stablecoin involves banking activities, such as the custody of stablecoin reserve assets, the issuer may need to obtain a banking license or cooperate with a bank. In addition, the issuer must meet the compliance requirements of the United States such as anti-money laundering (AML).

The European Union requires that the issuer of stablecoins be registered in the European Union and comply with the prudential regulatory requirements of the European Union. This includes provisions on the capital requirements, business rules, governance structure, etc. of the issuer. Only entities that meet these requirements can legally issue stablecoins within the European Union.

V. Issuance Procedures

Hong Kong, ChinaStablecoin issuers must submit an application to HKMA, including a white paper, a reserve management plan, anti-money laundering measures, etc. Existing issuers must apply for a license during the transition period. During the application process, a detailed stablecoin issuance plan must be provided, including the stablecoin's value anchoring mechanism, the management method of reserve assets, and risk control measures. The Hong Kong Monetary Authority will review the application materials, and the stablecoin can only be officially issued after the review is passed.

United StatesThe issuer of a stablecoin needs to register and apply in accordance with U.S. financial regulatory requirements. Banking institutions are directly subject to existing supervision, while non-bank institutions need to apply to the OCC or state regulators and pass monthly compliance reviews. During the application process, the relevant regulatory authorities should be provided with the issuance plan and compliance plan of the stablecoin. For example, if it involves banking-related business, it may be necessary to apply for approval from the Office of the Comptroller of the Currency. The regulatory authorities will conduct a strict review of the application to ensure that the issuance of stablecoins complies with the financial regulatory objectives of the United States.

European UnionThe issuer of stablecoins needs to prepare issuance documents in accordance with the regulatory requirements of the European Union and apply for registration and authorization with the relevant regulatory authorities. These documents include the white paper of the stablecoin, which details the technical architecture, value stabilization mechanism, and usage scenarios of the stablecoin. After receiving the application, the regulatory authorities will evaluate it according to the unified regulatory standards of the European Union to decide whether to approve the issuance. After approval in any member state, it can operate throughout the European Union. Documents such as technical standards and proof of reserves need to be submitted, and non-compliant projects need to be withdrawn during the transition period.

VI. Regulatory requirements

Hong Kong, ChinaIn terms of reserve assets, the issuer of stablecoins must have sufficient legal tender or other high-quality assets that meet the requirements as reserves of stablecoins to ensure the stability of the value of stablecoins. At the same time, there are also requirements for the transparency of stablecoin transactions. The issuer needs to regularly disclose the reserve assets, transaction data and other information of the stablecoins. In addition, in terms of anti-money laundering and combating terrorist financing, the issuer of stablecoins must establish a sound compliance system to identify and verify the identity of users.

United Statesemphasizes the stability and security of stablecoin reserve assets, and requires the issuer to properly manage and audit the reserve assets. In terms of transparency, the issuer of stablecoins needs to disclose to the public information such as the total amount of stablecoins issued, the composition and value of reserve assets. At the same time, it is necessary to comply with the strict anti-money laundering and counter-terrorist financing regulations of the United States and monitor and report suspicious transactions.

The European Union stipulates that the issuer of stablecoins must ensure that the reserve assets of stablecoins match the amount of stablecoins issued, and the reserve assets must be independently audited. In terms of information disclosure, the issuer is required to provide investors and regulators with accurate and complete information, including technical details of stablecoins, risk factors, etc. At the same time, the supervision of stablecoins in anti-money laundering and combating terrorist financing has been strengthened, and the issuer is required to take effective measures to prevent related risks.

VII. Scenarios and supervision

Hong Kong, ChinaFocus on expanding cross-border trade settlement, DeFi compliance clearing and retail payment scenarios, and encourage the integration of stablecoins with the real economy. The use scenarios of stablecoins are mainly concentrated in legal and compliant fields such as financial transactions and cross-border payments. As an international financial center, Hong Kong can use stablecoins for fund transfers between financial institutions and cross-border trade settlements of enterprises. However, some use scenarios that may pose risks, such as illegal financial transactions, will be strictly regulated and restricted.

United StatesPromote the use of stablecoins for on-chain payments, treasury bond financing and cross-border remittances, and restrict their entry into securities or commodity markets. Stablecoins are allowed to be used in a variety of financial transaction scenarios, including retail payments, securities trading settlements, etc. The use of stablecoins in the United States can improve the efficiency of financial transactions and reduce transaction costs. But at the same time, regulators will monitor the use of stablecoins to prevent them from being used for illegal activities such as money laundering and terrorist financing.

The European Unionfocuses on retail payments and financial infrastructure, and supports stablecoins as a supplement to the "digital euro". The use scenarios of stablecoins in the EU include payment, investment, etc. In the field of payment, stablecoins can be used for cross-border payments and e-commerce payments; in the field of investment, stablecoins can be part of an investment portfolio, but this must be done under the premise of complying with EU financial regulatory requirements. The EU pays attention to the risk assessment of stablecoin usage scenarios to ensure that they do not harm financial stability and consumer interests

VIII. Strategic Intentions

Hong Kong, Chinaintends to attract global innovative projects through flexible supervision, promote the internationalization of offshore RMB, and build an Asia-Pacific Web3 hub. For stablecoins issued overseas but traded and promoted in Hong Kong, Hong Kong financial regulators will regulate them based on their possible impact on Hong Kong's financial system. If the activities of overseas stablecoins pose a threat to Hong Kong's financial stability, investor interests, etc., Hong Kong regulators may take corresponding regulatory measures, such as requiring the provision of information and restricting transactions.

The United States intends to consolidate the hegemony of the US dollar in the digital age, use stablecoins to absorb the demand for US debt, and suppress competition from non-US stablecoins. US regulators will advocate the exercise of regulatory power for stablecoins issued overseas but involving US investors or having a significant impact on the US financial system. With its strong financial position and the principle of long-arm jurisdiction, the United States may require overseas stablecoin issuers to comply with relevant US laws and regulations, or restrict their business activities within the United States.

The EU intends to maintain the financial sovereignty of the euro area through unified supervision, prevent the spillover of crypto risks, and balance innovation and security. The EU will regulate stablecoins that are issued overseas but provide services within the EU or have an impact on the EU financial system according to their risk level. If the operation of overseas stablecoins does not meet the EU's regulatory standards, EU regulators may take measures, such as prohibiting them from doing business in the EU or requiring them to make rectifications, to ensure the security and stability of the EU financial market.

The stablecoin systems of the three major jurisdictions reflect different strategic orientations: Hong Kong focuses on openness and compatibility, the United States strengthens the dominance of the US dollar, and the EU pursues unity and security. In the future, compliant stablecoins will become the infrastructure of the on-chain economy, but their regulatory competition may also exacerbate the fragmentation of the global financial system. Enterprises need to choose a compliance path based on their business focus. For example, Hong Kong can be selected for cross-border scenarios, US dollar clearing focuses on the United States, and the European market must comply with MiCA standards.