New Regulatory Landscape for Stablecoins: Policy Trends from Hong Kong to Mainland China

On August 1, Hong Kong officially implemented the "Stablecoin Issuance and Reserve Management Ordinance." This ordinance clearly stipulates the issuance standards for stablecoins: only those anchored to the Hong Kong dollar are allowed, the issuing entities must obtain regulatory licenses, asset reserves are limited to local currency cash and bonds, and strict auditing and custody processes are required. This marks the formal transition of stablecoins from market-driven products to an extension tool of sovereign currency on the blockchain.

At the same time, mainland China is actively exploring policies related to stablecoins. From Hong Kong to the mainland, stablecoins have become an important topic in monetary policy and sovereign governance.

The Regulatory Paths of Three Global Stablecoins

Currently, the United States, the European Union, and Hong Kong represent three iconic models of stablecoin regulation.

USA: Market Dominance, Institutional Support

The United States has chosen a regulatory logic of "front-end openness and back-end support." After the passage of the GENIUS Act in 2025, stablecoins will be officially included under federal regulation, but the issuance rights will still be left to the market. As long as they are pegged to the US dollar, hold compliant reserves, and accept audits from the financial system, companies can issue "US dollar interfaces" on-chain. This allows the US dollar to naturally permeate all corners of Web3, but it also brings potential risks such as reserve breaches and delayed information disclosure.

EU: Built-in regulation, authority contraction

The EU has adopted a stricter regulatory approach. The MiCA legislation imposes high-intensity regulation on stablecoins, categorizing them as "significant tokens" once they reach specific standards, facing more restrictions. This "licensing-regulation" structure aims to control the scale penetration of stablecoins in cross-border settlements and local payments, but it may also stifle market vitality.

Hong Kong: License Pre-approval, Closed Scenario

Hong Kong has chosen the "preset boundary" regulatory model. Only stablecoins anchored to the Hong Kong dollar are allowed to apply for issuance, and issuers must be registered in Hong Kong and obtain a stored value payment instrument license, with circulation limited to approved local payment scenarios. This model of "regulatory embedding in financial instruments" emphasizes locking the issuance and use within controllable spaces from the outset, aiming for Hong Kong to secure a proactive position in the Asian stablecoin infrastructure.

Possible Pathways for the Renminbi Stablecoin

Recently, discussions on stablecoin policies in China have entered the high-level agenda. Based on the publicly available suggestions and policy context, the issuance structure of the RMB stablecoin may take the following form:

• Led by state-owned large banks or policy financial institutions to establish special purpose entities for issuance
• Anchored assets may choose policy financial instruments such as central bank bills, medium-term lending facilities, or some foreign exchange reserves.
• Adopting a dual-layer custody mechanism with on-chain issuance and off-chain audit settlement
• Prioritize license applications and cross-border usage testing in Hong Kong.
• Prioritize B-end service needs, such as cross-border payments, corporate clearing and settlement, etc.

This path design aims to promote the on-chain extension and offshore circulation structural reconstruction of the Renminbi, providing institutional tools for the internationalization of the Renminbi and the circulation of on-chain assets.

Opportunities for Entrepreneurs

If the renminbi stablecoin is implemented, it will be a public infrastructure led by the state or state-owned financial system. Web3 entrepreneurs should regard it as a callable system variable and build their business models around it:

1. Cross-border settlement tools: Develop payment APIs, settlement plugins, etc., to serve emerging markets.
2. Physical Asset Connection Interface: Development of RWA asset portfolio splitting and packaging, on-chain debt agreements, etc.
3. Application Scenarios Services: Promote the implementation of B2B cross-border payments, settlement within e-commerce platforms, and other scenarios.
4. Risk Management and Compliance Intermediary: Develop on-chain AML/KYC plugins, smart contract audit mechanisms, etc.

Although the RMB stablecoin is still in the policy discussion phase, its implementation has been incorporated into the national strategic vision. Entrepreneurs should plan in advance around directions such as payment, settlement, off-chain integration, and cross-border circulation to prepare for the possible policy opening in the future.