Author: Cobo
Stablecoins are accelerating their establishment as a foundational infrastructure in the digital financial system. As the scale of circulation rises, major jurisdictions are also speeding up regulatory arrangements, attempting to seize dominance in the reshaping of institutions. Although the US, Europe, and Hong Kong all emphasize "compliance first," they have gradually diverged into three distinct regulatory paradigms in terms of institutional design, market positioning, and technological integration. This divergence not only pertains to local financial governance logic but will also profoundly impact the evolution of the global stablecoin market and its institutional boundaries.
Core Comparative Analysis: Institutional Differences and Strategic Intent of Regulatory Paths in Three Major Jurisdictions
Major global jurisdictions are forming three typical strategies: the European Union is attempting to promote market unification and institutional integration through the MiCA framework; the United States focuses on financial dominance by legislating stablecoins into the federal financial infrastructure; and Hong Kong is advancing limited openness and tokenization experiments under prudent regulation. Below is a comparison of the core differences among the three in regulatory concepts, institutional frameworks, and market objectives.
European Union: Building a Unified Internal Market for Cryptocurrencies
The European Union, through the Markets in Crypto-Assets Regulation (MiCA), aims to create a unified regulatory framework across the entire European Economic Area, integrating the crypto asset market into the existing financial order. The MiCA framework is clear and extensive, covering all types of crypto assets (such as Electronic Money Tokens (ETMs) and Asset-Referenced Tokens (ARTs)) as well as various Crypto Asset Service Providers (CASPs).
The EU licensing and access thresholds adopt a "passporting system," allowing a company that obtains a MiCA license in any EU member state to provide services across all 30 countries in the European Economic Area (EEA), greatly facilitating market unification.
This top-level design has rapidly advanced the market compliance process. As of now, preliminary statistics from industry experts indicate that over 50 institutions have obtained relevant licenses, establishing a regulated stablecoin ecosystem. However, the strict limitations on reserves imposed by MiCA (such as prohibiting interest payments and restricting investment scope) have also compressed profit models, raising concerns about sustainability among some institutions. Nevertheless, the unified market entry and institutional certainty continue to attract cross-border participants like Coinbase and BBVA to accelerate their layouts.
United States: Evolving from Fragmented Regulation to Federal Integration
The stablecoin regulatory strategy in the United States is more geopolitically strategic. Proposals like the GENIUS Act aim to incorporate stablecoins into the national clearing and payment systems, granting them the role of "extending the dollar network." Current regulation is led in parallel by federal and state governments, with most stablecoin issuances still operating under state-level licenses. However, as the scale of stablecoins grows, federal regulation is strengthening direct intervention with systemic issuers.
The proposed institutional framework emphasizes the safety of reserves (such as 100% coverage by government bonds) and encourages large stablecoin issuers to apply for bank qualifications and master accounts to access the Federal Reserve's clearing network. The bank license applications by Circle and Ripple are examples of such explorations. Although this model does not allow stablecoins to pay interest, it aims to create new profit paths based on credit, custody, and financial intermediation through integration with banking operations.
Hong Kong: Promoting Limited Openness and Tokenization Experiments Under High Barriers
Hong Kong adopts a prudent and pragmatic strategy for stablecoin regulation, emphasizing cautious advancement. In the upcoming Stablecoin Regulation, which will take effect in August, the Monetary Authority expects to issue only a single-digit number of licenses in the first batch, highlighting a "first establish, then break" institutional orientation. Hong Kong requires 100% high-quality reserves and prohibits using reserves for risky asset management, reinforcing the functional positioning of stablecoins as payment and clearing tools.
This highly secure institutional design compresses traditional profit margins, but Hong Kong is promoting application experiments of stablecoins on real-world assets (RWA) through regulatory sandbox projects (such as Project Ensemble), including bonds, carbon credits, and supply chain finance. At the same time, Hong Kong's role in the Renminbi stablecoin (CNHC) is becoming increasingly clear, as it seeks to explore new paths for the internationalization of the Renminbi through a dual-track mechanism of "offshore onshore + on-chain issuance."
Cross-Domain Impact: Shaping a New Order in Digital Finance
As global stablecoin regulation becomes clearer, the institutional boundaries and market roles of this asset class will be redefined. From a macro perspective, the divergence of compliance paths not only reflects differences in financial governance philosophies among countries but is also reshaping the competitive landscape, profit logic, and technological routes of stablecoins.
Firstly, the clarification of regulation is transforming "compliance identity" itself into one of the most important market assets. Licenses not only signify access permission but also determine whether institutions can connect to key clearing networks, obtain banking partnerships, attract institutional clients, and secure venture capital. A noticeable trend of market concentration has emerged: leading institutions with banking qualifications, compliance capabilities, and settlement abilities are gaining an advantageous position, such as Circle and Ripple, which are actively applying for federal-level financial licenses to master the entire chain of stablecoin issuance, custody, and circulation. Regulatory dividends thus become a market threshold, accelerating the exit of those without qualifications.
At the same time, increasingly stringent compliance requirements are forcing stablecoin projects to adjust their profit models. The traditional revenue structure relying on interest rate spreads and reserve interest is constrained by reserve composition limitations and interest payment prohibitions. Under this pressure, the value logic of stablecoins is beginning to evolve towards "servicization": their function is no longer a simple currency substitute but is embedded in more complex financial processes such as cross-border payments, asset custody, and on-chain clearing. Profit margins will increasingly come from peripheral services, on-chain asset combinations (such as RWA), and operational efficiency improvements. This transformation also reflects early signs of stablecoins evolving from "single products" to "platform capabilities."
The clarity of regulation is also driving the underlying technological architecture towards standardization. For example, infrastructure service providers like Cobo are modularizing capabilities such as on-chain custody, clearing, risk control, fund inflow and outflow, KYC, and cross-chain interoperability, providing institutions with "plug-and-play" issuance and circulation components. These services not only lower the compliance entry barriers for stablecoin projects but also enable non-crypto-native enterprises (such as Web2 transformation companies) to quickly embed relevant capabilities. Here, technological abstraction and compliance requirements achieve dynamic coordination: regulation defines boundaries, while technology suppliers are responsible for translating them into executable interfaces, thereby enhancing the overall flexibility and stability of the system.
On a broader scale, stablecoins are becoming a new battleground for global currency competition. The United States is promoting the integration of dollar stablecoins into the federal clearing system through the GENIUS Act, strengthening its global settlement advantage; the European Union is leveraging MiCA to create unified regulation, enhancing the strategic weight of the euro in the digital economy; and China is promoting the on-chainization and cross-border application of Renminbi assets through the dual-track structure of "onshore offshore" and "offshore offshore" for Renminbi stablecoins. These differentiated paths are guiding the stablecoin market to accelerate stratification along geographical and institutional dimensions, which may have lasting impacts on the monetary sovereignty of small countries, cross-border capital flows, and financial stability.
However, regulatory clarity does not automatically imply widespread adoption. Whether stablecoins have the potential for large-scale implementation still depends on whether they can achieve "usability" beyond being "trustworthy." Technical complexity, compliance burdens, and regional differences in preferences for settlement efficiency and consumer protection constitute real barriers to actual deployment. Ultimately, how to simplify user experience and lower usage thresholds without sacrificing regulatory bottom lines will determine whether stablecoins can gain mainstream status in daily payments and value storage. This is the final link that regulation and technology need to solve together.
免责声明：本文章仅代表作者个人观点，不代表本平台的立场和观点。本文章仅供信息分享，不构成对任何人的任何投资建议。用户与作者之间的任何争议，与本平台无关。如网页中刊载的文章或图片涉及侵权，请提供相关的权利证明和身份证明发送邮件到support@aicoin.com，本平台相关工作人员将会进行核查。
