The U.S. Senate and the Hong Kong Legislative Council took key steps on stablecoin regulation almost at the same time this week: the former passed the procedural motion of the GENIUS Act with an overwhelming advantage, clearing the way for the first federal stablecoin bill in the United States; the latter passed the third reading of the Stablecoin Bill, making Hong Kong the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. The high overlap of the legislative rhythms of the East and the West is not just a collision of chance opportunities, but also a competition for the right to speak in the future of finance.
Stablecoin annual transaction volume may exceed $100 trillion by 2030
According to incomplete statistics from OKG Research, the current global stablecoin market value is close to $250 billion, an increase of more than 22 times in the past five years; from the beginning of 2025 to date, the on-chain transaction volume has exceeded $3.7 trillion, and the annual total is expected to be close to $10 trillion . US dollar stablecoins represented by USDT and USDC have been widely used for transactions and remittances in emerging markets, and in some regions the scale has even exceeded that of traditional payment systems. Stablecoins have leapt from marginal assets to key nodes in the global payment network and sovereign competition. The United States and Hong Kong have accelerated legislation almost at the same time, which means that the global stablecoin market has entered a period of accelerated compliance.
Based on this, OKG Research refers to the previous calculation model of Standard Chartered Bank, and combines the current pace of regulatory signal release and the attitude of institutional funds. On the premise of keeping the current stablecoin turnover rate basically unchanged, it is calculated that:
Under the optimistic scenario of the gradual rollout of the global compliance framework and widespread adoption by institutions and individuals, the global stablecoin market supply will reach 3 trillion US dollars in 2030, with monthly on-chain transaction volume reaching 9 trillion US dollars, and the annual transaction volume may exceed 100 trillion US dollars. This means that stablecoins will not only be on par with traditional electronic payment systems, but will also occupy a structural foundation in the global clearing network. In terms of market value, stablecoins will become the "fourth type of base currency asset" after government bonds, cash, and bank deposits, and become an important medium for digital payments and asset circulation.
What is more noteworthy is that under this growth trend, the reserve structure of stablecoins will also have a feedback effect on the macro economy. OKG Research previously stated that the current scale of stablecoins has absorbed about 3% of the short-term US Treasury bonds that are about to mature, ranking 19th in the list of overseas US Treasury bond holders.
Considering that the GENIUS Act explicitly requires 100% of the reserves to be highly liquid US dollar assets, short-term US Treasuries are considered the main choice ( currently more than 80% of USDT/USDC reserve assets are related to US Treasuries. ) If the allocation ratio is estimated at 50%, the market value of 3 trillion US dollars will correspond to at least 1.5 trillion US dollars in short-term US Treasuries. This scale is close to the current US Treasury holdings of overseas sovereign buyers in China or Japan, and stablecoins are expected to become the "largest invisible creditor" of the US Treasury.
Comparison of stablecoin regulatory frameworks in the United States and Hong Kong: consensus amid disagreement
Although the United States and Hong Kong differ in legislative paths and some details, they have reached a high degree of consensus on basic principles such as "legal currency anchoring, sufficient reserves, and licensed issuance."
The GENIUS Act defines "payment stablecoins", that is, stablecoins that are anchored to legal currencies such as the US dollar, promise to be redeemable at a 1:1 ratio, and cannot carry interest income, emphasizing their non-securities attributes, and is intended to prevent stablecoins from evolving into financial products with investment attributes. Hong Kong, on the premise of ensuring a full 1:1 anchor, has not yet restricted interest income and anchoring structure, seeking to open up a new track in the stablecoin market dominated by the US dollar and reserve space for future innovation.
In terms of reserve requirements, both the United States and Hong Kong require sufficient anchoring of high-liquidity assets, but the GENIUS Act clearly defines the types of eligible reserve assets, including T-Bills, cash and repurchase agreements, and requires monthly audits; Hong Kong also requires audits and segregated custody, but the types of reserve assets are not fully limited.
In terms of institutional framework, the GENIUS Act adopts a dual-track system of "federal-state", providing three paths for the issuance of stablecoins: banks or their subsidiaries apply to issue stablecoins, which are supervised by banking regulators such as the Federal Reserve and the FDIC; non-bank institutions can apply to the OCC to become federal licensed issuers, or obtain licenses through state regulators . Hong Kong is uniformly licensed by the HKMA, and requires that regardless of whether the stablecoin issuer is located in Hong Kong, as long as it is anchored to the Hong Kong dollar or actively provides services to the Hong Kong public, it must apply for a license.
In terms of the management of overseas issuers, the GENIUS Act explicitly prohibits the circulation of unlicensed overseas stablecoins in the U.S. market, authorizes the Treasury Department to establish a "non-compliant stablecoin list" and block their circulation paths through U.S. digital asset service providers; Hong Kong mainly focuses on stablecoins anchored to the Hong Kong dollar and remains open to non-Hong Kong dollar stablecoins.
These institutional differences reflect the different demands of the two places on the positioning of stablecoins. The United States mainly focuses on maintaining the dominance of the US dollar and serving the needs of fiscal structural financing, and promotes stablecoins to become an extension of the on-chain US dollar; while Hong Kong hopes to attract global Web3 projects without damaging local financial stability, leaving policy flexibility in many details, aiming to create a controlled but open and compatible Asia-Pacific compliance innovation test site.
How does the implementation of stablecoin regulation affect the Web3 ecosystem?
The real significance of the implementation of stablecoin regulation lies in providing a payment and settlement foundation for the large-scale adoption of Web3.
In the DeFi field, although stablecoins such as USDT and USDC are important settlement assets for on-chain financial innovation, the lack of clear legal status and accountability mechanisms makes it difficult for institutions to directly participate. If stablecoin regulatory frameworks such as the Genius Act are implemented one after another, stablecoins provided by compliant issuers will become the clearing core of "compliant DeFi", and the protocol will embed more KYC, AML and asset identification modules, and decentralized finance will gradually evolve into an "auditable on-chain financial network."
In the Web3 payment system, the implementation of stablecoin regulation will break the gray line between payment scenarios and asset circulation in the past, allowing stablecoins to truly move from "transaction intermediaries" to "payment channels". OKG Research observed that since Visa announced that the cumulative stablecoin clearing volume exceeded US$225 million, many payment technology companies have successively embedded stablecoins into their merchant settlement processes; Web3 wallets use stablecoins as the default payment assets to expand micropayment scenarios such as recharge, reward, and subscription. On-chain payment is transforming from a "transfer tool within the crypto circle" to an "enterprise-level financial interface", and compliance is a necessary prerequisite for this transformation.
The deeper change lies in the reshaping of the global clearing structure: stablecoins open up the connection between local currencies and on-chain assets by anchoring fiat currencies at a 1:1 ratio. At the same time, they do not rely on the bank account system and can achieve "point-to-point" clearing. This means that in future scenarios such as cross-border payments, on-chain trade financing, and RWA dividends, stablecoins may replace traditional banks as the hub of capital circulation.
In the past, when we discussed the large-scale popularization of Web3, we focused too much on technological breakthroughs and user experience, and ignored the legitimacy of the underlying assets. Now, compliant stablecoins provide the "last piece of the puzzle": they are both institutionally recognized trading assets and programmable on-chain. They are both digital mirrors of the US dollar and the Hong Kong dollar, and can be directly used in DeFi protocols and NFT transactions.
In other words, stablecoins are not an appendage of Web3, but one of the forces driving it towards the mainstream. With the support of compliant stablecoins, from RWA asset transactions to on-chain salary payments, from cross-border clearing to Web3 payment interfaces, stablecoins will become "infrastructure assets" that promote the large-scale popularization of the on-chain economy.
