The era of fierce competition in digital finance is drawing to a close, and a new, rule-driven order is taking shape. In March 2026, global stablecoin regulation will witness a historic "triple play." On March 5th, the Hong Kong Monetary Authority announced that the first batch of fiat-backed stablecoin licenses was nearing issuance, with traditional financial institutions like HSBC and Standard Chartered reportedly leading the race. Three days later, the U.S. Office of the Comptroller of the Currency (OCC) released its GENIUS Act implementation proposal, establishing a comprehensive federal licensing and prudential regulatory framework for payment stablecoin issuers. Almost simultaneously, British fintech company BVNK obtained a crypto asset service provider license from the Malta Financial Services Authority, becoming one of the few institutions to simultaneously possess MiCA compliance and access to European payment networks. Meanwhile, across the Pacific, Chinese regulators also released a clear signal. On February 6th, the People's Bank of China and eight other departments jointly issued Document No. 42, for the first time including the tokenization of Real-World Assets (RWA) within the regulatory framework, clarifying a dual-track approach of "strict prohibition within China and registration overseas." In late March, the number of digital yuan operators was expanded to 12, bringing the total number of operators from 10 to 22. This marks the official entry of the digital yuan into its 2.0 era of institutionalized operation. These three seemingly independent events share a common trend: stablecoins are rapidly moving from the "gray area" of the crypto world into the spotlight of the mainstream financial system. According to RWA.xyz data, as of March 2026, the on-chain value of tokenized real-world assets, excluding stablecoins, has exceeded $25 billion, with stablecoins themselves becoming the core "bloodstream" of this value migration—USDC's monthly trading volume has reached $1.26 trillion, accounting for over 70% of total stablecoin activity. However, while capital can instantly cross national borders, regulation remains confined to national borders. What are the three regulatory schemes implemented almost simultaneously in the US, Hong Kong, and the EU competing for? What do their differences mean for companies? With the official launch of the digital yuan 2.0 era, how should Chinese companies choose their path in this regulatory race? This is an institutional race that will determine the global digital financial infrastructure landscape for the next decade. I. The United States: A Market Efficiency-First "Federal License" Model. On February 25, 2026, the U.S. Office of the Comptroller of the Currency released a proposal hundreds of pages long aimed at implementing the provisions of the GENIUS Act regarding the issuance of stablecoins for payments. The release of this proposal signifies that the United States has finally established clear federal-level rules for the private issuance of stablecoins, a "digital dollar."The GENIUS Act itself, signed into law on July 18, 2025, establishes a three-tiered issuance structure for payment stablecoins: first, subsidiaries of custodian institutions, approved by their primary federal regulators; second, federally qualified payment stablecoin issuers, directly approved by the OCC; and third, state-qualified payment stablecoin issuers, approved by state regulators. The underlying logic of this design is "diversified access"—it neither completely isolates stablecoin issuance from the traditional banking system nor confines it to a few institutions. The OCC's proposal further refines these rules. Regarding permitted activities, payment stablecoin issuers are limited to issuing and redeeming stablecoins, managing reserve assets, providing related custody services, and other activities that "directly support" these core business activities. The OCC acknowledges in its proposal that the term "directly support" has ambiguity and provides examples such as holding non-stablecoin crypto assets for testing distributed ledger technology or paying network transaction fees, which could be considered permitted "direct support" activities. This cautious "case-by-case clarification" approach reflects the pragmatic attitude of regulators towards technological innovation—defining boundaries while allowing room for exploration. The most noteworthy aspect is the implementation of the interest rate ban. While the GENIUS Act itself prohibits stablecoin issuers from paying interest or returns to holders, it does not explicitly prohibit issuers' affiliates or "related third parties" from providing returns indirectly funded by the issuer—a detail that has recently sparked heated debate in industry and Congress. The OCC's proposal addresses this by establishing a rebuttable presumption that such arrangements violate the interest rate ban. The proposal also clarifies that merchants independently offering stablecoin payment discounts, and profit sharing in white-label partnerships, are not covered by this presumption, as long as they do not involve passing on interest or returns to holders. The proposal further adds anti-circumvention clauses, treating any arrangement designed to circumvent the interest rate ban as a violation. Regarding reserve assets, the proposal requires issuers to maintain at least a 1:1 ratio of high-quality reserve assets. Acceptable reserve assets include US dollar cash, demand deposits at custodian institutions, short-term Treasury bills with maturities of 93 days or less, certain reverse repurchase agreements, and registered government money market funds. Notably, the proposal explicitly excludes stablecoins themselves and other crypto assets as eligible reserve assets. Reserve assets are measured at fair value, while stablecoins in circulation are measured at face value—meaning that even if stablecoins decouple in the secondary market, issuers must still maintain reserves equal to the face value of all circulating stablecoins. The redemption mechanism is designed to anticipate extreme scenarios.Generally, the redemption period does not exceed two business days. However, if the issuer receives redemption requests exceeding 10% of the total circulating supply within 24 hours, the redemption period can be extended to seven calendar days. This "automatic extension" mechanism is essentially a preventative measure against the risk of bank runs—giving issuers time to liquidate reserve assets and avoid systemic collapse due to short-term liquidity shortages. Regarding capital requirements, newly approved issuers must comply with the initial capital framework, including a minimum capital of at least $5 million during the initial regulatory phase. This requirement means that stablecoin issuance in the US is considered a regulated financial activity requiring substantial financial strength, rather than a lightweight, technology-driven product. Anti-money laundering compliance is directly linked to license status. Issuers must provide board-level certification confirming their maintenance of an anti-money laundering compliance framework that complies with applicable laws. Failure to submit a qualified certification may result in the revocation of issuance eligibility. This design, which traces compliance responsibility back to the board, aims to strengthen the importance placed on compliance by the governance level. In summary, the underlying logic of the US model is to "maintain the dollar's hegemony in the digital age." By lowering compliance thresholds to attract more issuers, prohibiting interest rates to prevent stablecoins from becoming deposit substitutes, and including global dollar stablecoins within the US regulatory sphere through foreign issuer provisions, the core objective of this set of rules is not to stifle innovation, but to bring innovation into a controllable and supervised framework, while consolidating the dollar's dominant position in the global digital payment system. II. Hong Kong: A "Compliance Extension" Model Connecting Chinese Assets. In Hong Kong, the pace of stablecoin regulation is equally rapid. In August 2025, the Stablecoin Ordinance officially came into effect, establishing the world's most stringent stablecoin regulatory framework. In February 2026, Chief Executive John Lee revealed at the Consensus Hong Kong conference that the first batch of stablecoin issuer licenses would be officially issued in March. Hong Kong Monetary Authority Chief Executive Eddie Yue disclosed approval details: a total of 36 license applications were received, but the number of licenses issued in the first round "will definitely not be large," with the primary goal being to ensure system stability rather than pursuing quantity. The stringency of the Hong Kong model is reflected in multiple dimensions. The minimum paid-up capital is HK$25 million, five times that of the United States; a 100% high-liquidity asset reserve requirement, with the reserve assets held in Hong Kong; 24/7 anti-money laundering monitoring; and the issuer must be a Hong Kong-registered entity with identifiable management and a physical office. These requirements combined create an extremely high barrier to entry—excluding small and medium-sized crypto companies and ensuring that only reputable and well-resourced traditional financial institutions can participate.This explains why the first batch of licensees were spearheaded by traditional banking giants like HSBC, Standard Chartered, and Bank of China (Hong Kong). Standard Chartered launched an integrated digital asset trading service for institutional clients as early as July 2025, with its UK branch already offering spot trading in Bitcoin and Ethereum. Through its subsidiaries Zodia Custody, Zodia Markets, and Libera, Standard Chartered provides digital asset custody, trading, and tokenization services respectively, building a full-chain capability from issuance to custody. The core design concept of Hong Kong's regulatory framework is to "integrate stablecoin issuance into the traditional financial regulatory framework." This means that stablecoins are considered an extension of "electronic money," rather than a completely new asset class. Issuers must comply with the same stringent anti-money laundering and counter-terrorism financing requirements as traditional financial institutions; reserve assets must be segregated and regularly disclosed; and licensed institutions are subject to continuous supervision by the Hong Kong Monetary Authority. The attitude towards foreign stablecoins is also clear. Eddie Yue emphasized that even stablecoins that comply with foreign regulations must obtain a Hong Kong license to conduct retail business in Hong Kong. Foreign stablecoins without a Hong Kong license are prohibited from being promoted to retail investors. This "local licensing" principle aims to firmly anchor the stablecoin ecosystem within Hong Kong's local regulatory system, preventing the transmission of risks from overseas. The deeper strategic intent of the Hong Kong model is to become a "strategic hub" connecting mainland Chinese assets with the global digital capital market. This was powerfully demonstrated on February 26, 2026. On that day, the Digital Currency Research Institute of the People's Bank of China and the Hong Kong Monetary Authority jointly launched a special test for cross-border RWA settlement of the digital RMB, successfully achieving real-time exchange and clearing between the digital RMB and Hong Kong-licensed stablecoins. The test focused on two major real-world scenarios: cross-border infrastructure and agricultural trade. In the traditional model, a cross-border payment requires multiple intermediary banks, taking approximately two hours and incurring high exchange costs. In the test, this process was compressed to three minutes, reducing exchange costs by more than 20%. The underlying technological breakthrough is "atomic swap"—locking the digital RMB and minting an equivalent amount of stablecoins are completed simultaneously, completely eliminating counterparty credit risk. This dual-track collaborative model of "digital yuan + Hong Kong stablecoin" forms a clear division of functions: the digital yuan serves as a "value anchor and compliance channel," ensuring the legal credit support and traceability of fund inflows and outflows; the Hong Kong compliant stablecoin, on the other hand, acts as a "liquidity bridge," connecting the global digital financial market with its 24/7 uninterrupted trading capabilities. Fan Wenzhong, vice president of the Beijing Academy of Social Sciences, defines it as a new "public-private partnership" architecture—combining the security and compliance of sovereign currency with the efficiency and flexibility of market-driven mechanisms.For mainland enterprises, this collaborative model signifies the formation of a clear and compliant path for RWA (Rich Asset Transaction) to expand overseas. Whether it's the revenue rights of cross-border infrastructure projects, supply chain finance assets in agricultural trade, or green carbon sinks and commercial real estate revenue rights, all can utilize the digital yuan as a compliant entry point, achieving tokenization, global circulation, and circulation through the Hong Kong stablecoin ecosystem. III. The EU: A "Comprehensive and Prudent" Model Under Prioritized by Regulations. Across the Atlantic, the EU chose a different path. In June 2025, the European Banking Authority issued a "no-action letter," clarifying the interaction between MiCA (Crypto Asset Market Regulation) and PSD2 (Payment Services Directive II). This seemingly technical document reveals a significant regulatory challenge: from March 2, 2026, crypto asset service providers offering electronic currency token custody and transfer services may need to hold both a MiCA crypto license and a PSD2 payment services license. This means that the same business activity will face two sets of regulatory frameworks, two sets of capital requirements, and two sets of compliance costs. MiCA requires crypto asset service providers to have a minimum capital of €125,000, and the PSD2 payment service license also requires €125,000—together totaling €250,000, or nearly $290,000. Adding double reporting and double regulatory fees, compliance costs nearly double. Patrick Hansen, Circle's EU policy head, warned on social media that failure to resolve the conflict between MiCA and PSD2 would severely damage the EU's digital finance competitiveness. He pointed out that this double-licensing trap violates the EU's principles of proportionality, legal clarity, and consistency, and runs counter to the EU's efforts to simplify regulation and enhance competitiveness. The root of this conflict lies in MiCA's design logic: it attempts to establish a unified rulebook for crypto assets, but overlaps with existing payment service directives in the custody and transfer of electronic currency tokens. The European Banking Authority acknowledges that all financial activities should be governed by one law, but currently MiCA and PSD2 simultaneously regulate stablecoin custody and transfer services. The European Banking Authority (EBSA) has proposed two legislative amendments: one is to revise the MiCA to incorporate the relevant payment services terms in PSD2, establishing a single framework for e-money token activities; the other is to amend the upcoming PSD3 and payment services regulations, exempting MiCA-licensed institutions from the separate payment services licensing requirements for e-money token custody and transfers. The PSD3 legislative process is still underway and is expected to be passed after 2025—this provides policymakers with a limited window to add specific exemptions before the March 2026 deadline.The essence of the EU model is "institutional first"—establishing a rule system covering the entire industry chain before the industry is fully mature. The advantage of this approach is strong regulatory certainty; once compliant, it can be applied in all 27 countries. The disadvantage is high compliance costs and long adjustment periods, potentially stifling innovation in the early stages. However, the EU's goals extend beyond regulation. The case of BVNK might illustrate this point. Founded in 2021, this stablecoin payment infrastructure company, headquartered in London, holds electronic money institution licenses in the UK and EU, as well as money transmission licenses in several US states. By 2025, BVNK's transaction processing volume exceeded $20 billion, with operations covering more than 130 countries and regions. On March 17, Mastercard announced its acquisition of BVNK for $1.8 billion, Mastercard's largest acquisition in the digital asset field. BVNK's appeal lies in its full-stack enterprise-level solutions—API interfaces, wallet management, compliance risk control, and liquidity management—lowering the barrier for enterprises to access stablecoins. It supports the sending, receiving, exchanging, and storing stablecoins on all major blockchains. Fiat currency deposits and withdrawals support USD, EUR, and GBP. Its main service scenarios include cross-border B2B settlement, cross-border payroll payments, and enterprise stablecoin issuance. This "compliance-first, technology-driven" model is precisely what the EU regulatory framework aims to cultivate—encouraging sustainable innovation within clearly defined boundaries. Mastercard's acquisition also confirms the strategic bet of traditional financial giants on stablecoin infrastructure—Strip acquired stablecoin company Bridge for $1.1 billion in 2024, Visa strategically invested in BVNK, and traditional payment giants are all increasing their investment. IV. Convergence Amidst Divergence: The Consensus of Five Core Principles Observing the three regulatory frameworks side-by-side reveals obvious differences. The US path prioritizes "market efficiency," allowing diverse issuers, but at the cost of a minimum capital of $5 million and strict interest rate restrictions. Hong Kong's path is "traditional financial extension," strictly limiting issuers to licensed financial institutions with a minimum capital of HK$25 million, and requiring reserve assets to be held in Hong Kong. The EU's approach is "comprehensive prudential regulation," with a dual capital requirement of €250,000 and complex overlap between MiCA and PSD2. However, beneath these differences, five core principles are gaining global consensus. First is the 1:1 reserve principle. All three frameworks require stablecoin issuers to hold reserve assets equivalent to the circulating supply, ensuring redemption at any time. Second is the reserve segregation principle. All require that reserve assets be segregated from the issuer's own assets to prevent misappropriation. Third is the prohibition of interest payments.All three frameworks prohibit stablecoin issuers from paying interest or returns to holders, clearly defining stablecoins as "payment instruments" rather than "investment products." Fourth is the principle of anti-money laundering compliance, requiring strict KYC, transaction records, and reporting obligations. Fifth is the principle of consumer protection, protecting holders' interests through mechanisms such as reserve requirements, information disclosure, and redemption rights. This pattern of "converging principles but differentiated details" essentially reflects a competition among jurisdictions for "rule-making power"—whoever can provide lower compliance costs and more flexible operating space for businesses without sacrificing financial stability will gain a competitive advantage in the next decade of digital finance. For Chinese companies, understanding this divergence and convergence is itself a strategic capability. In March 2026, when the stablecoin regulatory frameworks of the three major economies are almost simultaneously implemented, we are witnessing a historic moment: the "Warring States" era of digital finance is ending, and a "new order" dominated by rules is taking shape. The United States' choice is "efficiency first"—allowing market forces to drive innovation and maintaining its advantage through dollar hegemony. Hong Kong's choice is "compliance extension"—backing digital assets with the prudence of traditional finance, becoming a bridge connecting China and the world. The EU's choice is "institutional first"—drawing boundaries with the highest standards, attempting to become a global rule-maker. There is no absolute right or wrong among these three choices, only differences in adaptability to different resource endowments and strategic goals. But for Chinese companies, understanding this difference is itself a strategic capability—between the institutionalized operation of the digital yuan 2.0 and the compliant channel of Hong Kong's stablecoin license, a "fast track" connecting high-quality mainland assets with global digital capital has been paved. As Mastercard's acquisition of BVNK reveals, stablecoins are no longer a niche crypto experiment, but the cornerstone of the next generation of global payment networks. Whoever finds their own path in the regulatory race will seize the initiative in the wave of digital civilization. And the starting point of this path is the understanding of the rules; the end point is the shaping of the rules. [RWA Research Institute]