Comparison of Regulatory Frameworks for Stablecoins in Hong Kong and the United States: Balancing Innovation and Risk

Stablecoins, as an important infrastructure in the Crypto Assets market, have received significant attention from global regulatory bodies in recent years. On one hand, stablecoins have tremendous innovative potential, capable of deeply integrating on-chain and off-chain value systems, and even playing a key role in the adjustment of the global financial landscape. On the other hand, stablecoins also face inherent risks and external risks, necessitating the establishment of a systematic regulatory framework to balance innovation and risk.

At present, regions such as Hong Kong and the United States have launched relatively complete regulatory frameworks for stablecoins. Hong Kong issued the "Stablecoin Regulation Draft" in December 2024, which clarifies the definition of "designated stablecoins," the scope of regulated activities, the entry thresholds for issuers, and the management requirements for reserve assets. It also established a "stablecoin sandbox" mechanism to provide compliance support for issuers. The United States has constructed a parallel regulatory system at both federal and state levels through the "GENIUS Act" and the "STABLE Act," which stipulate definitions of stablecoins, qualifications for issuers, and management of reserve assets.

Although there are differences in the regulatory frameworks of the two regions, they both focus on issuer access, stablecoin value stabilization mechanisms, and the compliance of circulation links. This reflects the regulators' desire to encourage innovation while reducing systemic risks through institutional design, promoting the standardized development of the stablecoin industry.

With the continuous optimization of the regulatory framework, the stablecoin industry will enter a new stage that emphasizes both regulation and innovation. This not only raises higher compliance requirements for issuers but also provides institutional space for exploring new business models. In the future, the development of stablecoins will seek new growth momentum and value creation points within the global financial system through technological iteration and institutional adaptation.