New Era of Stablecoin Regulation: Reshaping the Global Market Landscape and Outlook for the Next Decade

With the United States and Hong Kong successively launching legislation related to stablecoins, the global digital asset market has officially entered a new growth cycle driven by regulation. These regulations not only fill the regulatory gap for stablecoins pegged to fiat assets but also provide the market with a clear compliance framework, including reserve asset segregation, redemption guarantees, and anti-money laundering compliance requirements, effectively reducing systemic risk.

This article will delve into the core framework of the two major bills, combining quantitative forecasts to systematically project the ten-year growth trajectory of compliant USD stablecoins and their restructuring effects on the public blockchain ecosystem.

I. Growth Momentum and Quantitative Simulation of US Dollar Stablecoins under the US Act

The "GENIUS Act" (Guiding and Establishing National Innovation for U.S. Stablecoins Act), passed by the U.S. Senate in May 2025, marks a critical step for the United States in stablecoin regulation. The Act establishes a detailed regulatory framework for stablecoin issuers, requiring them to maintain reserves backed by highly liquid assets, such as cash in U.S. dollars, short-term U.S. government bonds, or government money market funds, at a minimum ratio of 1:1. It also mandates regular audits and compliance with anti-money laundering (AML) and know your customer (KYC) requirements. Additionally, the Act prohibits stablecoins from offering interest yields, restricts foreign issuers from entering the U.S. market, and clarifies that stablecoins are neither securities nor commodities, thus providing a clear legal positioning for digital assets. This legislation aims to strengthen consumer protection, mitigate financial risks, and provide a stable regulatory environment for fintech innovation.

The implementation of the "GENIUS Act" is expected to have a profound impact on the global cryptocurrency market landscape. Firstly, investing in highly liquid USD assets that do not allow for interest will directly benefit the issuance of U.S. Treasury bonds, making stablecoins an important channel for distributing U.S. Treasury bonds. This mechanism not only alleviates the financing pressure of the U.S. fiscal deficit but also reinforces the international settlement position of the dollar through digital currency channels. Secondly, a clear regulatory framework may attract more financial institutions and technology companies to enter the stablecoin sector, promoting innovation and efficiency in payment systems. However, the Act has also sparked some controversies, such as the potential conflicts of interest arising from the Trump family's involvement in the cryptocurrency industry, as well as international regulatory coordination issues that may arise from restrictions on foreign issuers. Nevertheless, the "GENIUS Act" provides institutional guarantees for the development of stablecoins, marking an important step for the United States in the global competition for digital asset regulation.

According to predictions from a well-known financial institution, under the scenario of clearer regulatory pathways, the global stablecoin market value is expected to grow from $230 billion in 2025 to $1.6 trillion by 2030. It is worth noting that this prediction implies two key assumptions: first, compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving about $40 billion in international remittance costs each year; second, the amount of stablecoins locked in DeFi protocols will exceed $500 billion, becoming the foundational liquidity layer of decentralized finance.

2. The Differentiated Positioning of Hong Kong's Stablecoin Regulatory Framework

The recent release of the "Stablecoin Regulation" by the Hong Kong Special Administrative Region government marks a significant progress in its systematic layout in the Web 3.0 field. The regulation establishes a licensing system for stablecoin issuance, requiring issuers to obtain permission from the Hong Kong Monetary Authority (HKMA) and meet strict requirements regarding reserve asset management, redemption mechanisms, and risk control. Additionally, Hong Kong plans to introduce a dual licensing system for over-the-counter (OTC) trading and custody services within the next two years, further improving the comprehensive regulatory framework for virtual assets. These measures aim to enhance investor protection, increase market transparency, and consolidate Hong Kong's position as a global digital asset hub.

The Hong Kong Monetary Authority plans to release operational guidelines on the tokenization of real-world assets (RWA) in 2025, promoting the on-chain tokenization process of traditional assets such as bonds, real estate, and commodities. By using smart contract technology, functions such as automatic dividends and interest distribution will be realized. Hong Kong is committed to building an innovative ecosystem that integrates traditional finance with blockchain technology, opening up broader application spaces for the development of Web 3.0. Under Hong Kong's regulatory framework, the issuance of stablecoins will show a prosperous development trend with multiple currencies and scenarios, further consolidating Hong Kong's position as a technology and finance hub.

Although the Hong Kong "Stablecoin Regulation Draft" draws on the regulatory logic of the United States, it shows significant differences in implementation details.

III. The Evolution of the Global Stablecoin Landscape under Regulatory Competition

(1) The strengthening effect of the US dollar stablecoin as a global reserve currency

Under the regulatory framework established by the GENIUS Act, payment stablecoins must be backed by U.S. Treasury securities as reserve assets. This provision gives U.S. dollar stablecoins strategic significance beyond the realm of digital currencies. Essentially, these stablecoins have become a new distribution channel for U.S. Treasury securities, creating a unique capital circulation system globally: when global users purchase stablecoins denominated in U.S. dollars, the issuing institutions must allocate the corresponding funds to U.S. Treasury assets. This not only facilitates the flow of funds back to the U.S. Treasury but also invisibly strengthens the global usage of the U.S. dollar. This mechanism can be seen as a globalization extension of U.S. dollar financial infrastructure.

From the perspective of international settlement, the emergence of stablecoins marks a paradigm shift in the dollar clearing system. In the traditional model, cross-border flows of the dollar are highly dependent on interbank settlement networks such as SWIFT, while blockchain-based stablecoins are embedded directly into various compatible distributed payment systems in the form of "on-chain dollars." This technological breakthrough means that the dollar's settlement capability is no longer limited to traditional financial institutions. This not only expands the international use cases of the dollar but also represents a modernization upgrade of dollar settlement sovereignty in the digital age, further consolidating its core position in the global monetary system.

(2) Challenges of Regulatory Coordination in Asia between Hong Kong and Singapore

Although Hong Kong was the first to establish a stablecoin licensing system, the Monetary Authority of Singapore (MAS) simultaneously launched a "stablecoin sandbox" that allows experimental issuance of tokens pegged to existing fiat currencies. Regulatory arbitrage between the two regions may trigger issuers' "regulatory site selection" behavior, and it is necessary to establish unified reserve audit standards and anti-money laundering information sharing mechanisms through the ASEAN Financial Regulatory Forum.

Although Hong Kong and Singapore have similar goals in their stablecoin regulatory policies, their implementation paths show significant differences. Hong Kong adopts a prudent tightening regulatory approach, with the Monetary Authority planning to establish a statutory stablecoin licensing system, positioning stablecoins as "substitutes for virtual banks" and strictly adhering to traditional financial regulatory frameworks. In contrast, Singapore adheres to an experimental regulatory concept, allowing innovative pilot projects that link digital tokens to fiat currencies, reserving flexible space for technological and business model innovations, and adopting an overall regulatory attitude of tolerance for trial and error.

These regulatory differences may lead issuers to selectively register to circumvent strict scrutiny or to engage in arbitrage operations by taking advantage of the differences in regulatory standards, thereby undermining the effectiveness of the oversight of fiat currency pegging mechanisms. In the long term, if there is a lack of coordination, this divergence may compromise regulatory fairness and policy consistency, and even trigger regional regulatory competition risks, causing both places to fall into a self-consuming competition. Furthermore, the lack of uniform regulatory standards may weaken Asia's voice in the global stablecoin system, thereby affecting the competitiveness of Hong Kong and Singapore as international financial centers.

Regulatory agencies in both regions need to strengthen policy coordination to seek a better balance between preventing systemic risks and encouraging financial innovation, in order to enhance Asia's overall influence in global digital financial governance.

Conclusion: Regulatory Clarity Opens a Golden Decade for Stablecoins

The joint implementation of the US GENIUS Act and the Hong Kong regulatory draft marks a shift in digital asset regulation from fragmentation to systematization. Compliant US dollar stablecoins are expected to achieve exponential growth within a decade, becoming the core bridge connecting traditional finance and the crypto ecosystem. The technological evolution of public chain infrastructure will determine whether it can capture the maximized value dividend within the regulatory framework. For issuers, building a multi-chain, multi-coin, and multi-regulatory compliant stablecoin system will be the key strategy to win the competition in the next decade.