Global Stablecoin Regulation Ushers in Historic "Trilogy": GENIUS Bill, Hong Kong License, and MiCA

In March 2026, global stablecoin regulation ushers in a historic “triple play.”

On March 5th, the Hong Kong Monetary Authority announced that the first batch of fiat-backed stablecoin licenses is entering the issuance phase, with traditional financial institutions like HSBC and Standard Chartered leading the race. Three days later, the U.S. Office of the Comptroller of the Currency (OCC) released a proposal to implement the GENIUS Act, establishing a comprehensive federal licensing and prudential regulatory framework for payment stablecoin issuers. Almost simultaneously, the UK fintech company BVNK received a crypto asset service provider license from the Malta Financial Services Authority, becoming one of the few entities with both MiCA compliance and access to the European payment network.

Across the ocean, mainland China’s regulators also signaled clear intentions. On February 6th, the People’s Bank of China and eight other departments jointly issued Document No. 42, officially incorporating the tokenization of real-world assets (RWA) into the regulatory framework, with a dual-track approach of “strict domestic prohibition and overseas registration.” In late March, the digital renminbi operating institutions launched a new expansion round, with 12 commercial banks shortlisted, increasing the total number of operators from 10 to 22, marking the official entry of digital RMB into its second-generation institutionalized operation era.

These seemingly independent events are driven by the same underlying trend: stablecoins are rapidly moving from the “gray area” of the crypto world into the spotlight of mainstream finance. According to RWA.xyz, by March 2026, the on-chain value of tokenized real-world assets—excluding stablecoins—has surpassed $25 billion, with stablecoins themselves becoming the core “blood system” of this value migration—USDC’s monthly trading volume alone has reached $1.26 trillion, accounting for over 70% of total stablecoin activity.

However, while capital can cross borders instantly, regulation remains territorial. What are the three nearly simultaneous regulatory frameworks in the US, Hong Kong, and the EU competing for? What do their differences mean for enterprises? In the context of the official launch of Digital RMB 2.0, how should Chinese companies navigate this regulatory race?

This is a race that will determine the future landscape of global digital financial infrastructure over the next decade.

1. United States: The “Federal Licensing” Model Prioritizing Market Efficiency

On February 25, 2026, the OCC released a lengthy proposal to implement provisions related to the issuance of payment stablecoins under the GENIUS Act. This marks the first clear federal-level regulation for the private issuance of “digital dollars.”

The GENIUS Act, signed into law on July 18, 2025, established a three-tiered issuance structure for payment stablecoins: (1) subsidiaries of depository institutions approved by federal regulators; (2) federally qualified payment stablecoin issuers directly approved by the OCC; (3) state-qualified issuers approved by state regulators. The core idea is “diversified access”—avoiding complete detachment from traditional banking while preventing concentration in a few institutions.

The OCC’s proposal further refines these rules. Allowed activities for stablecoin issuers include issuing and redeeming stablecoins, managing reserves, providing custody services, and other activities directly supporting these core functions. The OCC acknowledges that “direct support” is somewhat ambiguous; for example, holding non-stablecoin crypto assets to test distributed ledger technology or pay network transaction fees could be considered permissible “direct support.” This cautious, case-by-case clarification reflects a pragmatic approach—setting boundaries while leaving room for innovation.

A notable aspect is the implementation of interest prohibition. The GENIUS Act bans stablecoin issuers from paying interest or yields to holders but does not explicitly prohibit related parties or “third parties” from providing indirectly funded yields—this has sparked intense industry and congressional debate. The OCC’s proposal responds by establishing a rebuttable presumption that such arrangements violate the interest prohibition. It also clarifies that merchants offering discounts for stablecoin payments or profit-sharing in white-label collaborations, as long as no interest or yields are transferred to holders, are outside the scope. An anti-avoidance clause is added to treat any circumvention arrangements as violations.

Regarding reserves, the proposal requires issuers to maintain at least 1:1 high-quality reserve assets, including USD cash, deposits at approved depository institutions, short-term government bonds (within 93 days), certain repurchase agreements, and registered government money market funds. Notably, the proposal explicitly excludes stablecoins and other cryptocurrencies from qualifying reserves. Reserves are valued at fair market value, while circulating stablecoins are valued at face value—meaning even if stablecoins decouple in secondary markets, issuers must maintain reserves equal to all circulating stablecoins’ face value.

The redemption mechanism anticipates extreme scenarios. Typically, redemption requests are fulfilled within two business days, but if redemption requests within 24 hours exceed 10% of total circulation, the redemption period can extend up to seven calendar days. This “automatic extension” acts as a preemptive measure against bank run risks—giving issuers time to liquidate reserves and prevent systemic collapse.

On capital requirements, newly approved issuers must meet initial capital thresholds, including a minimum of $5 million during early regulation phases. This indicates that stablecoin issuance in the US is regarded as a regulated financial activity requiring substantial financial strength, not a lightweight, tech-driven product.

Anti-money laundering (AML) compliance is directly tied to licensing status. Issuers must provide board-level certification confirming AML compliance frameworks are in place. Failure to submit such certification could revoke licensing. This governance-focused design aims to reinforce the importance of compliance at the leadership level.

Overall, the US approach’s core logic is to “maintain dollar dominance in the digital age.” By lowering compliance barriers to attract more issuers, banning interest to prevent stablecoins from becoming deposit substitutes, and including foreign issuers to regulate global USD stablecoins, the rules aim not to stifle innovation but to bring it into a controllable, supervised framework—while reinforcing the dollar’s leadership in global digital payments.

2. Hong Kong: The “Compliance Extension” Model Connecting Chinese Assets

Hong Kong’s stablecoin regulation is equally swift. In August 2025, the “Stablecoin Ordinance” came into effect, establishing the world’s most stringent stablecoin regulatory framework. In February 2026, Chief Executive John Lee announced at Consensus Hong Kong that the first stablecoin licenses would be issued in March. The HKMA’s Chief Executive, Eddie Yue, disclosed that 36 license applications had been received, but the initial licenses would be limited—priority is given to stability over quantity.

Hong Kong’s strictness manifests in several dimensions: a minimum paid-up capital of HKD 25 million (five times US standards); 100% high-liquidity reserve assets, which must be held in Hong Kong; 24/7 AML monitoring; issuers must be registered entities with identifiable management and offices in Hong Kong. These high thresholds effectively exclude small and medium crypto firms, ensuring only reputable, resource-rich traditional financial institutions can participate.

This explains why the first licenses are held by giants like HSBC, Standard Chartered, and Bank of China Hong Kong. Standard Chartered, for example, launched integrated digital asset trading services for institutional clients as early as July 2025, with its UK branch offering spot trading of Bitcoin and Ethereum. Through subsidiaries like Zodia Custody, Zodia Markets, and Libeara, it provides end-to-end services from issuance to custody.

Hong Kong’s regulatory philosophy centers on “integrating stablecoin issuance into traditional financial oversight.” Stablecoins are viewed as an extension of “electronic money,” not a new asset class. Issuers must comply with strict AML, anti-terrorism financing, and disclosure requirements similar to traditional banks; reserves must be segregated and periodically disclosed; licensed entities are subject to ongoing supervision by the HKMA.

The stance on foreign stablecoins is also clear. Yue emphasized that even stablecoins compliant with foreign regulations must obtain a Hong Kong license to conduct retail business. Unlicensed foreign stablecoins cannot be marketed to retail investors. This “local licensing” principle aims to anchor the stablecoin ecosystem within Hong Kong’s regulatory perimeter, preventing offshore risks from propagating.

Hong Kong’s strategic goal is to become a “strategic hub” connecting Chinese mainland assets with global digital capital markets. This was exemplified on February 26, 2026, when the People’s Bank of China’s Digital Currency Research Institute and the HKMA jointly launched a cross-border RWA settlement pilot, successfully enabling real-time exchange and settlement between digital RMB and Hong Kong’s licensed stablecoins.

The test focused on cross-border infrastructure and agricultural trade. Traditionally, cross-border payments involve multiple intermediaries, taking about two hours and incurring high costs. In the pilot, the process was reduced to three minutes, with over 20% cost savings. The breakthrough was “atomic exchange”—simultaneous locking of digital RMB and issuance of equivalent stablecoins, eliminating counterparty credit risk.

This “digital RMB + Hong Kong stablecoin” dual-track collaboration creates a clear division of roles: digital RMB as the “value anchor and compliance channel,” ensuring legal and traceable fund flows; Hong Kong’s compliant stablecoins as “liquidity bridges,” leveraging 24/7 trading to connect global digital markets. Economist Fan Wenzhong describes this as a “public-private partnership” model—combining the security and compliance of sovereign currency with market-driven efficiency and flexibility.

For mainland enterprises, this collaboration offers a clear, compliant pathway for RWA exports. Whether it’s cross-border infrastructure project rights, supply chain financial assets from agricultural trade, green carbon credits, or commercial real estate rights, they can be tokenized and globally circulated via the digital RMB and Hong Kong stablecoin ecosystem.

3. EU: The “Comprehensive Prudence” Model Under System-First Approach

Across the Atlantic, the EU has chosen a different path. In June 2025, the European Banking Authority issued a “non-action letter,” clarifying the interaction between MiCA (Markets in Crypto-Assets Regulation) and PSD2 (Second Payment Services Directive). This seemingly technical document reveals a major regulatory challenge: from March 2, 2026, crypto asset service providers offering electronic money token custody and transfer services may need both MiCA crypto licenses and PSD2 payment service licenses.

This means the same activity could face two regulatory regimes, two capital requirements, and double compliance costs. MiCA requires a minimum capital of €125,000, and PSD2 also mandates €125,000—totaling nearly €290,000. Coupled with dual reporting and supervision, compliance costs could nearly double.

Patrick Hansen, policy lead at Circle, warned on social media that unresolved conflicts between MiCA and PSD2 could severely impair the EU’s digital financial competitiveness. He argued that this “dual licensing trap” violates principles of proportionality, legal clarity, and consistency—contradicting the EU’s goal of simplifying regulation and boosting innovation.

The root of the conflict lies in MiCA’s design: it aims to create a unified rulebook for crypto assets but overlaps with existing payment directives in custody and transfer of electronic money tokens. The European Banking Authority admits that ideally, all financial activities should be governed by a single law, but currently, MiCA and PSD2 both regulate stablecoin custody and transfer services.

The Authority has proposed two legislative amendments: (1) revise MiCA to incorporate relevant PSD2 payment service provisions, creating a single framework; (2) amend upcoming PSD3 and payment service regulations to exempt MiCA-licensed entities from separate electronic money token custody and transfer licenses. PSD3 is expected to be enacted after 2025, providing a limited window for policymakers to add specific exemptions before the March 2026 deadline.

The EU’s approach is fundamentally “system-first”—building a comprehensive rule system before the industry fully matures. The advantage is regulatory certainty: once compliant, firms can operate across 27 member states. The downside is high compliance costs and slow adaptation, which may initially hinder innovation.

However, the EU’s broader goal extends beyond regulation. The case of BVNK illustrates this. Founded in 2021 and headquartered in London, BVNK holds UK and EU electronic money institution licenses, as well as multiple US state money transfer licenses. By 2025, BVNK’s transaction volume exceeded $20 billion, serving over 130 countries. On March 17, Mastercard announced an $1.8 billion acquisition of BVNK—its largest digital asset deal to date.

BVNK’s appeal lies in its full-stack enterprise solutions—APIs, wallet management, compliance, liquidity management—reducing barriers for enterprises to adopt stablecoins. It supports stablecoins on all major blockchains, with fiat on/off ramps in USD, EUR, GBP, mainly for cross-border B2B settlement, payroll, and enterprise stablecoin issuance. This “compliance-first, tech-driven” model aligns with the EU’s regulatory vision—encouraging sustainable innovation within clear boundaries. Mastercard’s acquisition underscores traditional financial giants’ strategic bets on stablecoin infrastructure—following Stripe’s $1.1 billion purchase of stablecoin firm Bridge in 2024, and Visa’s strategic investment in BVNK.

4. Divergence in Convergence: The Five Core Principles Gaining Consensus

Comparing these three regulatory frameworks reveals clear differences. The US prioritizes “market efficiency,” allowing diverse issuers but imposing a $5 million minimum capital and strict interest bans. Hong Kong emphasizes “traditional financial extension,” restricting issuers to licensed institutions with HKD 25 million minimum capital and reserves held locally. The EU adopts a “comprehensive prudence” approach, with €250,000 dual capital requirements and complex overlaps between MiCA and PSD2.

Yet, beneath these differences, five core principles are increasingly converging globally:

1. 1:1 Reserve Principle—issuers must hold reserves equal to circulating stablecoins, ensuring redeemability.
2. Reserve Segregation—reserves must be segregated from issuer assets to prevent misuse.
3. Interest Ban—issuers cannot pay interest or yields to holders; stablecoins are “payment tools,” not “investment assets.”
4. AML Compliance—strict KYC, transaction recording, and reporting obligations.
5. Consumer Protection—through reserve requirements, disclosures, and redemption rights.

This pattern of “principle convergence with detailed divergence” reflects each jurisdiction’s contest for “rule-setting authority”—who can craft rules that lower compliance costs, enable flexible operations, and maintain financial stability, thereby gaining an advantage in the next decade of digital finance.

For Chinese enterprises, understanding this landscape of divergence and convergence is itself a strategic capability.

In March 2026, as the regulatory frameworks of the three major economies are nearly simultaneously implemented, we witness a historic moment: the end of the “Warring States” era of digital finance, and the emergence of a “new order” led by rules.

The US chooses “efficiency first”—driving innovation through market forces and maintaining dollar hegemony. Hong Kong opts for “compliance extension”—endorsing digital assets with traditional financial prudence, serving as a bridge between China and the world. The EU pursues “system-first”—setting high standards to shape global rules.

There are no absolute right or wrong choices—only strategic differences aligned with different resources and goals. For Chinese companies, understanding these differences is a strategic skill—between the institutionalized operation of Digital RMB 2.0 and the compliant pathways of Hong Kong stablecoin licenses, a fast lane connecting mainland high-quality assets with global digital capital has already been paved.

As Mastercard’s acquisition of BVNK shows, stablecoins are no longer niche crypto experiments but foundational to the next-generation global payment network. Those who find their own path in the regulatory race will seize opportunities in the wave of digital civilization. The starting point of this path is understanding the rules; the destination is shaping the rules.

(Data sources: People’s Bank of China official announcements, OCC proposals, 21 Finance reports, Economic Herald, Mobile Payment Network, The National Law Review, Weekly Economic Reports. All data as of March 2026.)