Zhiheng's statement | Talking about the stablecoin industry from the Hong Kong Stablecoin Ordinance
Author | Attorney Gao Shengjie
"Preface"
In the past seven months, the market size of stablecoins has increased significantly to 250 billion dollars, and the transfer scale has exceeded 35 trillion dollars, even exceeding the sum of traditional giants Visa and MasterCard.
At the regulatory level, the US "GENIUS Act" (the "Guiding and Establishing the US Stablecoin National Innovation Act") completed the final vote on June 17, 2025, marking the first federal regulatory framework for stablecoins in the United States; the "Stablecoin Ordinance" (Chapter 656 of the Laws of Hong Kong) and related implementation guidelines issued by China's HKMA came into effect on August 1, 2025, setting an important regulatory framework for the virtual asset industry in Hong Kong, which is a milestone.
For a while, the stablecoin was replaced byCryptocurrencyMarket to the global mainstream financial marekt, become the hottest topic.
This article will be based on the Hong Kong Stablecoin Ordinance, and discuss the current development status of the stablecoin industry and the future development potential of Hong Kong stablecoins from the perspectives of the global ecosystem, application scenarios, regulatory policies, and usage risks of stablecoins, with the hope that readers can form a preliminary understanding of the underlying logic and practical significance of stablecoins.
The past and present of stablecoins
(1) The concept and characteristics of stablecoins
Stablecoins are different from bitcoin (BTC), ethereum (ETH) and other volatile cryptocurrencies. Stablecoins are cryptocurrencies that anchor real assets and have relatively stable values. They have the main characteristics of stability, digitality, and currency, as well as the stability of fiat currencies and the advantages of fast circulation of cryptocurrencies.
(2) The origin of stablecoins
Due to the many problems of major cryptocurrencies such as Bitcoin, such as large price fluctuations, it is difficult to serve as a stable and reliable means of payment in real transactions, so stablecoins came into being. The world's first stablecoin was BitUSD, which was first launched on the blockchain in 2014. It was one of the first stablecoins to use cryptoassets as collateral, and its value was supported by cryptoassets such as BTS, the core token of BitShares (which launched the blockchain).
The same year also saw the launch of USDT, which pioneered the "fiat collateral" model, with issuers promising a 1:1 anchor to the US dollar, making USDT one of the mainstream stablecoins in the cryptocurrency market today.
(III) The mainstream model of stablecoins
Global stablecoin mechanisms can be roughly divided into three categories, each of which has its own advantages and risks, as shown in the table below:
(IV) The global market landscape of stablecoins
According to the 2025 global stablecoin industry development report released by the mobile payment network, as of July 2025, the global stablecoin market size has exceeded 250 billion US dollars. Among them, USDT still occupies the first place in the world with a total issuance of 159.40 billion US dollars, accounting for about 62.44%; USDC issuance is 61.90 billion US dollars, accounting for about 24.15%.
(5) The core application scenario of stablecoins - cross-border transfer
In traditional cross-border trade, cross-border transfer is mainly carried out through the US SWIFT system, which has many problems such as multiple transaction layers, low transaction efficiency (about 3-5 working days), and high transaction fees (1% -3%). Especially in financially underdeveloped regions or countries subject to geopolitical sanctions (such as Russia), traditional payment methods led by SWIFT are difficult to meet commercial needs.
In comparison to traditional payment models, stablecoins offer innovative solutions in the following areas:
1. Increased payment efficiency
The stablecoin settlement mode conducts transaction settlement through the blockchain network. The cost of on-chain transfer is less than $0.1, and the system operates 24/7. The payer does not need to go through the bank for complex exchange and exchange locking operations, and the system automatically executes the exchange through smart contracts. This process has no middlemen to make the difference, which not only avoids the waiting time cost caused by the inability of buyers and sellers to grasp the dynamics of funds in real time, but also saves more than 80% of the transfer fee.
2. Digitization of trade documents
Cross-border trade emphasizes the synchronization of information, funds and logistics, while the processing of traditional cross-border trade documents is more cumbersome - a bill of lading needs to go through more than 10 links and takes 7-10 days to circulate. Blockchain technology can link core documents such as bills of lading, invoices and letters of guarantee on the chain, enabling real-time data sharing among multiple parties, automatic identification and processing of information, reducing manual intervention and improving efficiency.
In addition, the blockchain electronic bill of lading (eBL), as an alternative to the paper ocean bill of lading, not only has the same legal effect and function, but also has the characteristics of data structure, tamper-proof, traceability, and programmability, which can better realize data verification and automatic execution.
Legend: Comparison between stablecoins and traditional payment paths
In the field of cross-border e-commerce, retail giants have shown active interest in stablecoins due to their significant advantages of high efficiency and low cost. Take JD.com as an example. In July 2024, JD.com Coin was selected as the first batch of "stablecoin issuer sandbox" participants by the Hong Kong Financial Supervisory Authority. In June 2025, it entered the second phase of the sandbox test. The test scenarios cover cross-border transfer, retail payment, etc.
If the final JD.com coin is approved for issuance, in the future JD.com upstream and downstream settlement system, JD.com can directly realize automatic clearing and settlement through smart contracts, that is, automatically use JD.com coin payment, without waiting for traditional bank transfer, this move may open up JD.com's global e-commerce payment link in the future, making cross-border shopping and supply chain financing more efficient.
Overview of Hong Kong's Stablecoin Ordinance
(I) Scope of supervision
The Stablecoin Ordinance regulates activities involving "specified stablecoins", which are stablecoins that maintain a stable value by reference to one or more official currencies or HKMA-designated units of account or storage of economic value, as stipulated in Article 4 of the Stablecoin Ordinance.
In essence, it can be divided into stablecoins pegged to official currencies and stablecoins pegged to other units of account or stores of economic value designated by the HKMA.
(2) Scope of regulatory activities
The main regulatory design of the Stablecoin Regulations specifies two types of activities for stablecoins:
1. Issue a specified stablecoin
The regulation of the issuance of specified stablecoins under the Stablecoins Ordinance is mainly reflected in the licensing system, with the following specific requirements:
●Subject requirements: an authorized institution with a physical company in Hong Kong or incorporated outside Hong Kong;
●Minimum capital requirement: the licensee must maintain an amount of HK $25 million or an approved equivalent in other currencies to maintain the share capital;
●Reserve asset requirements: The licensee must ensure that the market value of the reserve asset is at least equal to its circulating face value at all times, and the fractional reserve model is prohibited.
●The right of redemption is clearly guaranteed: the licensee must pay the face value of the designated stablecoin to the holder who makes a valid redemption request, and no cumbersome conditions and unreasonable fees shall be attached;
●Risk management requirements: risk control covers market, operational, and legal risks, strengthening anti-money laundering and anti-terrorist financing measures, and establishing a KYC and AML system that meets the requirements of the Hong Kong government;
●Corporate personnel requirements: Key positions such as controlling shareholders and directors of licensees must pass background checks to ensure professional competence and ethical integrity.
2. Offering specified stablecoins
The regulation of the sale of specified stablecoins under the Stablecoins Ordinance is reflected in restricted sales, that is, in general (except for the HKMA exemption), only "authorized providers", that is, regulated intermediaries, have the right to sell specified stablecoins, "approved providers" include:
●Designated stablecoin issuers licensed by the HKMA;
●A virtual asset trading platform regulated by the Securities and Futures Commission of Hong Kong.
●1 licensed corporation regulated by the Securities Supervision Commission of Hong Kong;
●Authorized bodies regulated by the HKMA.
●SVF licensees regulated by the HKMA.
(III) Supervision system
Hong Kong's digital asset regulatory system is characterized by its "Twin Peaks" model, which is divided between the Hong Kong Securities and Futures Commission (SFC) and the HKMA (HKMA). The essence of this model lies in a clear division of responsibilities: the SFC focuses on the "investment" attributes of virtual assets, while the HKMA focuses on its "payment" functions. The specific division of labor and supervision scope are shown in the table below:
(4) Sandbox arrangement
In July 2023, the HKMA consulted on legislative proposals to implement a regulatory regime for stablecoin issuers and announced the launch of a sandbox arrangement. In July 2024, the HKMA announced the first batch of participants to enter the sandbox, including JD.com CoinChain Technology (Hong Kong), Yuanbi Technology, and a consortium consisting of Standard Chartered (Hong Kong), Security Group and HKT.
The first three companies plan to issue stablecoins pegged to the Hong Kong dollar first. The mechanism is intended to allow institutions intending to issue stablecoins in Hong Kong to test their business and risk management plans first, and regulators can also use this pilot opportunity to refine the final regulations.
It should be noted that the HKMA has not yet officially announced the final list of the first batch of licenses, and it is currently false news that a number of institutions, including JD.com, are planning to withdraw from Hong Kong's stablecoin business or other institutions that advertise the specified stablecoin purchase channels in Hong Kong.
(5) The strategic value of the Stablecoin Regulations for Chinese enterprises going overseas
1. Settlement bonus
Stablecoins rely on the characteristics of fast arrival and stable exchange rates to open up a multi-currency direct settlement channel for supply chains and cross-border e-commerce. It is expected to get rid of the time and cost of traditional cross-border transfer as the "hidden cost" of enterprise development, and realize the closed-loop and standardization of high-frequency cross-border transactions.
2. Trust bonus
With the combination of stablecoins and smart contracts, Chinese companies can build a precise peer-to-peer credit system in their trade activities with countries with weaker financial foundations. The performance logic completed on the chain not only saves the manual review process, but also significantly enhances the performance certainty of both parties to the transaction.
3. Compliance bonus
The stablecoin license system is essentially a set of exportable and mutually recognized compliance operating systems. It bridges Chinese enterprises between different regulatory systems around the world, reduces the cost of repeatedly building compliance structures, and makes it possible for Chinese enterprises to expand their compliance in many places.
Risk prevention of fake stablecoins
As of August 2025, with "virtual currency" and "virtual currency" as keywords, there were 659 criminal judgment documents for the crime of illegally absorbing public deposits and the crime of fund-raising fraud retrieved by Wolters Kluwer, an increase of 474% compared with the data in 2023.
It can be seen that as the society's attention to stablecoins gradually increases, some criminals will take the opportunity to issue or hype fraudulent projects using "stablecoins" and "RWA" as gimmicks, which will inevitably increase.
Since July 2025, financial management departments in Beijing, Shenzhen, Suzhou, Chongqing, Ningxia and other places, as well as industry self-regulatory organizations, have issued risk warning announcements, solemnly reminding that institutions that have not been legally approved by the national financial management department do not have the qualifications to publicly absorb public deposits. It is illegal to fabricate so-called "virtual currencies", "virtual assets" and "digital assets" and other investment projects to publicly publicize and absorb public funds.
The state prohibits any form of illegal fund-raising, and no unit or individual may obtain economic benefits from illegal fund-raising. Losses suffered due to participation in illegal fund-raising shall be borne by the participants themselves.
In this regard, the Beijing Internet Finance Industry Association has summarized the illegal fundraising projects of virtual currencies as follows:
1. Lack of qualificationsInstitutions or individuals do not have the legal qualifications to attract deposits, sell wealth management products or issue securities to the public without the approval or filing of the financial management department of the State Council.
2. Concept packaging:Utilizing emerging and complex concepts such as "stablecoins", "decentralized finance (DeFi) " and "Web 3.0" for packaging and speculation, deliberately creating information asymmetry to confuse investors;
3. False promises:There are cases of exaggerated propaganda and false promises, such as "steady profit but not loss", "high fixed income", "principal and interest payment", etc., which take advantage of the public's pursuit of high returns;
4. Fund pool operation:The operation model often relies on absorbing new investors' funds to maintain operation or pay the returns of previous investors. Once the capital chain breaks or the project party runs away, investors will face a huge risk of not being able to recover the principal.
5. Risk spillover:Such activities can easily evolve into illegal fund-raising, financial fraud, pyramid schemes, money laundering, and other illegal and criminal activities, seriously disrupting the economic and financial order, infringing on the safety of people's property, and damaging the foundation of social integrity.
Overall, for individuals or enterprises, before attempting to explore stablecoins, they should first understand the basic operating logic of the blockchain, learn to use formal channels to understand the blockchain and stablecoin consultation, and avoid downloading wallets and other applications from unknown or unofficial channels.
conclusion
With the official implementation of the Stablecoin Ordinance on August 1, the Ordinance provides a more solid institutional foundation and broad development space for Hong Kong to promote the application of stablecoins, expand the variety of tokenized products, and enhance the liquidity and popularity of stablecoins and tokenized financial products. At the national level, this is a battle for monetary sovereignty without gunpowder smoke. The United States extends the US dollar credit to the blockchain world through stablecoins. Hong Kong has the voice over digital finance with a compliance framework and resists the impact of "hidden dollarization".
Looking to the future, Hong Kong, as a natural hub that relies on the deep foundation of traditional international financial centers, the first-mover advantage of the systemic regulatory framework in the digital asset field, and the connection between the mainland and the global digital asset market, is expected to become a key node of global digital assets and the core hub of real-world asset tokenization, building an irreplaceable competitiveness.
References Swipe down to view
Footnote:
Global Stablecoin Industry Development Report 2025
②FXC Intelligence，The State of Stablecoin in Corss Board Payments；
③Artemis Analytics.Stablecoin Payments from the Ground Up.2025;
④ Web3 compliance hotspots | "Hong Kong Stablecoin Draft" officially takes effect! Analysis of Hong Kong's digital asset supervision: development process + sandbox practice!
⑤ Research report on the application of stablecoins in cross-border commodity trade;
(6) Special problems and judicial approaches in the identification of virtual currency transaction-type illegal fund-raising crimes;
"On the risk warning of illegal fund-raising in the name of" stablecoins "."
author
brief introduction
Gao Shengjie
Senior Equity Partner of Zhiheng (Dalian) Law Firm
Gao graduated from the Law School of Jilin University and practiced in Beijing Junzejun (Shenzhen) Law Firm and Beijing Haotian (Shenzhen) Law Firm. He joined Guangdong Zhiheng (Dalian) Law Firm in May 2025 and officially returned to his hometown of Dalian.
Business area:
Capital markets Dispute Resolution, Corporate Equity Investments and Mergers and Acquisitions, Corporate Finance, Debt Collection, Corporate Legal
Representative performance:
Non-litigation areas - Shenzhen biotechnology company restricted equity comprehensive dispute resolution project, Shenzhen new materials company investment against gambling special project legal counsel project, Shenzhen electrical manufacturing company management buyout project, Hunan real estate company workout, Gansu a photovoltaic joint stock company pre-restructuring project.
Responsible for Guangwei Technology Company, Tianhai World Satellite Communication Company, Lingyu Technology Company, Hailei New Energy Company and other companies for perennial or special project legal counsel work; litigation areas - a new material joint stock company in Shenzhen and the actual controller and investors Equity disputes and other difficult cases, as a lawyer acting on contract disputes between Shenzhen Huiji group company and a number of construction companies (about 50 cases), Shenzhen Hong Construction Company and a listed company Material litigation series (including subrogation disputes nearly 30 cases), Shenzhen A trading company Shareholder qualification confirmation case, a commercial bank Financial loan contract dispute series Cases and dozens of labor dispute cases involving regular law consulting units.
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