Hong Kong's Stablecoin Ordinance (hereinafter referred to as the Ordinance) officially came into effect on August 1, 2025. The Ordinance sets strict rules for the issuance and operation of stablecoins, explicitly prohibiting the offer, promotion, and sale of stablecoins without a license, and does not provide a transition period. As institutions primarily engaged in the exchange of stablecoins for fiat currency, local cryptocurrency money changers in Hong Kong have been particularly affected. Following the Ordinance's implementation, several over-the-counter (OTC) trading providers (hereinafter referred to as "Over-the-Counter") trading services have suspended stablecoin-related operations pending their license application. This article aims to provide regulators with an on-chain perspective on the impact of the Ordinance by disclosing TRC20-USDT outflow data from Hong Kong OTC service provider (HKVAOTC) addresses over the past 70 days.

Data Description

Bitrace has been monitoring the business address traffic of VAOTC entities located in Hong Kong or primarily serving Hong Kong customers. These entities are classified as store-based service providers that primarily serve offline or real-name customers, and non-store-based service providers that primarily serve online or anonymous customers.

This survey data disclosure will include TRC20-USDT outbound transfer data from all service providers during the two time periods of June 1 to July 31, 2025, and August 1 to August 8, 2025, Beijing time.

The following data excludes non-operational transfer activities between business addresses.

The trading volume of stablecoins in the over-the-counter market decreased by 32.94%

Between June 1 and July 31, all business addresses transferred out a total of 3.17B USDT, with an average daily amount of 52.04M USDT; between August 1 and August 8, all business addresses transferred out a total of 279M USDT, with an average daily amount of 34.90M USDT. Compared to before the ordinance came into effect, the overall size of the stablecoin exchange market decreased by 32.94% after August 1st. This sensitivity demonstrates the profound impact of the ordinance on Hong Kong's local crypto industry. Store-based service providers saw a greater reduction in volume. Traffic statistics were collected for both store-based and non-store-based service providers' business addresses. After the regulations came into effect, the average daily USDT transfer volume of store-type service providers decreased by 43.20% (9.47M -> 5.38M), while the business addresses of non-store-type service providers decreased by 30.65% (42.57M -> 29.52M).

Store-based service providers suffered significantly greater impact than non-store-based ones, indicating that after the regulation came into effect, some businesses in Hong Kong's OTC trading services industry quickly went underground.

Final Note

The introduction of the Stablecoin Ordinance marks a significant step forward in regulatory compliance for the Hong Kong crypto industry and will have a significant short-term impact on the local OTC trading services industry. Among relevant practitioners, some chose to comply with regulators and apply for licenses, while others turned to underground operations, presenting a differentiated approach.