✅ Policy Implementation Overview
• Hong Kong's Stablecoins Ordinance officially came into effect on August 1, 2025, establishing a licensing system for fiat-referenced stablecoins (FRS) and regulating their issuance and marketing.
• The HKMA has published supporting supervisory guidance, AML/CFT guidelines, exemption clauses, and application transitional arrangements, and is now accepting market feedback. The market is encouraged to proactively engage with the regulator by August 31 and submit the first round of application materials by September 30.
🎯 Core Regulatory Requirements
• Token issuers must obtain a HKMA license; this includes stablecoins issued in Hong Kong or overseas but pegged to the Hong Kong dollar.
• Minimum registered capital must be HKD25 million, 100% of which must be held in highly liquid covered assets. The system must ensure user redemptions within one day, separate fund custody, and preferred liquidation rights.
• All holders must complete real-name identity verification (KYC) and establish a governance structure that tracks the identities of token holders.
💡 Market Reaction and Application Positioning
Market Participation Enthusiasm
• Over 50 institutions are expected to express interest in applying. Only 3–4 licenses will be issued in the initial phase, focusing on issuing Hong Kong dollar or US dollar stablecoins. RMB-pegged stablecoins still require careful exchange rate policy coordination and mechanism clarification.
• Institutions such as JD CoinChain, Standard Chartered Bank, Ant Group, and LianLian Technology have already entered the market and are participating in testing through joint ventures, gaming applications, and other means.
Funding and Industry Response
• Hong Kong fintech companies raised approximately US$1.5 billion in July, with the majority invested in digital assets, stablecoins, RWA issuance, and payment system development, signaling the industry's rapid seizure of development opportunities.
• Market analysts believe that Hong Kong dollar stablecoins will meet cross-border payment needs and those for Belt and Road Initiative projects, while US dollar stablecoins will focus on improving international market liquidity and efficiency. RMB stablecoins are a future development direction, but will be implemented with caution.
⚠️ Risk Boundaries and Regulatory Pace
• The HKMA has not yet issued any licenses, but the first batch is expected to be awarded in early 2026. Applicants should proceed with compliance preparations prudently and avoid hype and misleading statements, as false advertising of licenses is illegal.
• If existing institutions fail to apply and meet the requirements within the prescribed timeframe, they may be prohibited from continuing operations or be forced to cease operations, accelerating market cleanup.
