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

Recently, the United States and Hong Kong have successively introduced legislation related to stablecoins, marking the entry of the global digital asset market into a new growth cycle driven by regulation. These regulations not only fill the regulatory gap for stablecoins anchored to fiat currency assets but also provide a clear compliance framework for the market, including reserve asset segregation, redemption guarantees, and anti-money laundering compliance requirements, effectively reducing systemic risk. This article will analyze the core content of these two pieces of legislation and, combined with quantitative analysis, systematically forecast the growth trajectory of compliant USD stablecoins over the next decade and their impact on the reconstruction of the public chain ecosystem.

1. The US GENIUS Act: Growth Drivers and Quantitative Forecast of the US Dollar Stablecoin

The "GENIUS Act" passed by the U.S. Senate in May 2025, (Guiding and Establishing National Innovation for U.S. Stablecoins Act), is an important milestone in the regulation of stablecoins in the United States. The act establishes a detailed regulatory framework for stablecoin issuers, requiring issuers to hold at least 1:1 high-liquidity dollar assets as reserves, undergo regular audits, and comply with anti-money laundering and customer identification requirements. The act also prohibits stablecoins from offering interest, restricts foreign issuers from entering the U.S. market, and clarifies that stablecoins are neither securities nor commodities, providing a clear legal positioning for digital assets.

The implementation of the GENIUS Act is expected to have a profound impact on the global crypto market. First, investing in high-liquidity US dollar assets will directly benefit US Treasury issuance, making stablecoins an important channel for US Treasury distribution, alleviating the financing pressure of the US fiscal deficit, while strengthening the international settlement position of the dollar through digital currency channels. Second, a clear regulatory framework may attract more financial institutions and technology companies into the stablecoin field, promoting innovation and efficiency improvement in payment systems. However, the Act has also sparked some controversies, such as potential conflicts of interest arising from certain political figures' families getting involved in the cryptocurrency industry, and the 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 US in the global digital asset regulatory competition.

According to a forecast by a large financial institution, in a scenario of regulatory clarity, the global stablecoin market capitalization is expected to grow from $230 billion in 2025 to $1.6 trillion by 2030. This prediction is based on two key assumptions: firstly, compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving approximately $40 billion in international remittance costs each year; secondly, the amount of stablecoins locked in decentralized finance (DeFi) protocols will exceed $500 billion, becoming the foundational liquidity layer for decentralized finance.

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

The recent release of the "Stablecoin Regulation" by the Hong Kong SAR government marks an important progress in its systematic layout in the Web 3.0 field. The regulation establishes a licensing system for the issuance of stablecoins, requiring issuers to obtain permission from the Hong Kong Monetary Authority (HKMA) and meet strict requirements in areas such as reserve asset management, redemption mechanisms, and risk control. In addition, Hong Kong also plans to introduce a dual licensing system for over-the-counter (OTC) and custodial services within the next two years, further improving the full-chain regulatory system for virtual assets.

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 including bonds, real estate, and commodities. Through 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 space for the development of Web 3.0.

Although the Hong Kong "Stablecoin Bill" draws on the regulatory logic of the United States, it presents significant differences in implementation details. For example, regarding the scope of regulation, the U.S. legislation mainly targets payment-type stablecoins, while the Hong Kong regulations cover a broader range of stablecoin types. In terms of reserve asset requirements, the U.S. stipulates that they must be in U.S. dollar cash or short-term government bonds, whereas Hong Kong allows for a more diversified asset mix. Furthermore, concerning the issuing entities, the U.S. restricts foreign issuers, while Hong Kong maintains a more open attitude towards international issuers.

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

The strengthening effect of a global reserve currency for ( dollar stablecoin

Under the GENIUS Act framework, payment stablecoins must be backed by U.S. Treasury securities, which 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 funding circulation system globally: when global users purchase dollar-denominated stablecoins, the issuing institution must allocate the corresponding funds to U.S. Treasury assets, which not only facilitates the flow of funds back to the U.S. Treasury but also strengthens the global usage of the U.S. dollar in an intangible way.

From the perspective of international settlement, the emergence of stablecoins signifies a paradigm shift in the US dollar clearing system. Blockchain-based stablecoins are embedded in various compatible distributed payment systems in the form of "on-chain dollars." This technological breakthrough has made the settlement capability of the US dollar no longer limited to traditional financial institutions, expanding the international use cases of the dollar and representing a modernization upgrade of the dollar's settlement sovereignty in the digital age, further consolidating its core position in the global monetary system.

) ### two ( The regulatory coordination challenges in Asia between Hong Kong and Singapore

Although Hong Kong and Singapore have similar goals in stablecoin regulatory policies, their implementation paths show significant differences. Hong Kong adopts a prudently tightening regulatory approach, with the Monetary Authority planning to establish a licensing system for fiat-backed stablecoins, positioning stablecoins as "alternatives to virtual banks" and strictly adhering to traditional financial regulatory frameworks. In contrast, Singapore maintains an experimental regulatory mindset, allowing innovative pilots that link digital tokens to fiat currencies, preserving flexibility for technological and business model innovations, and overall adopting a regulatory attitude that allows for trial and error.

This regulatory disparity may lead issuing institutions to selectively register to evade strict scrutiny or exploit differences in regulatory standards for arbitrage operations, thereby undermining the effectiveness of the fiat currency peg mechanism's review. In the long term, if coordination is lacking, this divergence could compromise regulatory fairness and policy consistency, and even trigger regional regulatory competition risks, causing both areas 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 financial governance.

Conclusion: Regulatory Clarity Opens a Golden Decade for Stablecoins

The joint implementation of the U.S. GENIUS Act and the Hong Kong ordinance draft marks the transition of digital asset regulation from fragmentation to systematization. Compliant USD stablecoins are expected to achieve exponential growth 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 dividend within the regulatory framework. For issuers, building a stablecoin system that is multi-chain, multi-coin, and multi-regulatory compliant will be the key strategy to win the competition of the next decade.

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