Global crypto regulators intensify compliance scrutiny in Hong Kong, the EU, and the US

Author: EXIO Research Institute

Global virtual asset regulation is moving from “setting rules” into a “survival of the fittest” phase. Hong Kong’sSFC has just defined new boundaries for stablecoin services, the European Union’s MiCA transition period is nearing its end, and the United States’ CLARITY Act has passed a key Senate committee. All three major markets are simultaneously entering an “enforcement screening” phase—compliant players receive admission tickets, while latecomers may be shut out.

One, three signals in the same direction

2024 to 2025 is the “legislative surge period” for crypto regulation: Hong Kong’s Stablecoin Ordinance takes effect [1], the EU’s MiCA becomes fully applicable [2], and the U.S. passes its first federal stablecoin law, the GENIUS Act [3]. Entering 2026, the rules are set—the question now is, “Who can comply?”

Over the past two weeks, three independent regulatory threads have emerged, all pointing to the same conclusion: major global markets are not “opening up” to crypto, but rather restructuring their markets by license, product, custody, and customer classification.

II. Hong Kong: Dual-layer Regulation for Stablecoins Officially Implemented

2.1 What is a Relevant Stablecoin?

In its circular on May 27, the SFC defined the regulatory boundaries for Relevant Stablecoin services offered by licensed virtual asset trading platforms (VATPs) and licensed corporations [4]. To qualify under this definition, a stablecoin must satisfy two conditions: it must be a “specified stablecoin” under the Stablecoin Ordinance, and it must be issued by a licensed issuer authorized by the HKMA.

On April 10, the HKMA issued the first stablecoin issuer licenses to HSBC and Standard Chartered [6], meaning compliant tokens are now available in the market. This marks the formation of Hong Kong’s two-tier structure: the HKMA regulates issuers, while the SFC oversees trading and distribution.

2.2 Coexistence of Relaxation and Constraints

The SFC's core message is differentiated treatment — Relevant Stablecoins have risk characteristics distinct from speculative assets like Bitcoin and are more akin to payment tools, so certain regulations 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 stabilization mechanism and redemption arrangements [4].

2.3 Hong Kong’s “Hidden Agenda”

This letter is not an isolated action. On April 20, the SFC of Hong Kong announced a new regulatory framework to pilot secondary market trading of tokenized SFC-authorized investment products (tokenized products) in Hong Kong, aiming to promote digital asset trading activities locally in the long term and support the further growth of the ecosystem [8]. Three policy strands intertwine to form a clear pathway: stablecoins as settlement infrastructure, tokenized securities as investment instruments, and VATPs as compliant distribution + custody + trading channels — creating a complete virtual asset regulatory闭环.

Three: The EU's MiCA "big exam" is counting down

If Hong Kong is “fine-grained classification,” the EU is “compliance screening.” On April 17, ESMA confirmed that the MiCA transition period will end on July 1 [2]. Afterward, it will be illegal for entities without a CASP license to provide services to EU customers.

As of early May, only 210 authorized CASPs [9] existed across 23 EU countries, with 86% having activated the passporting mechanism for cross-border services. This number represents just the tip of the iceberg compared to the total number of VASPs previously registered in the EU (before MiCA took effect, member states operated their own VASP registration systems, resulting in a cumulative total of approximately 3,000–3,200 VASPs across the EU). Progress varies significantly by country. Germany leads with 53 authorized institutions [9], featuring stringent approval processes and high capital requirements; Poland’s implementing legislation has been vetoed twice by the president [10], risking a legal vacuum after July 1. The median time from application to licensing has reached 6 to 9 months [9], meaning applicants in the second half of the year may not be able to operate legally until 2027.

Four, United States: CLARITY Act pushes for legislation

U.S. crypto regulation is shifting from "enforcement-driven" to "rule-driven." On May 14, the Senate Banking Committee passed the CLARITY Act [5] by a vote of 15 to 9, marking the first federal legislation aimed at clarifying the jurisdictional division between the SEC and the CFTC.

The core provisions of the bill include: SEC regulating digital assets with characteristics of investment contracts, CFTC regulating spot digital commodities; establishing registration rules for trading platforms and custodians; and incorporating stablecoins into the regulatory framework [11].

The most intense debate centered on stablecoin yields. The final compromise prohibited "passive yields" based on idle balances but permitted "activity rewards" tied to substantive activities such as payments and lending [12]. This established a middle ground between banking stability and crypto innovation.

But there is still a distance to enactment. A 60-vote supermajority in the Senate is required to overcome a filibuster [13], and Polymarket predicts a 73% probability of enactment by 2026 [5].

Five: Stablecoins are becoming "financial infrastructure"

The deeper context behind synchronized regulatory efforts in three regions is the fundamental shift in the role of stablecoins. In 2025, global stablecoin payment volume reached $33 trillion [14], comparable to the combined annual transaction volumes of Visa and Mastercard; total market capitalization surpassed $320 billion [3]. U.S. Treasury Secretary Scott Bessent forecasts that by 2030, it could reach $3.7 trillion [3].

Use cases are also expanding: approximately 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 a settlement layer between traditional and digital finance.

Hong Kong, the European Union, and the United States have different regulatory paths, but the direction is consistent: integrating stablecoins into a regulated financial infrastructure framework rather than allowing them to grow unchecked. This means that compliance capability will become the defining threshold for the next round of competition—not “who has the most products,” but “who achieves regulatory market access first.”

Conclusion

The global crypto market is undergoing a quiet but profound realignment of access. Hong Kong’s two-tier stablecoin framework, the EU’s licensing screening, and U.S. market structure legislation together outline the contours of a new era: compliance is no longer a cost, but the new era’s “entry permit.” For investors, understanding this paradigm shift is a crucial prerequisite for evaluating the long-term value of platforms and assets—especially asset security.