Author: EXIO Research Institute

Global virtual asset regulation is transitioning from "setting rules" to "elimination rounds." Hong Kong SFC has just defined new boundaries for stablecoin services, the EU's MiCA transition period is about to end, and the US CLARITY Act has passed a key committee in the Senate. The three major markets coincidentally enter the "enforcement screening period"—compliant entities have received their tickets to enter, while those who are late may be kept outside.

1. Three Signals, the Same Direction

2024 to 2025 is a "legislative intensive period" for crypto regulation: Hong Kong's "Stablecoin Ordinance" comes into effect [1], EU's MiCA becomes fully applicable [2], and the US passes its first federal stablecoin law, the GENIUS Act [3]. Entering 2026, the rules have been established, and the question becomes "who can comply."

In the past two weeks, three independent regulatory clues appeared simultaneously, pointing to the same conclusion: major global markets are not "loosening" crypto regulations but are undergoing market restructuring based on licensing, products, custody, and customer classifications.

2. Hong Kong: Stablecoin "Dual-Layer Regulation" Officially Implemented

2.1 What is Relevant Stablecoin?

The SFC's circular on May 27 delineated the regulatory boundaries for Relevant Stablecoin services for licensed virtual asset trading platforms (VATP) and licensed legal entities [4]. To fit this definition, stablecoins must meet two criteria: first, they must be "designated stablecoins" under the "Stablecoin Ordinance"; second, they must be issued and authorized by an HKMA licensed issuer.

On April 10, the HKMA issued the first batch of stablecoin issuer licenses to HSBC and Standard Chartered [6], and compliant entities already exist in the market. This marks the formation of Hong Kong's "dual-layer framework": HKMA oversees issuance, SFC oversees trading and distribution.

2.2 Coexistence of relaxation and constraints

The core message from the SFC is differentiated treatment—Relevant Stablecoins have risk characteristics that differ from speculative assets like Bitcoin, being closer to payment tools; therefore, some rules can be relaxed [7]:

However, "differentiation" does not mean "relaxation." If a platform solicits or recommends Relevant Stablecoins, it must still comply with suitability requirements and disclose the stability mechanism and redemption arrangements [4].

2.3 Hong Kong's "Hidden Agenda"

This circular is not an isolated action. On April 20, the SFC announced a new regulatory framework to promote the secondary market trading of tokenized investment products (tokenized products) recognized by the SFC in Hong Kong, aiming to further promote local digital asset trading activities and support the ecosystem's further growth [8]. The three policy lines intertwine to form a clear path: stablecoins as settlement infrastructure, tokenized securities as investment tools, VATP as compliant distribution + custody + trading channels—this is a complete regulatory closed loop for virtual assets.

3. EU: MiCA "Big Test" Countdown

If Hong Kong is "fine layering," the EU is "compliance screening." On April 17, ESMA confirmed that the MiCA transition period will end on July 1 [2]. After this date, entities without a CASP license will be illegal to provide services to EU clients.

As of early May, only 210 entities have been authorized as CASPs across 23 EU countries [9], of which 86% have initiated passport mechanisms for cross-border services. This number is just the tip of the iceberg compared to the total number of VASPs previously registered in the EU (prior to MiCA taking effect, each member state had its own VASP registration system, with a cumulative total of about 3,000–3,200 VASPs). The progress of various countries is uneven. Germany leads with 53 authorized entities [9], with strict approvals and high capital requirements; Poland's implementation bill has been vetoed by the president twice [10], risking legal vacuum after July 1. The median time from application to licensing has reached 6 to 9 months [9], and applicants in the second half of the year may have to wait until 2027 to operate legally.

4. US: CLARITY Act Sprint Legislative

US crypto regulation is shifting from "enforcement-driven" to "rules-driven." On May 14, the Senate Banking Committee passed the CLARITY Act by 15 to 9 [5], which is the first federal legislation attempting to clarify the division of jurisdiction between the SEC and CFTC.

The core content of the bill includes: SEC regulates digital assets with investment contract characteristics, CFTC regulates spot digital commodities; establishes registration rules for trading platforms and custodians; includes stablecoin regulatory framework [11].

The fiercest competition centers around stablecoin yields. The final compromise is to prohibit "passive income" based on idle balances, but allow "active rewards" linked to substantive activities such as payments and lending [12]. This draws a line between banking stability and crypto innovation.

However, there is still a distance to becoming law. The Senate full vote requires 60 votes to overcome lengthy debates [13], and Polymarket predicts a probability of about 73% for it to become law in 2026 [5].

5. Stablecoins are Becoming "Financial Infrastructure"

The profound background of synchronized regulation in three regions is the fundamental shift in the role of stablecoins. By 2025, global stablecoin payment volumes will reach 33 trillion USD [14], comparable to the annual processing volume of Visa and Mastercard; total market capitalization will exceed 320 billion USD [3]. US Treasury Secretary Scott Bessent predicts it may reach 3.7 trillion USD by 2030 [3].

The use is also expanding: about 67% is related to DeFi and trading, 15% for cross-border remittances, 10% as inflation hedges, and 5% for merchant payments [15]. Stablecoins are no longer just a "bridge currency" for crypto users, but rather the settlement layer between traditional finance and digital finance.

Hong Kong, the EU, and the US have different regulatory paths, but the direction is consistent: to incorporate stablecoins into a regulated financial infrastructure system, rather than allowing their "wild growth." This means that the ability to comply will become the dividing line in the next round of competition—not "who has the most products" but "who completes compliance market access first."

Conclusion

The global crypto market is undergoing a silent and profound "access reorganization." Hong Kong's dual stablecoin framework, the EU's license screening, and the US's legislative structure collectively outline the contours of a new era: compliance is no longer a cost, but rather the "access permit" of the new era. For investors, understanding this paradigm shift will be a key prerequisite for evaluating the long-term value of platforms and assets (especially asset safety).

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