Global Crypto Regulation "Closing the Net": Hong Kong, EU, US Simultaneously Take Action, Is the Compliance Window Closing?

Author: EXIO Research Institute

Global virtual asset regulation is transitioning from "rule-setting" to an "elimination round." Hong Kong's SFC has just delineated new boundaries for stablecoin services, the EU's MiCA transition period is about to end, and the US CLARITY Act passed a key Senate committee. The three major markets have coincidentally entered an "enforcement screening period" — compliant players get their entry ticket, while latecomers may be shut out.

I. Three Signals, One Direction

2024-2025 was a "legislation-intensive period" for crypto regulation: Hong Kong's Stablecoin Ordinance took effect [1], the EU's MiCA became fully applicable [2], and the US passed its first federal stablecoin law, the GENIUS Act [3]. By 2026, the rules are set, and the question becomes "who can comply."

Over the past two weeks, three independent regulatory developments occurred simultaneously, pointing to the same conclusion: major global markets are not "opening up" to crypto but are undergoing market restructuring based on licensing, products, custody, and client classification.

II. Hong Kong: "Two-tiered Regulation" for Stablecoins Officially Lands

II.1 What is a Relevant Stablecoin?

In its May 27 circular, the SFC defined the regulatory boundaries for Relevant Stablecoin services for licensed Virtual Asset Trading Platforms (VATPs) and licensed corporations [4]. To qualify, a stablecoin must meet two conditions: it must be a "specified stablecoin" under the Stablecoin Ordinance; and it must be issued and authorized by an HKMA-licensed issuer.

On April 10, the HKMA issued the first batch of stablecoin issuer licenses to HSBC and Standard Chartered [6], creating compliant assets in the market. This marks the formation of Hong Kong's "dual-track structure":HKMA regulates issuance, SFC regulates trading and distribution.

II.2 Relaxation and Constraints Coexist

The SFC's core message is differential treatment — Relevant Stablecoins have risk characteristics different from speculative assets like Bitcoin, being closer to payment instruments, therefore some rules can be relaxed [7]:

However, "differential" does not mean "relaxed." If platforms solicit or recommend Relevant Stablecoins, they must still adhere to suitability requirements and disclose stabilization mechanisms and redemption arrangements [4].

II.3 Hong Kong's "Hidden Agenda"

This circular is not an isolated action. On April 20, the Hong Kong Securities and Futures Commission announced a new regulatory framework to pilot secondary market trading of tokenized SFC-authorized investment products (tokenized products) in Hong Kong, aiming to promote local digital asset trading activities and support ecosystem development in the long term [8]. Three policy threads weave into a clear path: stablecoins as settlement infrastructure, tokenized securities as investment tools, VATPs as compliant distribution + custody + trading channels — This forms a complete virtual asset regulatory loop.

III. EU: MiCA "Final Exam" Countdown

If Hong Kong represents "fine-grained layering," the EU represents "compliance filtering." ESMA confirmed on April 17 that the MiCA transition period will end on July 1 [2]. Thereafter, providing services to EU clients without a CASP license will be illegal.

As of early May, only 210 authorized CASPs existed across 23 EU countries [9], with 86% having activated the passporting mechanism for cross-border services. This number is just the tip of the iceberg compared to the total number of VASPs previously registered in the EU (before MiCA, each member state had its own VASP registration system, with a cumulative total of 3,000–3,200 VASPs across the EU). Progress varies greatly by country. Germany leads with 53 authorized entities [9], known for strict approvals and high capital requirements; Poland's implementation bill has been vetoed twice by the president [10], risking a legal vacuum post-July 1. The median time from application to license has reached 6 to 9 months [9]; applicants in the latter half of this year might have to wait until 2027 to operate legally.

IV. US: CLARITY Act's Legislative Sprint

US crypto regulation is shifting from "enforcement-driven" to "rules-driven." On May 14, the Senate Banking Committee passed the CLARITY Act with a 15 to 9 vote [5], marking the first federal legislation attempting to clarify the jurisdictional division between the SEC and CFTC.

The bill's core content includes: SEC regulation of digital assets with investment contract characteristics; CFTC regulation of spot digital commodities; establishment of registration rules for trading platforms and custodians; and incorporation of a stablecoin regulatory framework [11].

The fiercest debate centered on stablecoin yields. The final compromise: prohibit "passive yields" based on idle balances, but allow "activity rewards" tied to substantive activities like payments and lending [12]. This draws a middle line between banking stability and crypto innovation.

However, there is still a distance to becoming law. Full Senate passage requires 60 votes to overcome a filibuster [13], and Polymarket predicts a ~73% probability of enactment by 2026 [5].

V. Stablecoins Becoming "Financial Infrastructure"

The deeper context for this synchronized regulatory push across three jurisdictions is the fundamental shift in the role of stablecoins. In 2025, global stablecoin payment volume reached 33 trillion USD [14], comparable to the annual total processing volume of Visa and Mastercard; total market capitalization exceeded $3.2 trillion [3]. US Treasury Secretary Scott Bessent predicts it may reach $3.7 trillion by 2030 [3].

Use cases are also expanding: about 67% related to DeFi and trading, 15% for cross-border remittances, 10% as inflation hedges, and 5% for merchant payments [15]. Stablecoins are no longer just "bridging currencies" for crypto users but the settlement layer between traditional and digital finance.

While the regulatory paths in Hong Kong, the EU, and the US differ, the direction is consistent: bringing stablecoins into the regulated financial infrastructure system, rather than letting them grow "wild." This means compliance capability will become the watershed for the next round of competition — not "who has the most products," but "who completes compliant market access first."

Conclusion

The global crypto market is undergoing a silent yet profound "realignment of access." Hong Kong's two-tiered stablecoin framework, the EU's license filtering, and the US's market structure legislation together sketch the contours of a new era: Compliance is no longer a cost but the "admission permit" for the new era. For investors, understanding this paradigm shift will be a key prerequisite for assessing the long-term value (especially asset security) of platforms and assets.