From Sandbox to License: Comparing Stablecoin Regulatory Paths in 12 Global Countries
Author: Fairy, ChainCatcher Editor: TB, ChainCatcher Original title: Breaking the circle: 12 countries' stablecoin regulatory policies are broadly compared to stablecoins, and the circle-breaking effect continues to expand. From high-frequency related topics popping up on Douyin's hot lists, to content creation turned to by traditional financial bloggers, to active inquiries from relatives and neighbors, stablecoins seem to have become a social buzz word that permeates everyday life. At the same time, the global policy side also ushered in a critical turning point. Over the past year, the attitude of many countries towards stablecoins has changed from careful wait-and-see to acceptance: Hong Kong's “Stablecoin Regulations” are about to be implemented, the EU MiCA Act is officially implemented, and the US has passed the “Genius Act”. Stablecoins are quietly leveraging the foundations of the global monetary system. This article will systematically sort out the latest developments in stablecoin regulation in various countries and analyze the underlying logic and strategic implications of this financial transformation. A table looks at the global stablecoin regulatory situation and analyzes the evolution of stablecoin policies in the world's twelve core markets: the United States: the division of states, the speed of development of the layout policy: ★★★★ The development of stablecoins in the US shows a “federal+state” two-track situation. On the one hand, the federal government is speeding up the unification of the regulatory framework at the legislative level; on the other hand, states are taking the lead in testing the waters and promoting the implementation of the system first. At the state level, many regions have taken the lead in implementing specific regulations and regulatory frameworks: Wyoming passed the “Wyoming Stablecoin Act” in 2023, established the “Wyoming Stablecoin Commission”, and plans to issue the state-supported stablecoin WYST on August 20, 2025. In 2018, the New York Department of Financial Services required stablecoin issuers to obtain a BitLicense license or trust company license and comply with strict regulations. California passed the Digital Financial Assets Act (DFAL) in 2023, establishing a comprehensive licensing system that includes stablecoin issuers. The DFAL will officially take effect in July 2026. Regulatory legislation at the federal level is also progressing rapidly: the GENIUS Act was signed into effect by Trump on July 19, 2025. The bill requires prohibiting the issuance of yield-based stablecoins, monthly disclosure of the composition of reserves and audits, and the CEO and CFO being responsible for the authenticity of the data. Issuers can choose to be regulated by the federal or state, and smaller issuers (<$10 billion in issuance) can choose to be regulated only by the state. The STABLE Act was introduced in March 2025 and has now been reviewed by the House of Representatives and is awaiting a vote in the Senate. The draft bill is largely the same as the GENIUS Act. China: Hong Kong policy comes first, the Mainland waits for policy progress: Hong Kong ★★★★ | Mainland ★ Mainland China and Hong Kong have formed an “outpost + mainland” stablecoin regulation linkage pattern: Hong Kong took the lead in establishing a mature regulatory system to accelerate the attraction of enterprises; while the Mainland remains cautious at the policy level. On the Hong Kong side, its Stablecoin Ordinance will come into effect on August 1, 2025. Currently, about 50 to 60 companies have expressed their intention to apply. Half of them are payment institutions and the other half are large-scale internet platforms. Most of them have a Chinese background. JD, Standard Chartered, Ant, etc. have already begun relevant preparations. The industry expects to issue only 3 to 4 licenses in the first batch, and the entry threshold is quite high. According to reports, the first batch of licenses may adopt an “invitation application system” rather than a unified public application. In the early stages, stablecoins were mainly linked to the Hong Kong dollar and the US dollar. In the mainland, in the past, there was a trend of “preventive suppression” for a long time, but recently several provinces and cities have released signals of research and concern about stablecoins. On July 7, at the Wuxi Municipal Committee Reform Promotion Conference, it was proposed to explore “stablecoins to empower foreign trade development” and expand new space for digital trade; on July 9, the official account of the Jinan Municipal People's Government Research Office published a special stablecoin article written by Xinhua News Agency; on July 10, the Party Committee of the Shanghai Municipal State-owned Assets Administration Commission held a central group study meeting to study the development trends and coping strategies of cryptocurrencies and stablecoins; on July 18, the China Industrial Internet Research Institute hosted the “Stablecoins and Industrial Digital Assets Seminar”. South Korea: Attitudes have changed, and banking alliances have accelerated the pace of development policy: ★★★ South Korea is experiencing a shift from “wait and see” to “entering the market.” In the context of new President Lee Jae-myung's promise to support the development of the Korean won stablecoin, South Korea's ruling party officially proposed the “Digital Asset Basic Law” on June 10 to allow local companies with capital exceeding 368,000 US dollars to issue stablecoins, marking a relaxation at the policy level. Currently, the eight major players in Korea...
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