Global stablecoin regulation ushers in a historic "trio": the GENIUS Act, Hong Kong licenses, and MiCA

Written by: RWA Research Institute

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

On March 5, the Hong Kong Monetary Authority announced that the first batch of fiat-backed stablecoin licenses are 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.

Meanwhile, across the ocean, regulators in mainland China also sent clear signals. On February 6, 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 agency launched a new expansion round, with 12 commercial banks selected—raising the total number of operational institutions from 10 to 22—marking the official entry of digital RMB into its second-generation institutionalized operation era.

These seemingly independent events reveal a common trend: stablecoins are rapidly moving from the “gray area” of the crypto world into the spotlight of mainstream finance. According to data from RWA.xyz, as of March 2026, the on-chain value of tokenized real-world assets, excluding stablecoins, has exceeded $25 billion. Stablecoins themselves are becoming the core “blood system” of this value migration—USDC’s monthly trading volume 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 schemes in the US, Hong Kong, and the EU competing for? What do their differences mean for enterprises? Against the backdrop of the official launch of Digital RMB 2.0, how should Chinese companies choose their path in this regulatory race?

This is a制度竞赛— a competition that will determine the future landscape of global digital financial infrastructure over the next decade.

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

In February 2026, the OCC released a lengthy proposal aimed at implementing provisions related to stablecoin issuance under the GENIUS Act. This marks the first clear federal-level regulation for the private issuance of “digital dollars”—stablecoins.

The GENIUS Act, signed into law on July 18, 2025, established a three-tiered issuance structure: (1) subsidiaries of depository institutions approved by federal regulators; (2) federally qualified payment stablecoin issuers directly approved by the OCC; and (3) state-qualified issuers approved by state regulators. The core idea is “diversified access”—not to completely detach stablecoin issuance from traditional banking, nor to concentrate it in a few entities.

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 the term “direct support” is somewhat vague, providing examples such as holding non-stablecoin crypto assets to test distributed ledger technology or payment networks, which could be considered permissible “direct support.” This pragmatic, case-by-case clarification approach reflects regulators’ attitude toward technological innovation—setting boundaries while leaving room for exploration.

Of particular interest is the implementation of the interest prohibition. The GENIUS Act itself bans stablecoin issuers from paying interest or yields to holders but does not explicitly prohibit related parties or third parties from earning indirect profits funded by the issuer—this has recently sparked intense debate in industry and Congress. The OCC’s proposal responds by establishing a rebuttable presumption that such arrangements violate the interest ban. It also clarifies that merchants offering discounts for stablecoin payments or profit-sharing in white-label collaborations, as long as they do not transfer interest or yields to holders, are not covered by this presumption. An anti-evasion clause is added to treat any arrangements aimed at circumventing the interest ban as violations.

Regarding reserves, the proposal requires issuers to maintain at least 1:1 backing with high-quality assets. Acceptable reserves include USD cash, deposits at 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 as 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 design 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 be extended to seven calendar days. This “automatic extension” acts as a preventive measure against bank run risks—giving issuers time to liquidate reserves and avoid systemic collapse.

On capital requirements, newly approved issuers must meet initial capital thresholds, including a minimum of $5 million during early regulation. 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 compliance with AML laws. Failure to submit such certification could result in license revocation. This governance-focused approach aims to reinforce the importance of AML at the highest organizational levels.

Overall, the US model’s core logic is “maintaining dollar dominance in the digital age.” It seeks to attract more issuers by lowering compliance barriers, prevent stablecoins from becoming deposit substitutes through the interest ban, and include foreign issuers under US regulation via the “foreign issuer” clause. The goal is not to stifle innovation but to bring it into a controllable, supervised framework, thereby reinforcing the dollar’s leading role in global digital payments.

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

Hong Kong’s stablecoin regulation is equally rigorous. In August 2025, the “Stablecoin Ordinance” came into effect, establishing the world’s strictest 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 they received 36 license applications, but the initial licenses would be limited—prioritizing stability over quantity.

Hong Kong’s approach is characterized by high thresholds: a minimum paid-up capital of HKD 25 million (five times US standards); 100% high-liquidity reserve assets held in Hong Kong; 24/7 AML monitoring; and licensees must be registered entities with identifiable management and offices. These requirements create a high entry barrier—excluding small and medium-sized crypto firms and ensuring only reputable, resource-rich traditional financial institutions participate.

This explains why the first licenses went to giants like HSBC, Standard Chartered, and Bank of China Hong Kong. Standard Chartered, for example, launched integrated digital asset services for institutional clients in July 2025, with its UK branch offering spot trading of Bitcoin and Ethereum. Through subsidiaries like Zodia Custody, Zodia Markets, and Libeara, it provides custody, trading, and tokenization services, building a full chain from issuance to custody.

Hong Kong’s regulatory philosophy is to “bring stablecoin issuance into the traditional financial regulatory framework.” 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, with assets held in segregated custody and 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 confirmed on February 26, 2026, when the People’s Bank of China and HKMA jointly launched a cross-border RWA settlement pilot, successfully enabling real-time exchange and settlement between digital RMB and licensed Hong Kong stablecoins.

The pilot 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 test, the process was reduced to three minutes, with a cost reduction of over 20%. 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 a “value anchor and compliance channel” ensuring legal and traceable fund flows; Hong Kong’s compliant stablecoins as “liquidity bridges,” facilitating global digital finance with 24/7 trading. Wang Wenzhong, Vice President of the Chinese Academy of Social Sciences, described this as a “public-private partnership”—combining the security and compliance of sovereignty with market-driven efficiency and flexibility.

For mainland enterprises, this collaboration offers a clear, compliant pathway for RWA going abroad. 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: “Comprehensive Prudence” Under System-First Approach

Across the Atlantic, the EU has chosen a different path. In June 2025, the European Banking Authority (EBA) 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: starting March 2, 2026, crypto asset service providers offering electronic money token custody and transfer services may need both MiCA crypto licenses and PSD2 payment licenses.

This means the same activity could face two regulatory frameworks, two capital requirements, and double compliance costs. MiCA requires a minimum capital of €125,000, and PSD2 also requires €125,000—totaling nearly €290,000. Combined reporting and regulatory fees could nearly double compliance costs.

Patrick Hansen, Policy Lead at Circle in the EU, warned on social media that unresolved conflicts between MiCA and PSD2 could severely impair the EU’s digital finance competitiveness. He argued that this double-licensing trap violates principles of proportionality, legal clarity, and consistency—contradicting the EU’s goal of simplifying regulation and boosting competitiveness.

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 EBA 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 EBA has proposed two legislative amendments: (1) revise MiCA to incorporate relevant PSD2 payment provisions, creating a single framework; or (2) amend upcoming PSD3 and Payment Services Regulation 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”—establishing a comprehensive rule system before the industry fully matures. The advantage is regulatory certainty: once compliant, firms can operate across all 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 licenses and multiple US state money transfer licenses. By 2025, BVNK processed over $20 billion in transactions, serving more than 130 countries. On March 17, Mastercard announced acquiring BVNK for $1.8 billion—its largest digital asset acquisition.

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 across major blockchains, with fiat on/off ramps in USD, EUR, GBP, serving cross-border B2B payments, payroll, and stablecoin issuance. This “compliance-first, tech-driven” model aligns with the EU’s regulatory framework—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 Bridge in 2024 and Visa’s strategic investment in BVNK.

4. Divergence in Convergence: Five Core Principles Gaining Consensus

Comparing these three regulatory frameworks reveals stark 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 high capital and local reserves. 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: All frameworks require stablecoin issuers to hold reserves equal to circulating supply, ensuring redeemability.
2. Reserve Segregation: Reserves must be kept separate from issuer assets to prevent misuse.
3. No Interest Payments: Stablecoins are designated as “payment tools,” prohibiting issuers from paying interest or yields to holders.
4. AML Compliance: Strict KYC, transaction monitoring, and reporting obligations are enforced.
5. Consumer Protection: Reserve requirements, disclosures, and redemption rights safeguard holder interests.

This “principle convergence with detailed divergence” reflects each jurisdiction’s contest for “rule-setting authority”—who can craft rules that balance financial stability with innovation, gaining a competitive edge in the next decade of digital finance.

For Chinese enterprises, understanding this divergence and convergence is a strategic skill.

By March 2026, as the three major economies’ stablecoin regulatory frameworks nearly simultaneously come into force, we witness a historic moment: the “Spring and Autumn” era of digital finance is ending, giving way to a “new order” led by rulemaking.

The US chooses “efficiency first”—driving innovation through market forces and maintaining dollar dominance. Hong Kong opts for “regulatory extension”—using traditional financial prudence to endorse digital assets and serve 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 resource endowments and goals. For Chinese companies, understanding these differences is itself a strategic capability—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 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, Economic Weekly. All data as of March 2026.)