New Global Stablecoin Regulatory Landscape and Its Ten-Year Rise Prospects

With the United States and Hong Kong successively introducing regulations 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 gaps concerning stablecoins pegged to fiat currencies but also provide the market with a clear compliance framework, including asset reserve isolation, redemption guarantees, and anti-money laundering compliance requirements, effectively reducing systemic risk.

This article will analyze the core framework of regulations in two regions, combining quantitative analysis to systematically forecast the growth trajectory of compliant US dollar stablecoins over the next decade and their transformative effects on the blockchain ecosystem.

1. The Rise Dynamics and Quantitative Analysis of the US Stablecoin Bill

The United States' "Stablecoin Innovation and Regulatory Act" (GENIUS Act) was passed in the Senate in May 2025, marking a key step for the U.S. in the field of stablecoin regulation. The bill establishes a detailed regulatory framework for stablecoin issuing institutions, requiring issuers to hold at least 1:1 high liquidity assets as reserves, including U.S. dollar cash, short-term U.S. Treasury bills, or government money market funds, and to undergo regular audits while complying with anti-money laundering and know your customer requirements. The bill also prohibits stablecoins from providing interest yields, restricts foreign issuers from entering the U.S. market, and clarifies that stablecoins are neither securities nor commodities in legal terms. This legislation aims to enhance consumer protection, mitigate financial risks, and provide a stable regulatory environment for fintech innovation.

The implementation of the bill is expected to have a profound impact on the global cryptocurrency market landscape. Firstly, investing in high-liquidity dollar assets that do not allow for interest accumulation will directly benefit the issuance of U.S. Treasury bonds, making stablecoins an important channel for the distribution of U.S. Treasury bonds. This mechanism not only alleviates the financing pressure of the U.S. fiscal deficit but also strengthens the dollar's position in international settlement 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 improvements in payment systems. However, the bill has also sparked some controversies, such as potential conflicts of interest and the international regulatory coordination issues that may arise from restrictions on foreign issuers. Nevertheless, the bill provides institutional guarantees for the development of stablecoins, marking an important step for the United States in the global regulatory competition for digital assets.

According to a certain data platform's forecast, under a clear regulatory path, the global stablecoin market value will rise from $230 billion in 2025 to $1.6 trillion in 2030. This prediction is based on two key assumptions: first, compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving approximately $40 billion in international remittance costs each year; second, the amount of stablecoins locked in decentralized finance protocols will exceed $500 billion, becoming the foundational liquidity layer of decentralized finance.

2. The Unique 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 and meet strict requirements in areas such as reserve asset management, redemption mechanisms, and risk control. In addition, Hong Kong plans to introduce a dual licensing system for over-the-counter 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 solidify Hong Kong's position as a global digital asset center.

The Hong Kong Monetary Authority plans to release operational guidelines on the tokenization of physical assets in 2025, promoting the on-chain tokenization process of traditional assets including bonds, real estate, and commodities. Through smart contract technology, functionalities 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 fintech hub.

The Hong Kong "Stablecoin Regulation Draft" draws on American regulatory logic, but there are significant differences in implementation details. For example, Hong Kong allows the issuance of multi-currency stablecoins, while the U.S. only permits U.S. dollar stablecoins; the restrictions on reserve assets in Hong Kong are relatively lenient, whereas the U.S. is more stringent; regarding the redemption mechanism, Hong Kong requires redemption to be completed within 7 days, while the U.S. does not specify a concrete timeframe; additionally, Hong Kong has a more open attitude towards foreign issuers, while the U.S. has set higher thresholds.

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

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

Under the regulatory framework established by the stablecoin bill in the United States, payment stablecoins must have U.S. Treasury securities as reserve assets. This requirement gives U.S. dollar stablecoins a strategic significance that transcends 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 as Treasury securities. This not only facilitates the return of funds to the U.S. Treasury but also subtly strengthens the global usage of the U.S. dollar. This mechanism can be seen as a globalization extension of the U.S. dollar's financial infrastructure.

From the perspective of international settlement, the emergence of stablecoins marks a paradigm shift in the US dollar settlement system. In the traditional model, the cross-border flow of dollars heavily relies on interbank settlement networks, whereas blockchain-based stablecoins directly embed "on-chain dollars" into various compatible distributed payment systems. This technological breakthrough means that the dollar's settlement capacity is no longer restricted 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 launched a "stablecoin sandbox" at the same time that allows experimental issuance of tokens pegged to existing fiat currencies. Regulatory arbitrage between the two regions may lead to issuers engaging in "regulatory site selection" behavior, necessitating the establishment of 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 regarding stablecoin regulatory policies, their implementation paths show significant differences. Hong Kong adopts a cautious 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 maintains an experimental regulatory philosophy, allowing innovative pilot projects linking digital tokens to fiat currencies, reserving flexibility for technological and business model innovations, and overall adopting a regulatory attitude of tolerance for errors.

This regulatory disparity may lead issuing institutions to selectively register to evade strict scrutiny or to exploit differences in regulatory standards for arbitrage operations, thereby undermining the review effectiveness of fiat currency peg mechanisms. In the long term, if there is a lack of coordination, this divergence may disrupt regulatory fairness and policy consistency, and even trigger regional regulatory competition risks, causing both regions to fall into a state of internal 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, seeking a better balance between preventing systemic risks and encouraging financial innovation, in order to enhance Asia's overall influence in global digital finance governance.

Conclusion: Regulatory Clarity Opens a Golden Decade for Stablecoins

The joint implementation of the US stablecoin bill and the Hong Kong regulation draft marks the transition of digital asset regulation from fragmentation to systematization. Compliant US dollar stablecoins will achieve an order of magnitude rise within the next 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 maximum value dividends 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.