Author: EXIO Research Institute
Global virtual asset regulation is moving from 'setting the rules' to 'the elimination round.' Hong Kong SFC has just defined new boundaries for stablecoin services, the EU MiCA transition period is about to end, and the US CLARITY Act has passed a key Senate committee. The three major markets are entering a 'compliance screening phase'—compliant players get their entry ticket, while latecomers may find themselves locked out.
1. Three major signals, all pointing in the same direction.
2024 to 2025 will be a 'legislative crunch period' for crypto regulation: Hong Kong's stablecoin regulations take effect [1], EU MiCA becomes fully applicable [2], and the US passes its first federal stablecoin law, the GENIUS Act [3]. By 2026, the rules will be set in stone, and the question will shift to 'who can comply.'
In the past two weeks, three independent regulatory threads have emerged simultaneously, pointing to the same conclusion: the major global markets are not 'loosening' crypto but are restructuring the market by licensing, products, custody, and client classification.
Region
Regulatory Actions
Time
Core Impact
Hong Kong
SFC Issues Relevant Stablecoin Circular [4]
May 27
Differentiated Regulation for Stablecoins and Regular VAs
EU
MiCA Transition Period Ends [2]
July 1
Unlicensed platforms must cease operations
US
CLARITY Act Committee Passed [5]
May 14
SEC/CFTC Jurisdictional Division Established
II. Hong Kong: Dual Regulation for Stablecoins Officially Launched
2.1 What is a Relevant Stablecoin?
In the circular dated May 27, the SFC defined the regulatory boundaries for Relevant Stablecoin services for licensed virtual asset trading platforms (VATPs) and licensed entities [4]. To meet this definition, stablecoins must satisfy two conditions: they must be recognized as 'designated stablecoins' under the Stablecoin Regulation and be issued and authorized by HKMA licensed issuers.
On April 10, HKMA issued the first licenses for stablecoin issuers to HSBC and Standard Chartered [6], indicating that compliant options already exist in the market. This marks the formation of Hong Kong's 'dual-framework': HKMA manages issuance, and SFC oversees trading and distribution.
2.2 Coexistence of Relaxation and Constraints
The core message from SFC is differentiated treatment — the risk characteristics of Relevant Stablecoins differ from speculative assets like Bitcoin and are closer to payment tools, so some rules can be relaxed [7]:
Dimensions
Relevant Stablecoin
Regular VA
Retail Liquidity / Index Requirements
❌ Not Applicable
✅ Applicable
VA Knowledge Assessment
Partially Exempt
Must
Exposure Limit
Not Included in Limit
Included
Suitability
Compliance still required during solicitation
Must Comply
Stability Mechanism / Redemption Disclosure
Must Disclose
Depends on the product
Launch / Suspend / Remove
Must Notify SFC in Writing
Must Notify
But 'differentiation' does not equal 'relaxation.' If the platform promotes 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 Hong Kong Securities and Futures Commission announced a new regulatory framework to promote the secondary market trading of tokenized investment products (tokenized products) approved by the SFC, to long-term foster local digital asset trading activities in Hong Kong, supporting further growth of the ecosystem [8]. Three policy lines intertwine to form a clear path: stablecoins as settlement infrastructure, tokenized securities as investment tools, VATPs for compliant distribution + custody + trading channels — this is a complete regulatory loop for virtual assets.
III. EU: MiCA's 'Big Test' Countdown
If Hong Kong is 'fine-grained layering,' the EU is 'compliance screening.' ESMA confirmed on April 17 that the MiCA transition period will end on July 1 [2]. After this date, entities that do not hold a CASP license providing services to EU clients will be illegal.
As of early May, only 210 entities in 23 EU countries have been authorized as CASPs [9], with 86% having activated passporting for cross-border services. This number is just the tip of the iceberg compared to the total of VASPs registered in the EU prior (before MiCA took effect, each member state had its own VASP registration system, totaling about 3,000–3,200 VASPs). Progress varies by country. Germany leads with 53 authorized entities [9], with strict approvals and high capital requirements; Poland's implementation bill has been vetoed twice by the president [10], risking a legal vacuum post-July 1. The median time from application to licensing has reached 6 to 9 months [9], with applicants in the second half of the year likely having to wait until 2027 to operate legally.
IV. US: CLARITY Act Legislative Sprint
US crypto regulation is shifting from 'enforcement-driven' to 'rules-driven.' On May 14, the Senate Banking Committee passed the CLARITY Act by a vote of 15 to 9 [5], the first federal legislation attempting to clarify the jurisdictional division 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 stablecoins in the regulatory framework [11].
The fiercest battle centers on stablecoin yields. The final compromise is: banning 'passive income' based on idle balances, but allowing 'active rewards' linked to substantive activities like payments and lending [12]. This draws a middle line between banking stability and crypto innovation.
But there is still a distance to go before it becomes law. The full Senate vote requires 60 votes to overcome lengthy debates [13], with Polymarket predicting a 73% probability of becoming law by 2026 [5].
Legislative Process
Time
Status
House Passed
July 2025
✅ 294-134 Votes [11]
Senate Banking Committee
May 14, 2026
✅ 15-9 Votes [5]
Full Senate
Expected in the second half of 2026
⏳ Need 60 Votes [13]
President Signed
White House Target July 4
⏳ To Be Determined [5]
V. Stablecoins are Becoming 'Financial Infrastructure'
The deep background of synchronized regulatory advancement in the three regions is the fundamental transformation of stablecoins' roles. By 2025, global stablecoin payment volume is expected to reach $33 trillion [14], comparable to the annual total processing volume of Visa and Mastercard; total market cap will exceed $320 billion [3]. US Treasury Secretary Scott Bessent predicts it could reach $3.7 trillion by 2030 [3].
Use cases are also expanding: about 67% are related to DeFi and trading, 15% for cross-border remittances, 10% as an inflation hedge, and 5% for merchant payments [15]. Stablecoins are no longer just a 'bridge currency' for crypto users but also serve as a settlement layer between traditional finance and digital finance.
Hong Kong, EU, and US regulatory paths differ, but the direction is consistent: bringing stablecoins into the regulated financial infrastructure system rather than allowing their 'wild growth.' This means that compliance capability will be the dividing line in the next round of competition — it's not about 'who has the most products,' but 'who completes compliance market entry first.'
Conclusion
The global crypto market is undergoing a silent yet profound 'access reshuffle.' Hong Kong's dual stablecoin framework, the EU's licensing screening, and US market structure legislation collectively outline the contours of a new era: compliance is no longer a cost, but a 'license to operate' in the new age. For investors, understanding this paradigm shift will be key to assessing the long-term value of platforms and assets (especially asset safety).