The image above is from the Hong Kong Monetary Authority's official website. The delayed issuance of stablecoin licenses in Hong Kong has typically elicited a "delayed" reaction from the market. However, in my view, the real issue worth discussing isn't just "why the delay," but rather that it underscores a more practical problem: Hong Kong maintains a typically cautious approach to crypto-related licenses. If stablecoins, a matter repeatedly foreshadowed by the authorities and with a relatively clear legislative timeline, haven't been implemented as smoothly as the market expected, then there's even less reason for many payment institutions to harbor illusions that VA dealing (virtual asset trading services) and VA custody (virtual asset custody services) licenses will arrive soon. For those preparing to engage in crypto payments, stablecoin transactions, and on-chain clearing and settlement, the biggest danger right now isn't the high cost of licenses or the difficulty of compliance, but rather misjudging the timing of business launches. Without licenses, businesses are hesitant to operate; yet the market window is closing. This easily leads to a situation where everything is prepared, but the timing is missed. The Hong Kong stablecoin license issue is significant not only because of its inherent importance, but also because many see it as a signal. The reason is simple. Stablecoins are not a marginal issue in Hong Kong, but rather one of the core components of the Web3 regulatory landscape over the past two years. They relate to payments, fund flows, and the future development of on-chain financial infrastructure. If these licenses could be issued smoothly and clearly, the market would naturally conclude that Hong Kong's regulation of crypto finance has truly entered the implementation phase. However, the problem is that this light hasn't shone as expected. The Hong Kong Monetary Authority (HKMA) is more likely to emphasize prudence, stability, the need for thorough preparation, and ensuring the quality of the implementation. This explanation is entirely understandable. Once stablecoins are formally included in licensing regulations, regulators will not only consider "whether they can be issued," but also a whole set of issues including reserve assets, redemption mechanisms, fund segregation, anti-money laundering (AML), and systemic risk transmission. In other words, the slow issuance of licenses is not necessarily due to a lack of preparedness, but may also be because regulators are unwilling to leave any ambiguity at crucial junctures. But the market won't just look at explanations; it will also look at the pace. If the process is delayed, people will inevitably start speculating: are the applicants not ready yet? Is the list not finalized? Are the regulators still weighing the pros and cons? Is it waiting for higher-level policy coordination? Which of these speculations is true is perhaps not important.Importantly, this will cause the market to recalibrate its perception: Hong Kong will not rush into issuing crypto-related licenses. To view this delay merely as a minor hiccup in the stablecoin licensing process is a superficial understanding. What's truly worth understanding is Hong Kong's consistent approach to crypto regulation: not that it won't do it, but that it does it very slowly, very steadily, and very sequentially. Many people have a biased view of Hong Kong, believing that its mature financial market, transparent systems, and high degree of internationalization mean that once the direction is set, the subsequent licenses and regulations will be implemented quickly. This is not the reality. Hong Kong has never adopted a "preemptive regulation" approach, but rather a "confirmation-based regulation," in matters involving financial infrastructure, payment systems, public funds, and cross-border capital flows. This means that it prefers to formally launch its licensing system only after the market has seen the direction, the risk boundaries are roughly clear, and the policy consequences can be controlled. Stablecoins are a prime example. Hong Kong has long recognized their direction; the regulations are indeed progressing; and the policy stance has consistently been positive. Yet, when it comes to actually issuing licenses, the pace will still be slow. Why? Because once licenses are issued, it's not just about giving a few companies a piece of paper; it's equivalent to regulators officially confirming that a new financial arrangement can be put into operation. This means that any subsequent licenses related to virtual asset payments, trading, custody, and clearing will likely follow the same path. It's not about how anxious the market is, or how much the industry anticipates, but whether the regulators themselves believe it's time to let it through. Currently, many payment institutions, overseas projects, and stablecoin payment teams are eyeing VA dealing and VA custody. The reason is not hard to understand. For many crypto payment businesses, these two types of licenses are indeed highly compatible. Especially those teams hoping to handle stablecoin payments, merchant settlements, on-chain fund aggregation, and wallet and clearing connections naturally feel that as long as Hong Kong issues these two licenses, their business will have a good foothold. The problem lies here. "Compatibility" does not mean "soon to be available." If even the issuance of stablecoin licenses, a matter that has been on the table for a long time and whose institutional framework is relatively mature, is still being delayed, how can VA dealing and VA custody, which are more focused on subsequent and supporting layers, possibly be issued faster than stablecoins? From a regulatory perspective, these two types of licenses are unlikely to precede stablecoins in the regulatory order.The reason is simple: stablecoins are about the underlying payment and funding units, and are closer to "infrastructure" in some ways; while VA dealing and VA custody are more about business licenses related to virtual asset services. Although they are important, regulation is usually implemented after a more comprehensive main framework. So if a team is still writing a business plan like, "Wait until Hong Kong's VA dealing/VA custody is released, then we'll launch immediately," that kind of pacing is very risky. It's not that these two licenses won't come, but that you may not be able to afford to wait. Many people doing compliance planning are used to asking, "What is the ideal license?" This question is correct, but incomplete. The more appropriate question should be, "Which license is most suitable for me to get the business up and running at this stage?" These are two completely different questions. If you are doing crypto payments, stablecoin payments, cross-border settlements, or on-chain clearing related businesses, then in the long run, Hong Kong is certainly worth investing in. Its brand effect, institutional credibility, and ability to radiate to the Asian market are all very strong. The problem is, being worth investing in in the long term does not mean it is suitable to put all your eggs in one basket for business launch in the short term. Businesses have a window of opportunity. Especially in the payment business, the market won't wait for you just because you get a license. Customers won't wait, partners won't wait, and competitors certainly won't wait. While you're still desperately waiting for a future license, others may already be using licenses from other jurisdictions to establish merchant networks, channels, wallets, OTC (over-the-counter) transactions, and clearing and settlement processes. By the time you finally get a "theoretically more perfect" license, the market landscape may have already been dominated by others. Therefore, from a business perspective, the most dangerous compliance strategy is not "choosing the wrong license," but rather waiting for a license whose arrival date is uncertain and remaining inactive for an extended period. This will directly hinder business development, and in the end, it won't lead to more stable compliance, but rather to the loss of market share. If your current goal is to launch your crypto payment business as quickly as possible, rather than simply creating a Hong Kong license story, then instead of waiting for VA dealing and VA custody, you should seriously consider several more realistic paths: US MSB, US MTL, Canadian MSB, Australian DCE, etc. These jurisdictions each have their own problems and costs; there is no such thing as a "universal license." But they share a common advantage: at least they allow you to get started under clearly defined rules. For many payment businesses, the most important thing is not to build the most beautiful regulatory framework in the world from the beginning, but to find a starting point that can be legally launched, sustainably iterated, and connected with customers and partners.Once the business is up and running, subsequent expansion into Hong Kong, Europe, the Middle East, or multi-jurisdictional structures will be natural upgrades. Conversely, if the first step is delayed, even the most impressive license designs may remain only on PowerPoint slides. Therefore, the realistic strategy is usually not to "just wait for Hong Kong," but rather: continue to monitor Hong Kong, but don't bet solely on Hong Kong to launch the business. What's truly worth fighting for isn't the license yet to be issued, but market positioning. Ultimately, many teams are currently anxious not about the license itself, but about missing the next window of opportunity for crypto payments. This anxiety is valid. However, the solution isn't necessarily to continue waiting. The delay in stablecoin licensing has already given the market a very clear reminder: Hong Kong will continue, but it won't accelerate just because the market is impatient. Therefore, a truly mature strategy shouldn't be passive waiting, but proactive positioning. Whoever establishes the licensing pathway, funding pathway, cooperation pathway, and customer pathway first has a greater chance of securing the market. When the subsequent Hong Kong licenses are finally issued, you'll be able to acquire licenses, upgrade your structure, and scale up, rather than starting from scratch and catching up again. So if you're currently looking into crypto payments, stablecoin transactions, or Web3 cross-border settlements, my advice is clear: don't pin all your hopes on Hong Kong's next license. Since stablecoins have already experienced delays, there's even less reason to wait for VA dealing and VA custody. What you should really be doing isn't guessing when they'll be released, but finding a legal jurisdiction and structure that allows your business to get started as quickly as possible. Recommended course: The arrival of the AI payment era isn't a problem of a single link—from regulatory characterization and licensing pathways to AML system construction, off-chain and on-chain risk control, and compliance implementation in real-world business scenarios, every link directly impacts whether AI can truly "emerge." Based on Mankiw's long-term expertise in Web3 legal practice, we've launched the "Crypto Payment Compliance Practical Closed-Door Workshop (Shenzhen)". April 18-19, Shenzhen, limited small class, multiple perspectives on "law + compliance + security". The speakers are from Mankiw LLP, Chainalysis, Beosin, KUN昆, COBO, and practical experience leaders from licensed institutions. The content covers: regulatory pathways and licensing systems, compliance governance frameworks, anti-money laundering practices, on-chain security, and firsthand experience from licensed institutions. If you are developing crypto payment-related products or considering the compliance path of AI agents in payment scenarios, we recommend scanning the QR code for consultation. [Shao Jiadian]