With the implementation of stablecoin legislation, who will become the next hot spot for RWA and cross-border payments?

Author: Ying Ying, Research by CITIC Construction Securities Hong Kong's Stablecoin Ordinance has officially become a law, and the dominance of the "right to mint" of digital currency may become the focus of global competition. On May 30, the Hong Kong Special Administrative Region Government published the Stablecoin Ordinance in the Gazette, marking the official entry into force of this epoch-making digital financial regulatory regulation. Hong Kong officially became the world's first jurisdiction to establish a comprehensive regulatory framework for fiat stablecoins. This pioneering legislative measure is regarded as another major breakthrough in the field of financial technology supervision after Hong Kong introduced the virtual banking license system in 2017. It will not only further consolidate its position as an international financial center, but also establish "oriental standards" in the field of global digital financial governance.

1. From the perspective of the legislative history, it fully reflects the characteristics of prudence and gradual progress. The formation of the Ordinance did not happen overnight. The Hong Kong Financial Bureau issued a discussion document on crypto assets and stablecoins in 2022, marking the official launch of the Ordinance. The Regulations have gone through three stages: preliminary research and preparation, gradual construction of systems, and draft promotion and implementation. They have been continuously adjusted and optimized. They were officially implemented on May 30, 2025, and finally built a comprehensive and systematic stablecoin regulatory framework.

2. From the perspective of legislative content, the core innovation lies in strict access, strengthening reserves, and ensuring redemption. The Regulations adopt the principle of "value anchoring supervision" and innovatively build a full-chain supervision system for stablecoins around regulatory agencies, regulatory objects and definitions, regulated stablecoin activities, licensing standards, license periods, sales restrictions and regulatory penalties mechanisms. The core innovation of the Regulations is mainly reflected in strict access systems, transparent reserve management and investor protection. 1) Strict access system: The issuer needs to apply for a license, with a minimum registered capital of HK$25 million, and needs to prove reserve management capabilities and risk response capabilities. 2) Transparent reserve management: The Regulations implement the regulatory mechanism of "100% fiat currency reserve + independent custody + monthly audit". 3) Complete investor protection: an unconditional redemption system, where users can redeem stablecoins at face value at any time. The issuer must handle it within a reasonable time, otherwise there will be heavy fines.

3) From the perspective of legislative impact, both standardizing development and seizing opportunities are important. As the world's first special legislation for fiat currency stablecoins, the Regulations fill the gap in fiat currency stablecoins regulation and help promote the compliance development of stablecoins. 1) Improve compliance threshold. Implementing a high-standard licensing system (such as a minimum paid-in equity capital of 25 million, strict reserve assets requirements, etc.) will help increase the entry barriers of the stablecoin market, restrict the entry of small or emerging stablecoin issuers, screen out financially stable and technically reliable participants, and promote the development of the stablecoin market toward specialization and transparency. 2) Strengthen investor hearts. The Regulations effectively reduce fraud and market risks through strict licensing, reserve assets management and punishment mechanisms. For example, only licensed institutions are allowed to provide stablecoins to retail investors. 3) Seize the opportunities of stablecoin globalization development. With the improvement of the regulatory framework, stablecoins are moving from niche tools in the crypto world to the mainstream financial stage and are expected to become the infrastructure of the next generation of financial systems. The promulgation of the "Regulations" shows that Hong Kong intends to occupy an important position in the global stablecoin market and seize opportunities for the globalization of stablecoin.

4. From the perspective of global competition, mastering the rule-making power will be expected to gain the upper hand in the future reshuffle in the monetary system. In addition to Hong Kong, countries and regions such as the United States, the European Union, and Africa are also competing fiercely for the dominance of stablecoins. The GENIUS Act of the United States attempts to bring stablecoins into national strategic tracks to consolidate the dominance of the US dollar in the global monetary system, and requires that stablecoin legislation also needs to be deeply bound to the demand for government bonds. The EU's Crypto Asset Market Supervision Act attempts to redefine the digital financial order with a unified regulatory framework. African stablecoins are focused on "financial equality tools" to help people fight inflation and currency depreciation. In the future, if you master the right to formulate the rules for "minting rights" of digital currency, you will be expected to gain the upper hand in the future reshuffle of the monetary system.

The scale of the stablecoin market is growing rapidly, and the activity of cross-border payment application scenarios continues to rise . 1) From the perspective of market size, the stablecoin market has grown rapidly, with an increase of more than 1,100% in five years. According to Deutsche Bank data, in 2020, the total market value of stablecoins was about US$20 billion. As of May 30, 2025, the total market value of stablecoins had soared to US$249.7 billion, an increase of more than 1,100% in about five years. Among them, Tether , launched by the stablecoin issuer Tether in 2014, accounted for more than 60% of the stablecoin market, followed by USDC (accounting for more than 24%). In addition, stablecoins also dominate the transaction flow, with stablecoins trading volumes reaching $28 trillion in 2024, exceeding the combined Visa and Mastercard and supporting more than one-third of cryptocurrency transactions. 2) From the perspective of market competition pattern, the stablecoin market is showing a highly concentrated situation, mainly dominated by stablecoins supported by fiat currencies such as USDT, USDC, TUSD, and BUSD, accounting for more than 90% of the market share. Among them, USDT ranked first with an issuance of US$144.6 billion, accounting for 59%; USDC issuance of US$60.6 billion, accounting for 25%, with a significant growth rate (35%). The concentration of the stablecoin market continues to increase, and the head effect is significant. 3) From the perspective of application scenarios, stablecoins are constantly increasing in cross-border payment settlement. The application scenarios of stablecoins are constantly expanding, mainly including crypto asset transactions, cross-border payments, DeFi innovation scenarios, and value storage applications. Among them, the activity of stablecoins in cross-border payment settlement is increasing. Measures by Castle Island Ventures and Brevan Howard Digital (2024) show that in the 12 months before May 2024, the payment settlement volume of stablecoins reached about US$2.5 trillion, 10 times its payment settlement volume in 2020.

The implementation of stablecoin legislation will help accelerate the large-scale application of RWA, and the RWA market size is expected to soar to US$16 trillion in 2030. Compliant and transparent stablecoins are expected to play an indispensable "engine" and "cornerstone" role in the RWA ecosystem, building a compliance and trust foundation for RWA financing, and at the same time significantly reduce costs and improve efficiency, which will accelerate the process of converting various real assets into digital tokens through blockchain technology , which is expected to support the large-scale application of RWA. In recent years, many countries around the world, including the United States, Japan, Singapore, etc. have been actively exploring innovative applications of RWA. Giants such as Goldman Sachs, BlackRock, Ant Group, and JD.com have entered the market and actively seized the development opportunities of RWA. In October 2022, Hong Kong issued the "Virtual Asset Policy Declaration" to establish the strategic position of RWA; in March 2024, the Hong Kong Monetary Authority launched the Ensemble project, covering four major themes: fixed income and investment funds, liquidity management, green and sustainable finance, trade and supply chain finance, and has formed many RWA benchmark cases. For example, in August 2024, Langxin Group joined hands with Ant Digital Technology and UBS Group (main underwriter) to run the cross-border RWA case of domestic new energy assets. The underlying assets anchored the operating income rights of 9,000 charging piles in China, and raised RMB 100 million.

As of June 2, 2025, the total value of on-chain RWA was US$23.1 billion (excluding stablecoins), an increase of more than 110% year-on-year. Among them, private credit is US$13.4 billion, US Treasury bonds are US$7.2 billion, and commodity goods are US$1.5 billion. According to BlackRock's forecast, the RWA market size will soar to $16 trillion by 2030. As RWA continues to deepen and develop, RWA ecological entities such as issuing institutions, custodial banks, investors, and blockchain are expected to grow rapidly, and investment opportunities may be seen in fields such as RWA asset operation, bank IT and cross-border payments.

Summarize:

Hong Kong's "Stablecoin Ordinance" is officially implemented, and it is optimistic that stablecoins and RWA will accelerate to enter a new stage of accelerated development. On May 30, the Hong Kong "Stablecoin Ordinance" was officially implemented as the world's first special legislation for fiat stablecoins, effectively filling the gap in fiat stablecoins regulation and accelerating the regulatory development of stablecoins. Hong Kong has officially become the world's first jurisdiction to establish a comprehensive regulatory framework for fiat stablecoins. At the same time, the United States, the European Union, Africa and other countries are also competing fiercely for the dominance of stablecoins in order to gain the initiative in the future reshuffle of the monetary system. The scale of the stablecoin market has grown rapidly, with an increase of more than 1,100% in five years, and the activity of cross-border payment application scenarios has continued to rise. At the same time, the implementation of stablecoin legislation will help accelerate the large-scale application of RWA, and the RWA market size is expected to soar to US$16 trillion in 2030. As RWA continues to deepen and develop, RWA ecological entities such as issuing institutions, custodial banks, investors, and blockchain are expected to grow rapidly, and investment opportunities may be seen in fields such as RWA asset operation, bank IT and cross-border payments.