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

On March 5th, the Hong Kong Monetary Authority announced that the first batch of fiat-denominated stablecoin licenses was nearing issuance, with traditional financial institutions such as HSBC and Standard Chartered reportedly leading the race. Three days later, the U.S. Office of the Comptroller of the Currency (OCC) released its GENIUS Act implementation proposal, establishing a comprehensive federal licensing and prudential regulatory framework for payment stablecoin issuers. Almost simultaneously, British fintech company BVNK obtained a crypto asset service provider license from the Malta Financial Services Authority, becoming one of the few institutions to simultaneously possess MiCA compliance status and access to European payment networks.

Meanwhile, across the Pacific, Chinese regulators also sent a clear signal. On February 6, eight departments, including the People's Bank of China, jointly issued Document No. 42, which for the first time incorporated the tokenization of Real-World Assets (RWA) into the regulatory framework, clarifying a dual-track approach of "strict prohibition domestically and registration overseas." In late March, a new round of expansion of digital RMB operating institutions was launched, with 12 commercial banks joining, bringing the total number of operating institutions from 10 to 22, marking the official entry of the digital RMB into the 2.0 era of institutionalized operation.

These three seemingly independent events share a common trend: stablecoins are rapidly moving from the "gray area" of the crypto world into the spotlight of the mainstream financial system. According to data from RWA.xyz, as of March 2026, the on-chain value of tokenized real-world assets, excluding stablecoins, had exceeded $25 billion, and stablecoins themselves are becoming the core "bloodstream" 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 instantly cross national borders, regulation remains firmly rooted in national territory. What exactly are the three regulatory frameworks implemented almost simultaneously in the US, Hong Kong, and the EU vying for? What do their differences mean for businesses? With the official launch of the Digital Yuan 2.0 era, how should Chinese companies choose their course in this regulatory race?

This is an institutional race that will determine the competitive landscape of global digital financial infrastructure over the next decade.

I. The United States: The "Federal Licensing" Model Prioritizing Market Efficiency

On February 25, 2026, the U.S. Office of the Comptroller of the Currency (OCC) released a proposal hundreds of pages long aimed at implementing the provisions of the GENIUS Act regarding the issuance of stablecoins for payments. The release of this proposal signifies that the United States has finally established clear federal-level rules for stablecoins, a privately issued version of the "digital dollar."

The GENIUS Act itself, signed into law on July 18, 2025, establishes a three-tiered issuance structure for payment stablecoins: first, subsidiaries of depository institutions, approved by their primary federal regulatory agencies; second, federally qualified payment stablecoin issuers, directly approved by the OCC; and third, state-qualified payment stablecoin issuers, approved by state regulatory agencies. The underlying logic of this design is "diversified access"—it neither wants stablecoin issuance to completely detach from the traditional banking system, nor does it want to limit it to a few institutions.

The OCC's proposal further refines these rules. Regarding permitted activities, payment stablecoin issuers are limited to issuing and redeeming stablecoins, managing reserve assets, providing related custody services, and other activities that "directly support" these core businesses. The OCC's proposal acknowledges the ambiguity of the term "directly support" and provides examples, such as holding non-stablecoin crypto assets for testing distributed ledger technology or paying network transaction fees, which could be considered permitted "direct support" activities. This cautious, case-by-case approach reflects the regulator's pragmatic attitude towards technological innovation—setting boundaries while allowing room for exploration.

The most noteworthy aspect is the implementation of the interest rate ban. While the GENIUS Act itself prohibits stablecoin issuers from paying interest or returns to holders, it does not explicitly prohibit affiliates or "related third parties" of the issuer from providing returns indirectly funded by the issuer—a detail that has recently sparked heated debate in industry and Congress. The OCC's proposal addresses this by establishing a rebuttable presumption that such arrangements violate the interest rate ban. The proposal also clarifies that merchants independently offering stablecoin payment discounts, and profit sharing in white-label partnerships, are not covered by this presumption, as long as they do not involve passing on interest or returns to holders. Furthermore, the proposal adds anti-circumvention clauses, treating any arrangement designed to circumvent the interest rate ban as a violation.

Regarding reserve assets, the proposal requires issuers to maintain at least a 1:1 ratio of high-quality reserve assets. Acceptable reserve assets include US dollar cash, demand deposits at depository institutions, short-term Treasury bills with maturities of 93 days or less, certain reverse repurchase agreements, and registered government money market funds. Notably, the proposal explicitly excludes stablecoins themselves and other crypto assets as eligible reserve assets. Reserve assets are measured at fair value, while circulating stablecoins are measured at par value—meaning that even if stablecoins decouple in the secondary market, issuers must still maintain reserves equal to the par value of all circulating stablecoins.

The redemption mechanism is designed to anticipate extreme scenarios. Generally, the redemption period does not exceed two business days, but if the issuer receives redemption requests exceeding 10% of the total circulating supply within 24 hours, the redemption period can be extended to seven calendar days. This "automatic extension" mechanism is essentially a preventative measure against the risk of bank runs—giving the issuer time to liquidate reserve assets and preventing systemic collapse due to short-term liquidity shortages.

Regarding capital requirements, newly approved issuers must comply with the initial capital framework, including a minimum capital of at least $5 million in the initial regulatory phase. This requirement means that stablecoin issuance in the United States is considered a regulated financial activity requiring substantial financial strength, rather than a lightweight, technology-driven product.

Anti-money laundering compliance is directly linked to license status. Issuers must provide board-level certification confirming that they maintain an anti-money laundering compliance framework that complies with applicable laws. Failure to submit a qualified certification may result in the revocation of the issuer's eligibility. This design, which traces compliance responsibility back to the board of directors, aims to strengthen the importance placed on compliance by the governance level.

In summary, the underlying logic of the US model is to "maintain the dollar's hegemony in the digital age." This is achieved by lowering compliance thresholds to attract more issuers, preventing stablecoins from becoming deposit substitutes by prohibiting interest rates, and bringing global dollar stablecoins under US regulatory oversight through foreign issuer provisions. The core objective of this set of rules is not to stifle innovation, but to bring innovation into a controllable and supervised framework, while simultaneously consolidating the dollar's dominant position in the global digital payments system.

II. Hong Kong, China: A "Compliance Extension" Model Connecting Chinese Assets

In Hong Kong, the pace of stablecoin regulation is equally rapid. In August 2025, the Stablecoin Ordinance officially came into effect, establishing the world's most stringent stablecoin regulatory framework. In February 2026, Chief Executive John Lee revealed at the Consensus Hong Kong conference that the first batch of stablecoin issuer licenses would be officially issued in March. Hong Kong Monetary Authority Chief Executive Eddie Yue disclosed details of the approval process: a total of 36 license applications were received, but the number of licenses issued in the first round will "definitely not be many," with the primary goal being to ensure system stability rather than pursuing quantity.

The stringent nature of the Hong Kong model is reflected in multiple dimensions. The minimum paid-up capital is HK$25 million, five times that of the US; a 100% high-liquidity asset reserve requirement, with these reserves held in Hong Kong; 24/7 anti-money laundering monitoring; and the issuing entity must be a Hong Kong-registered entity with identifiable management and a physical office. These requirements combined create an extremely high barrier to entry—excluding small and medium-sized crypto companies and ensuring that only reputable, well-resourced traditional financial institutions can participate.

This explains why the first batch of license holders were traditional banking giants like HSBC, Standard Chartered, and Bank of China (Hong Kong). Standard Chartered launched an integrated digital asset trading service for institutional clients as early as July 2025, and its UK branch has already launched spot trading in Bitcoin and Ethereum. Through its subsidiaries Zodia Custody, Zodia Markets, and Libera, Standard Chartered provides digital asset custody, trading, and tokenization services respectively, building a full-chain capability from issuance to custody.

The core design concept of Hong Kong's regulatory framework is to "integrate stablecoin issuance into the traditional financial regulatory framework." This means that stablecoins are considered an extension of " electronic money ," rather than a completely new asset class. Issuers must comply with the same stringent anti-money laundering and counter-terrorism financing requirements as traditional financial institutions; reserve assets must be segregated and regularly disclosed; and licensed institutions are subject to continuous supervision by the Hong Kong Monetary Authority.

The stance on foreign stablecoins is also clear. Eddie Yue emphasized that even stablecoins that comply with foreign regulations must obtain a Hong Kong license to conduct retail business in Hong Kong. Foreign stablecoins without a Hong Kong license are prohibited from being promoted to retail investors. This "local licensing" principle aims to firmly anchor the stablecoin ecosystem within Hong Kong's local regulatory system and prevent the transmission of risks from overseas.

The underlying strategic intent of the Hong Kong model is to become a "strategic hub" connecting mainland Chinese assets with the global digital capital market. This was strongly demonstrated on February 26, 2026. On that day, the Digital Currency Research Institute of the People's Bank of China and the Hong Kong Monetary Authority jointly launched a special test for cross-border RWA settlement of the digital RMB, successfully achieving real-time exchange and clearing between the digital RMB and Hong Kong-licensed stablecoins.

The tests focused on two major real-world scenarios: cross-border infrastructure and agricultural trade. In the traditional model, a cross-border payment requires multiple intermediary banks, taking approximately two hours and incurring high exchange costs. In the tests, this process was reduced to three minutes, lowering exchange costs by over 20%. The underlying technological breakthrough is "atomic swap"—locking the digital yuan and minting an equivalent stablecoin are completed simultaneously, completely eliminating counterparty credit risk.

This dual-track collaborative model of " digital yuan + Hong Kong stablecoin" forms a clear division of functions: the digital yuan serves as a "value anchor and compliance channel," ensuring the legal credit support and traceability of fund inflows and outflows; the Hong Kong compliant stablecoin, on the other hand, acts as a "liquidity bridge," connecting the global digital financial market with its 24/7 uninterrupted trading capabilities. Fan Wenzhong, vice president of the Beijing Academy of Social Sciences, defines it as a new "public-private partnership" architecture—combining the security and compliance of sovereign currency with the efficiency and flexibility of market-driven mechanisms.

For mainland enterprises, this collaborative model signifies the formation of a clear and compliant path for RWA (Rich Coin Assets) to expand overseas. Whether it's the revenue rights of cross-border infrastructure projects, supply chain finance assets in agricultural trade, or green carbon sinks and commercial real estate revenue rights, all can utilize the digital yuan as a compliant entry point and achieve tokenization, global circulation, and circulation through Hong Kong's stablecoin ecosystem.

III. The European Union: A "Comprehensive Prudential" Model Based on Institutional Priority

Across the Atlantic, the EU chose a different path. In June 2025, the European Banking Authority issued a "no-action letter" clarifying the interaction between MiCA (Crypto Asset Markets Regulation) and PSD2 (Payment Services Directive II). This seemingly technical document reveals a significant regulatory challenge: from March 2, 2026, cryptocurrency service providers offering electronic currency token custody and transfer services may need to hold both a MiCA cryptocurrency license and a PSD2 payment services license.

This means that the same business activity will face two sets of regulatory frameworks, two sets of capital requirements, and two sets of compliance costs. MiCA requires crypto asset service providers to have a minimum capital of €125,000, and a PSD2 payment service license also requires €125,000—together, the total is €250,000, nearly $290,000. Adding in double reporting and double regulatory fees, compliance costs almost double.

Patrick Hansen, Circle's EU policy chief, warned on social media that failure to resolve the conflict between MiCA and PSD2 would severely damage the EU's competitiveness in digital finance. He pointed out that this dual-licensing trap violates the EU's principles of proportionality, legal clarity, and consistency, and runs counter to the EU's efforts to simplify regulations and enhance competitiveness.

The root of this conflict lies in MiCA's design logic: it attempts to establish a unified rulebook for crypto assets, but in the custody and transfer of electronic currency tokens, it overlaps with existing payment service directives. The European Banking Authority acknowledges that all financial activities should be governed by one law, but currently MiCA and PSD2 simultaneously govern stablecoin custody and transfer services.

The European Banking Authority (EBSA) has proposed two legislative amendments: one is to revise the MiCA to incorporate the relevant payment services terms in PSD2, establishing a single framework for e-money token activities; the other is to amend the upcoming PSD3 and payment services regulations, exempting MiCA-licensed institutions from the separate payment services licensing requirements for e-money token custody and transfers. The PSD3 legislative process is still underway and is expected to be passed after 2025—this provides policymakers with a limited window to add specific exemptions before the March 2026 deadline.

The essence of the EU model is "institutional first"—establishing a rule system covering the entire industry chain before the industry is fully mature. The advantage of this approach is the strong certainty of regulation; once compliant, it can be applied in all 27 countries. The disadvantage is the high cost of compliance and the long adjustment period, which may stifle innovation in the early stages.

But the EU's goals extend beyond regulation. The BVNK case might illustrate this point. Founded in 2021, this stablecoin payment infrastructure company, headquartered in London, holds electronic money institution licenses in the UK and the EU, as well as money transmission licenses in several US states. By 2025, BVNK's transaction processing volume exceeded $20 billion, with operations covering more than 130 countries and regions. On March 17, Mastercard announced its acquisition of BVNK for $1.8 billion, Mastercard's largest acquisition in the digital asset space.

BVNK's appeal lies in its full-stack enterprise-grade solution—API interfaces, wallet management, compliance and risk control, and liquidity management—lowering the barrier to entry for enterprises to access stablecoins. It supports the sending, receiving, exchanging, and storing stablecoins on all major blockchains, with fiat currency deposits and withdrawals supporting USD, EUR, and GBP. Its main service scenarios include cross-border B2B settlements, cross-border payroll payments, and enterprise stablecoin issuance. This "compliance-first, technology-driven" model is precisely what the EU regulatory framework aims to foster—encouraging sustainable innovation within clearly defined boundaries. Mastercard's acquisition also confirms the strategic bet of traditional financial giants on stablecoin infrastructure—Strip acquired stablecoin company Bridge for $1.1 billion in 2024, and Visa strategically invested in BVNK; traditional payment giants are all increasing their investment in this area.

IV. Convergence Amidst Differentiation: Consensus on Five Core Principles

Side-by-side observation of the three regulatory frameworks reveals stark differences. The US approach prioritizes market efficiency, allowing for diverse issuers, but at the cost of a minimum capital requirement of US$5 million and a strict interest rate ban. Hong Kong's approach is a "traditional financial extension," strictly limiting issuers to licensed financial institutions with a minimum capital of HK$25 million and requiring reserve assets to be held in Hong Kong. The EU's approach is "comprehensive prudential supervision," with a dual capital requirement of €250,000 and a complex overlap between MiCA and PSD2.

Despite these differences, five core principles are gaining global consensus. First is the 1:1 reserve principle. All three frameworks require stablecoin issuers to hold reserve assets equivalent to the circulating supply, ensuring redemption at any time. Second is the reserve segregation principle. All three require that reserve assets be segregated from the issuer's own assets to prevent misappropriation. Third is the prohibition of interest payments. All three frameworks prohibit stablecoin issuers from paying interest or returns to holders, clearly defining stablecoins as "payment instruments" rather than "investment products." Fourth is the anti-money laundering compliance principle. All require strict KYC, transaction recording, and reporting obligations. Fifth is the consumer protection principle. All frameworks protect the interests of holders through mechanisms such as reserve requirements, information disclosure, and redemption rights guarantees.

This pattern of "convergence of principles but differentiation in details" is essentially a competition among different jurisdictions for "rule-making power"—whoever can provide enterprises with lower compliance costs and more flexible operating space without sacrificing financial stability will gain an advantage in the next decade of digital finance .

For Chinese companies, understanding this differentiation and convergence is itself a strategic capability.

In March 2026, when the stablecoin regulatory frameworks of the three major economies are almost simultaneously implemented, we are witnessing a historic moment: the "Warring States" era of digital finance is coming to an end, and a "new order" dominated by rules is taking shape.

The US has chosen "efficiency first"—letting market forces drive innovation and maintaining its advantage through dollar hegemony. Hong Kong has chosen "compliance extension"—backing digital assets with the prudence of traditional finance, becoming a bridge connecting China and the world. The EU has chosen "institutions first"—drawing boundaries with the highest standards, attempting to become a global rule-maker.

There is no absolute right or wrong among these three choices, only differences in adaptability to different resource endowments and strategic goals. However, for Chinese companies, understanding these differences is itself a strategic capability—between the institutionalized operation of Digital Yuan 2.0 and the compliant channel of Hong Kong stablecoin licenses, a "fast track" connecting high-quality mainland assets with global digital capital has been paved.

As Mastercard's acquisition of BVNK reveals, stablecoins are no longer a niche crypto experiment, but rather the cornerstone of the next generation of global payment networks. Whoever can find their own path in the regulatory race will gain a competitive edge in the wave of digital civilization. And the starting point of this path is understanding the rules; the end point is shaping those rules.

(Data sources for this article: official announcements from the People's Bank of China, original text of the OCC proposal, reports from 21st Century Business Herald, Economic Herald, Mobile Payment Network, legal analysis from The National Law Review, and Economic Weekly. All data is current as of March 2026.)

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