In 2025, the global stablecoin market has shown signs of accelerated expansion. As of mid-June 2025, the market size of stablecoins exceeded USD 250 billion, accounting for approximately 8% of the entire crypto asset market. This scale has already surpassed the money supply of many emerging economies, marking stablecoins as a force that can no longer be ignored in the global financial system. In terms of transaction volume, stablecoins reached approximately USD 37 trillion in 2024, significantly surpassing Bitcoin’s USD 19 trillion during the same period. Standard Chartered Bank forecasts that the stablecoin market could reach USD 2 trillion by 2028.

Against this backdrop, the United States and several countries and regions in Asia have been actively advancing stablecoin legislation. Among them, the most representative are Hong Kong and the U.S. On May 21, Hong Kong’s Legislative Council unanimously passed the Stablecoin Ordinance, making it the world’s first jurisdiction to establish a comprehensive regulatory framework specifically for fiat-backed stablecoins. The ordinance will officially come into effect on August 1, 2025. On May 20, the U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). On July 18, President Donald Trump officially signed the GENIUS Act at the White House, marking the first time the U.S. has formally established a regulatory framework for digital stablecoins. What then, are the different underlying logics behind stablecoin issuance in Hong Kong versus the United States?

For the United States, its logic behind issuing stablecoins revolves around building a pool of liquid assets backed by U.S. Treasuries, U.S. dollars, and other dollar-denominated assets. This not only strengthens the influence of the U.S. dollar in the digital economy but also helps expand demand for U.S. Treasury securities.

The U.S. holds a dominant position in the global financial system, and stablecoins have become a tool to maintain and reinforce that influence. According to the GENIUS Act, U.S. stablecoins can only be pegged to the U.S. dollar (including Treasuries), explicitly excluding other fiat currencies. This reflects the principles of "America-led" and "America First", promoting the dollarization of the global decentralized finance (DeFi) market. It also brings stablecoins like USDC and PayPal USD under regulatory oversight, indirectly serving as a form of digital SWIFT, and reinforcing the dollar’s dominance in the digital world.

In reality, the development of stablecoins in the U.S. largely centers around “high-liquidity dollar assets”. Stablecoins pegged to the U.S. dollar have consistently dominated in terms of market capitalization, circulation, and use cases. Among them, USDT and USDC together account for over 80% of the total market value. Tether’s USDT leads with a market cap of USD 153.3 billion, followed by Circle’s USDC at around USD 61.4 billion.

At the same time, in theory, stablecoins follow a 1:1 reserve rule and do not create new base money. However, the GENIUS Act allows issuers to convert dollar reserves into U.S. Treasuries, enabling them to earn interest without passing those earnings on to users. This means that cash from the banking system is ultimately funneled into the bond market, while the stablecoins representing those bonds continue to circulate in the market just like real U.S. dollars.

This also largely reflects another intention of the U.S., i.e., to increase market liquidity without printing money and also bypassing the Federal Reserve. It has turned the expansion of U.S. Treasury bonds into a tool, while also finding a stable and potentially growing group of buyers for the bonds, thereby alleviating the structural contradiction and real dilemma of long-term fiscal deficits and a national debt reaching USD 36 trillion.

In contrast to U.S. stablecoins, the issuance logic of Hong Kong stablecoins places greater emphasis on reconstructing asset creditworthiness, focusing on countering the threat of financial sanctions and promoting the internationalization of the Chinese yuan, further expanding the influence of fiat currency, and consolidating its status as an international financial center.

According to Hong Kong’s Stablecoin Ordinance, designated stablecoins can be pegged to one or more official currencies to maintain a stable value; this can include the U.S. dollar, Hong Kong dollar, the Chinese yuan, or other major fiat currencies. Additionally, stablecoins must follow a 1:1 reserve rule, meaning that licensed issuers are required to back all circulating stablecoins with 100% high-quality liquid assets. These reserve assets will be subject to strict regulatory oversight.

This implies that the credit backing of Hong Kong stablecoins will be diversified, and local assets such as real estate can also be used as collateral. It reflects a de-dollarization intent, breaking away from the monetary issuance constraints imposed by the linked exchange rate system and the ceiling of U.S. dollar reserves. Currently, Hong Kong has already attracted institutions like Standard Chartered, JD Technology, and RD Technologies to participate in the stablecoin “regulatory sandbox”. The first batch of compliant Hong Kong dollar stablecoins is expected to debut in early 2026. For example, JD's approval to issue stablecoins in Hong Kong is centered on using high-quality corporate assets as backing and releasing credit through stablecoins. The Hong Kong Monetary Authority estimates that the global stablecoin transaction volume will reach nearly USD 10 trillion in 2025. Based on this proportion, the transaction volume of Hong Kong stablecoins is expected to reach approximately USD 1.5 trillion in 2025.

It is important to emphasize that the Stablecoin Ordinance provides a clear pathway for the compliant issuance of offshore yuan stablecoins. As an offshore yuan center, Hong Kong offers a testing ground for offshore yuan (CNH) stablecoins. If successfully issued, these stablecoins could establish a cross-border payment channel independent of SWIFT and complement the existing Cross-Border Interbank Payment System (CIPS), increasing the yuan’s share in cross-border trade, while also creating a complementary relationship between Hong Kong dollar stablecoins and the digital yuan.

Although Hong Kong and the U.S. share similar ideas in the stablecoin issuance process, their specific strategies reflect clear institutional differences, indicating their distinct financial environments.

The U.S. is the issuer of the global currency, and its financial logic is inherently oriented toward expansion. Stablecoins serve as an extension of the U.S. dollar, building capital pools to reinforce the dollar’s dominant position in the digital realm and alleviate its enormous domestic debt pressure. Hong Kong, on the other hand, functions as a financial gateway and offshore window, with a financial logic focused on maintaining liquidity and financial attractiveness. Stablecoins have become a supplement to Hong Kong’s liquidity and a mechanism for credit release, weakening the financial sanctions and clearing risks tied to the U.S. dollar, and providing Hong Kong with an opportunity to build endogenous financial sovereignty.

Ultimately, U.S. stablecoins are a technological reinvention of asset pools that reinforce the dollar’s dominance and expand the demand for Treasury bonds; whereas Hong Kong stablecoins represent a diversified reconstruction of credit assets, aimed at alleviating the linked exchange rate system, providing a global window for the digital yuan, and consolidating its status as an international financial center. However, in the wave of reshuffling the global digital financial order, stablecoins may only be the starting point. What will truly determine the future is the comprehensive strength behind each economy.

Final analysis conclusion:

As the global stablecoin market accelerates its expansion, multiple countries and regions are actively advancing stablecoin legislation. The difference in issuance logic between the United States and Hong Kong lies in the fact that U.S. stablecoins represent a technological reinvention of asset pools to strengthen the dollar’s dominance in the digital space and alleviate its enormous domestic debt pressure. On the other hand, Hong Kong stablecoins focus on the diversified reconstruction of credit assets to help relieve pressure on the linked exchange rate system, provide a global window for the digital yuan, and consolidate its status as an international financial center.

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Xia Ri is an Industry Researcher at ANBOUND, an independent think tank.