Analysis of Hong Kong's Stablecoin Ordinance Draft by Ren Tao

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Key Takeaways

Overview of Hong Kong's Stablecoin Regulatory Framework

Hong Kong's Stablecoin Ordinance Draft represents a landmark development in digital asset regulation. Approved by the Legislative Council on May 21, 2025, and gazetted on May 30, this legislation positions Hong Kong as a pioneer in comprehensive stablecoin oversight.

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Historical Context

  1. 2021: HKMA released initial consultation paper on stablecoin regulation
  2. 2023: Draft ordinance published for public consultation
  3. 2024: Regulatory sandbox launched with首批3家参与机构 including Standard Chartered Bank (Hong Kong)
  4. 2025: Final approval and implementation

Core Provisions of the Ordinance

Definition of Stablecoins

The ordinance defines "specified stablecoins" as:

Regulatory Scope

RequirementDescription
LicensingHKMA oversees licensing (fee: HK$113,020)
JurisdictionCovers HKD-pegged stablecoins issued overseas
MarketingRegulates promotions targeting Hong Kong public

Issuer Requirements

  1. Capital: Minimum HK$25 million reserve
  2. Asset Management: Segregated high-liquidity reserves
  3. Compliance: AML/CFT, financial audits, management vetting
  4. Transparency: Regular public disclosures and HKMA oversight

Significance of the Legislation

  1. Market Confidence: Provides legal certainty for stablecoin innovation
  2. Global Leadership: First comprehensive fiat stablecoin framework
  3. Financial Stability: Aligns with FSB recommendations for crypto oversight

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Frequently Asked Questions

What assets can stablecoins be pegged to?

The ordinance permits pegging to:

Can stablecoins pay interest?

No. The ordinance explicitly prohibits interest payments on specified stablecoins.

How does this affect retail investors?

Only licensed issuers may sell fiat stablecoins to retail investors, with strict advertising restrictions.

What's unique about Hong Kong's approach?

The framework combines:

Stablecoin Applications and Innovations

Cross-Border Advantages

Emerging Use Cases

  1. Tokenized Bonds: Creating liquid secondary markets
  2. Smart Contracts: Automating financial processes
  3. Cross-Border Payments: Reducing FX friction