Do not treat "support" as a single feature
Displaying balances in a wallet, receiving incoming transfers, safekeeping, permitting purchases, automatic conversion and settlement to merchants involve different activities. Platforms should first clearly state, for each stablecoin, the extent to which it is supported, and then verify local rules. In particular, the fact that an asset can be transferred on a blockchain must not be taken to mean that it can be sold to all customers in all countries, or that it can always be redeemed for fiat currency.
Hong Kong and the EU illustrate different review dimensions
The Hong Kong Government's official response concerning the Stablecoins Ordinance states that the provision of specified stablecoins involves permitted providers and restrictions on customer categories, and that the conditions for offering to retail customers differ from those for offering to professional investors. Accordingly, both the provider's eligibility and the stablecoin to be offered must be verified, rather than merely checking whether the platform itself holds a particular financial licence. The specific issuance and licensing status should be checked against the HKMA register.
Article 48 of the EU's MiCA sets requirements for the public offering and admission to trading of e-money tokens. It should also be noted that ESMA's supervisory opinion published on 8 October 2026 requires competent authorities to push CASPs to cease providing services to EU clients involving stablecoins that do not meet MiCA requirements, including custody and transfer; existing holdings may exit only under strict, time-limited and supervised arrangements. The opinion requires that remaining legacy exposures identified by competent authorities be remediated as soon as possible and no later than three months after publication of the opinion; this is not a uniform grace period for new business. Therefore, the 2025 statement that "mere custody and transfer may still be possible" can no longer be relied upon as a basis for continuing operations. This is a current supervisory opinion and should not be mischaracterised as a newly amended statutory provision.
Even for the same coin name, the network and rights must also be verified
Suppose a merchant requires final receipt in fiat currency, while the payer wishes to use stablecoins on two different networks. Even if the interface prices are all close to one US dollar, the platform still needs to confirm whether what is received is the issuer's native token or a cross-chain wrapped asset, whether the conversion counterparty will accept it, and how funds are returned if settlement fails. The technical team should not whitelist tokens based solely on ticker symbols; at a minimum, the network and contract identifiers should be confirmed.
Issuer terms, redemption eligibility, freeze arrangements, market liquidity and channel support may also differ. The platform need not assume all issuer risks on the customer's behalf, but it should state whether what it undertakes is to receive the coin, to convert it, or to settle a fixed amount, and should design notification and exit procedures for suspending receipt or delisting.
Make the token whitelist a continuously maintained record
It is recommended that the first batch include only assets whose legal classification and complete settlement path can be explained, and that the approver, source and review date be retained. Adding a new network, a change of issuer, an adjustment of regulatory restrictions or an upstream cessation of conversion should all trigger a re-review. The external token list should preferably also display applicable regions and functional restrictions, so that users do not discover only after completing a transfer that they can only hold the asset and cannot sell or withdraw it.
Recommended actions
- Establish a matrix of tokens, issuers, networks, contract addresses and permitted functions.
- Verify separately the conditions applicable to retail and professional clients, public sales and mere transfers.
- Test the asset exit process in the event of redemption channels, refunds and suspension of support.
- Update the whitelist in line with official registrations and channel changes, and do not treat licensing conclusions as permanently fixed.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- LCQ10：Regulation of digital assets，2025-09-10 — Government of the Hong Kong Special Administrative Region / Financial Services and the Treasury Bureau
- Register of Licensees under the Stablecoins Ordinance — Hong Kong Monetary Authority (HKMA)
- MiCA Article 48: Public offers and admission to trading of e-money tokens — EU regulations / ESMA official rulebook
- Opinion on non-MiCA-compliant ARTs and EMTs, 2026-10-08, paragraphs 7, 9, 12 and 21–27 — ESMA
