Author: Portal Labs
On May 21, 2025, the Hong Kong Legislative Council passed the Stablecoin Bill, paving the way for the compliant issuance of stablecoins in Hong Kong. Subsequently, the Web3 market, especially the Chinese (Chinese) market, has set its sights on Internet giants that are participating in the sandbox program.
Since June, news about stablecoins, led by JD.com, has ignited domestic discussions. On June 17, according to Sina Finance, JD.com's Liu Qiangdong said that JD.com hopes to apply for stablecoin licenses in all major currency countries in the world to achieve exchange between global companies. On the 18th, Liu Peng, CEO of JD.com CoinChain Technology, said in an exclusive interview with Bloomberg Businessweek that the Hong Kong dollar and multi-currency stablecoins have been successfully tested in the Hong Kong Monetary Authority's "Sandbox" and are expected to be officially licensed and launched in early Q4 this year.
As always, whenever there is good news in Hong Kong, there will always be a lot of "domestic open signals" in China, and this time is obviously no exception. However, there can be expectations, but as a practitioner, Portal Labs still believes that we should abandon the appearance and look at the underlying logic.
So, why can JD.com, as a Chinese Internet giant, issue stablecoins? That must be because its underlying architecture meets the conditions for the issuance of stablecoins in Hong Kong. (That's right, not China, only Hong Kong)
From the composition of the project itself, its compliance path, initiator and business positioning are extremely clear.
JD.com Stablecoin Project Entity
The reason why JD.com can promote the stablecoin project in Hong Kong is that its underlying architecture must meet the basic requirements of the Hong Kong Stablecoin Ordinance for the "issuer entity". According to the Hong Kong Stablecoin Bill, issuers must:
be incorporated in Hong Kong;
have a paid-in capital of more than HK$25 million;
have stable financial and risk control capabilities;
be able to maintain 100% high-quality, high-liquidity asset reserves;
accept audit supervision and establish a clear redemption mechanism.
The establishment of JINGDONG Coinlink Technology Hong Kong Limited is precisely to meet the institutional requirements of this regulatory container. The company is registered in Hong Kong, with JD Technology Group as its shareholder. It has independent legal status and can be isolated from its parent company in terms of finance, assets and business. This structural arrangement not only allows it to meet the basic qualifications of an issuer, but also ensures that its business operations can independently respond to compliance during sandbox testing, risk assessment and formal licensing processes.
From a compliance perspective, why doesn't JD Group apply for a license directly? The reason is that JD, as a large mainland group, cannot directly become a "locally registered issuer" under the Hong Kong Stablecoin Ordinance. By establishing a wholly-owned subsidiary, it can not only achieve unified coordination of the group in technology and resources, but also accept supervision by the Hong Kong Monetary Authority as an independent entity, and complete the legal relationship between the issuer and reserve custody and compliance reporting.
This arrangement is essentially no different from the logic of Circle's establishment of Circle Internet Financial LLC as the issuer of USDC in the United States: the "issuer" must have an independent and auditable legal identity to accept local supervision and business penetration requirements, rather than relying on the overall qualifications of the parent company for compensation.
In other words, JD.com is not qualified to participate in the stablecoin sandbox because it is "in Hong Kong and meets Hong Kong regulatory requirements" rather than "in China". This is the first principle for the establishment of the project and a prerequisite for judging whether it can be replicated.
JD.com Stablecoin Project Design
Meeting the subject qualifications set by regulators is only the starting point for the compliant issuance of stablecoins. The key to the real "ability to issue" lies in the design capability - that is, whether an institution can build a regulated, auditable and redeemable stablecoin issuance and operation system.
This capability is often reflected in three levels: governance structure, financial capacity and infrastructure.
Governance structure: institutional arrangements from group separation to independent risk control
According to the Hong Kong Stablecoin Bill, issuers must meet a series of regulatory requirements at the governance level: including the establishment of internal audit, risk control, and information disclosure mechanisms, and clarifying the boundaries of directors' responsibilities and statutory regulatory obligations. The purpose is to regard issuers as quasi-financial institutions and accept review with a penetrable governance structure.
The key to JD CoinChain Technology becoming a sandbox pilot institution is not that its parent company is an Internet giant, but that it has its own governance structure of a "quasi-financial issuer". From public information, the company has an independent director structure in its statutory documents and cooperates with local Hong Kong laws to conduct financial audits and daily regulatory submissions. This means that its issuance behavior does not rely on the guarantee or reputation of the parent group, but rather assumes statutory responsibilities with its "own governance system".
Fund structure: Behind the compliance reserve mechanism and high credit threshold
Hong Kong regulators have extremely strict requirements for stablecoin reserves: not only does it need to be 100% anchored, it must also be composed of "high-quality and highly liquid assets", such as Hong Kong dollars, bank deposits, short-term government bonds, etc., and a special custody account must be set up for asset isolation and auditing.
This threshold naturally excludes a large number of small and medium-sized crypto projects, and only companies with sufficient funds and strong financial risk control capabilities can be competent. As a large enterprise with abundant daily cash flow, JD.com has the ability to set up an equal reserve account and cooperate with financial institutions for asset custody. It is understood that it has established a stablecoin exchange and redemption mechanism during the sandbox test, and promised that users can redeem legal currency "at par and without additional fees", which is consistent with the basic requirements in the draft.
More importantly, its stablecoin is not anchored to virtual assets, but is collateralized by Hong Kong dollars or multiple currencies, further enhancing regulatory acceptability. The risk exposure behind this type of reserve mechanism is relatively controllable, which is clearly different from the solutions based on "algorithms" or "on-chain collateral" in the crypto market.
Infrastructure capabilities: whether it can independently complete clearing, verification and compliance
The issuance of stablecoins is not a technological innovation, but a reconstruction of "compliant financial facilities". In the regulatory framework of the HKMA, issuers must have clearing and settlement systems, identity verification processes, KYC/AML mechanisms, system audits and emergency response capabilities. In short, stablecoins are not issued by writing a smart contract and hanging a front end, but a set of system engineering.
In this regard, JD.com has accumulated rich experience in B-side scenarios such as e-commerce payment, consumer finance, and cross-border settlement. Its subsidiary JD Digits has previously built multiple payment and account systems and has the ability to operate millions of financial users. This provides a natural infrastructure soil for stablecoins. In other words, what JD issued is not a "chain token", but a "financial instrument" with a real convertible mechanism.
In contrast, many crypto-native projects, even if they have overseas licenses, find it difficult to establish supporting infrastructure in actual operations, and thus fail to meet the core requirements of Hong Kong regulators for "full process control of the stablecoin system."
JD Stablecoin Business Scenarios
The core demand of supervision is not only "can you issue it", but also "can you operate within the regulatory vision after you issue it." From this perspective, the use scenario of stablecoins is not only the logic of business expansion, but also a bridge of regulatory trust.
At this point, JD.com's stablecoin project is clearly positioned as "serving cross-border exchange and corporate payments", and the entry point is the existing business system in reality, rather than rebuilding an on-chain ecosystem. This approach, which starts from the "extension of the existing system", coincides with the regulatory tone of "combining with the real economy" emphasized by the Hong Kong Monetary Authority.
Corporate payments: not C-end wallets, but B-end settlement tools
JD.com's stablecoin project is a B2B-level settlement tool. According to CEO Liu Peng's statement in an exclusive interview with Bloomberg, its goal is to provide corporate customers with a more efficient means of exchange between legal currencies in different countries, reducing the traditional cross-border settlement transit links and exchange loss costs.
This means that JD.com's stablecoin first undertakes the function of "improving corporate exchange efficiency", and its circulation path is naturally closed, and users can clearly control it. For regulators, this high-certainty scenario is highly acceptable: it does not involve speculation, is not aimed at retail investors, has controllable risks, and has clear uses - it is the ideal "financial technology enhancement tool" rather than a "quasi-financial asset."
Off-chain connection: connecting with existing supply chain finance and cross-border settlement closed loop
JD.com has already laid out supply chain finance, cross-border clearing and settlement, warehousing and fulfillment systems in its cross-border business. The embedding of stablecoins is actually a natural extension of the "on-chain voucher + off-chain fulfillment" logic. Compared with the path of "issuing coins first and then looking for scenarios" of most Web3 projects on the market, JD.com itself has a demand side and can naturally generate stablecoin usage scenarios.
In other words, JD.com's stablecoin is not for "issuing for the sake of issuing", but is used to solve the pain points of currency circulation in the existing system: opaque multi-currency settlement, high handling fees, unstable arrival time, etc. In this system, stablecoins are not a show of skill for the C-end, but an efficiency improvement for the B-end.
Regulatory-friendly: clear scenario path, user verifiable, and predictable income
Compared with many stablecoin models that construct "anchor relationships" through DeFi protocols and contract mechanisms, JD.com provides a set of "discloseable, reportable, and controllable" commercial application paths.
Its goal is not to build a liquidity pool or a token market, but to clearly explain to regulators: which company this stablecoin is issued to, what scenario it is used for, and how to settle after use. There are KYC, auditing, and traceability mechanisms at every step in the entire process. To some extent, it is closer to an "on-chain settlement certificate running on a regulatory map" rather than a free market trading asset.
Conclusion
JD.com's stablecoin project proves one thing: today when stablecoins enter the institutional track, the "structural adaptability" of the project is becoming the core variable that determines success or failure.
It is not who issued the currency first, nor who knows smart contracts better, but who can build a complete architecture that is accepted by regulators, verified by scenarios, and recognized by the market. This architecture is not imagined by a white paper, but it must be implemented in the following ways:
Localized issuers and reserve segregated accounts;
Clear settlement systems and risk control mechanisms that meet financial-level requirements;
Clear scenario value closed loop, especially the real needs of the B-side.
In other words, future stablecoins are not "extensions of crypto projects" but "a new journey for infrastructure-level enterprises".
Portal Labs believes that the real benefits will not come in the form of "regulatory relaxation", but will be gradually released in the form of "institutional stability + the rise of compliance capabilities".
For companies that want to enter this field, the first question to ask yourself should be: Am I ready to become a financial issuer?
Anais
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