Strengthening Hong Kong's Lead in Financial Technology through New Stablecoin Regulations
In the dynamic world of fintech, two leading Asian hubs, Hong Kong and Singapore, have taken significant strides in establishing comprehensive regulatory frameworks for stablecoins. Both jurisdictions aim to foster a secure and innovative environment while preserving financial integrity.
Hong Kong's Stablecoins Bill, enacted in May 2025, mandates that anyone issuing fiat-referenced stablecoins, including those pegged to the Hong Kong dollar issued outside Hong Kong, must obtain a license from the Hong Kong Monetary Authority (HKMA). The ordinance covers stablecoins operating on distributed ledgers, ensuring they maintain a stable value with respect to fiat currencies.
In contrast, Singapore's approach, shaped by the Monetary Authority of Singapore (MAS), requires stablecoin issuers to comply with licensing under the Payment Services Act (PSA), which has been in force since 2020. The PSA framework enforces AML/CFT, capital, operational, and cybersecurity standards.
Both Hong Kong and Singapore's regulations emphasise stringent compliance, similar to traditional financial institutions. Hong Kong's Bill requires full backing of stablecoins, segregation of assets, clear redemption rights at par value, and prohibitions against unlicensed marketing or issuance to retail investors. Singapore's regime requires stablecoin issuers to adhere to customer due diligence, reporting suspicious transactions, capital requirements, safeguarding client monies, and operational risk management.
Hong Kong's regulatory approach is designed to be fair, yet new and comprehensive, with detailed supervisory and AML/CFT guidelines. This expansion of Hong Kong's digital asset regulatory perimeter is aimed at securing trustworthy stablecoin issuance under strict regulatory oversight, complementing broader virtual asset regulations and enhancing cross-border fintech potential.
Singapore's regime, by contrast, is earlier and better established, providing tested regulatory clarity and enabling significant fintech growth. The clear regulatory certainty provided by MAS has been instrumental in attracting global stablecoin issuers and fintech firms, thereby promoting growth and adoption in digital payments and decentralised finance sectors.
The regulatory climate in both Hong Kong and Singapore is a major growth factor for fintech firms worldwide. Both jurisdictions are correlated with international frameworks such as EU MiCA, and both have tools to manage compliance, such as Hong Kong's sandbox, regtech, and SlowMist.
Hong Kong's licensing practice for stablecoins is more prescriptive compared to Singapore, which allows innovation using the present PSA with a walk-out for consistent coin licensing. Ant, Standard Chartered, and Animoca have requested independent HKD stablecoin licenses in Hong Kong. The attractive aspect of Hong Kong's stablecoin regulation for fintech payment organisations is global.
In August 2023, Singapore's MAS completed its stablecoin regime under the Payment Services Act. The stable coins governed by Singapore's regime are SGD- and G10- pegged. The annual increase in fintech jobs in Hong Kong is currently 15 percent, and fintech employment in Hong Kong has increased by 15 percent every year.
In summary, Hong Kong's 2025 Stablecoins Bill introduces a newly codified, detailed licensing and compliance structure aiming to secure trustworthy stablecoin issuance under strict regulatory oversight, complementing broader virtual asset regulations and enhancing cross-border fintech potential. Singapore’s regime, by contrast, is earlier and better established, providing tested regulatory clarity and enabling significant fintech growth. Both jurisdictions emphasise financial integrity, but Hong Kong’s newer regime may initially pose more stringent entry requirements as the market adapts.
In the ongoing development of the stablecoin market, Hong Kong's Stablecoins Bill, enacted in May 2025, imposes extensive licensing and compliance requirements to ensure trustworthy stablecoin issuance, mirroring traditional financial institutions. On the other hand, Singapore's earlier and more established regulatory framework, defined by the Monetary Authority of Singapore (MAS), offers fintech businesses a tested regulatory clarity that fosters growth and adoption in digital payments and decentralized finance sectors.
