In Part 2 of the APAC crypto landscape, Monica Jasuja breaks down how regulators across the region are drawing market-by-market rules for crypto, stablecoins, and Web3 payments. From licensed hubs such as Hong Kong and Singapore to markets that are primarily operated through control-centered approaches like India, the Philippines, and Vietnam, APAC continues to develop and evolve. You can read Part 1 here. 

 

Market-by-market: where the lines are drawn

Hong Kong – the regulated hub

Hong Kong is explicit about wanting to be Asia’s virtual asset and stablecoin hub, and it is building the legal plumbing to match. The virtual asset service provider (VASP) regime under the Anti‑Money Laundering and Counter‑Terrorist Financing Ordinance requires operators of centralised virtual asset trading platforms to be licensed by the Securities and Futures Commission (SFC), with full know‑your‑customer (KYC), anti‑money‑laundering (AML), and client‑asset segregation obligations. At least initially, licensed platforms could only serve ‘professional investors’, defined in Hong Kong law as individuals with portfolios of at least HKD 8 million and corporates with HKD 40 million or more in assets. Retail access is now being opened in stages, but always through SFC‑supervised venues.

In February 2025, the SFC rolled out its ‘ASPIRe’ roadmap—standing for Access, Safeguards, Products, Infrastructure, and Relationships—setting out 12 initiatives to tighten security and compliance while broadening the virtual asset product set. That includes new frameworks for over‑the‑counter (OTC) trading and custody, refinements to trading‑platform rules, and clearer insurance and risk‑management expectations.

Layered on top is the 2025 Stablecoin Issuer Ordinance, which designates the Hong Kong Monetary Authority (HKMA) as licensing authority for fiat‑referenced stablecoin issuers from 1 August 2025. Issuers must be locally incorporated or authorised institutions, hold at least HKD 25 million in paid‑up capital, fully back tokens with high‑quality liquid reserves such as cash and short‑term government securities, and place those reserves with qualified custodians. Transitional relief runs to January 2026 for existing players who notify HKMA and work toward full compliance. High compliance load, but very high regulatory certainty. Hong Kong is where the guardrails are visible.

Despite this, visible momentum around new stablecoin launches had cooled by November, as mainland regulators signalled renewed discomfort with retail‑facing digital‑asset products and major Chinese tech firms paused their Hong Kong stablecoin plans.

High compliance load, but very high regulatory certainty. Hong Kong is where the guardrails are visible.

Singapore – controlled innovation

Singapore’s Monetary Authority of Singapore (MAS) has drawn a sharp line between institutional‑grade innovation and retail speculation. The Payment Services Act (PSA) brings digital payment token services—exchanges, brokers, custodians—into a payment‑service‑provider licensing regime with full AML/CFT and technology‑risk expectations.

On top of that, MAS finalised a dedicated framework for single‑currency stablecoins (SCS) in August 2023. Only tokens that are pegged to SGD or a G10 currency, issued by an MAS‑licensed entity in Singapore, and backed 1:1 with very low‑risk reserve assets in the same currency can use the ‘MAS‑regulated stablecoin’ label. Issuers must meet requirements on reserve composition, segregation, daily valuation, monthly independent attestations, and timely par‑value redemption.

StraitsX, the Singapore‑based platform behind XSGD (Singapore‑dollar stablecoin) and XUSD (US‑dollar stablecoin), secured in‑principle approval from MAS as a Major Payment Institution for digital payment token services to issue SCS that substantially comply with this framework. MAS has also tightened conduct rules for digital payment token service providers, including restrictions on retail incentives and leverage, and enhanced disclosures, with many of these protections taking effect from late 2024.

The opportunity is squarely institutional—treasury, cross‑border, tokenised finance. Retail can participate, but always behind MAS‑licensed intermediaries and under strict conduct rules.

Australia – playing catch‑up

Australia spent several years consulting on digital‑asset rules while others in the region moved to live regimes. That is now changing. In 2025, the federal Treasury released draft legislation to regulate digital asset and tokenised custody platforms and bring payment stablecoins formally into the Australian Financial Services Licence (AFSL) and payments framework. The draft would require exchanges, custodians and related platforms to be licensed, meet capital and conduct standards, and comply with new custody and disclosure obligations.

In parallel, the Australian Securities and Investments Commission (ASIC) has clarified that certain stablecoins can qualify as ‘financial products’ under existing law and, in September 2025, introduced class relief for intermediaries distributing eligible stablecoins, exempting them from separate AFSL authorisations until June 2028 if the issuer itself holds the necessary licence.

The framework is still being finalised, which means room to shape it—through consultation and early‑mover compliance builds—for players willing to engage regulators directly.

India – permissioned digital money, cautious‑control model

India is the market everyone wants, but no one has an easy playbook for.

On paper, crypto trading is not banned, but the tax regime is deliberately hostile: a 30% tax on gains from ‘virtual digital assets’ with no loss offsets, and a 1% tax deducted at source (TDS) on many transactions. The Reserve Bank of India (RBI) has repeatedly flagged private cryptocurrencies and stablecoins as threats to monetary and financial stability, and continues to argue for tight restrictions and global coordination.

At the same time, India tops global crypto adoption indices, with tens of millions of users and very high grassroots usage. Rather than eliminating activity, high taxation and bank‑level caution have pushed much of it to offshore platforms and informal channels.

RBI’s preferred answer is the e‑rupee, its central bank digital currency. By mid‑2025, retail pilots covered 17 banks and around 6 million users (60 lakh), with circulation above INR 1,000 crore, a more than fourfold increase over a year but still a tiny fraction of cash in circulation. RBI and the government are exploring cross‑border CBDC pilots and programmable use cases, but as of late 2025, there is no formal, published regime for INR‑backed private stablecoins.

Policy circles expect the 2025–2026 Economic Survey / Budget cycle to touch on digital‑asset and stablecoin issues, including licensing of exchanges and maybe a route to regulated INR‑linked tokens, but this remains prospective rather than codified.

Enormous addressable market, but today’s rules channel innovation toward CBDC rather than private Web 3 rails. For now, India’s stance on private stablecoins is closer to ‘wait, control, and contain’ than to Hong Kong’s or Singapore’s ‘license and supervise’.

Philippines & Vietnam – adoption first, rules later

Both the Philippines and Vietnam appear near the top of global crypto‑adoption rankings, driven much more by remittances and necessity than by degen trading. Regulation is trying to catch up with that reality.

In the Philippines, Bangko Sentral ng Pilipinas (BSP) licenses virtual asset service providers (VASPs) under Circular 1108, covering exchanges and custodial services with AML/CFT and risk‑management requirements. A three‑year moratorium on new VASP licences that began on 1 September 2022 has now been extended indefinitely from 1 September 2025, with the Monetary Board citing ‘heightened risks’ around virtual assets and a desire to protect consumers and financial stability. Existing licensed VASPs can continue operating, and BSP‑supervised financial institutions with strong supervisory ratings may still apply, but everyone else is frozen out until the central bank decides the risk profile has improved. BSP has also allowed pilots of a Philippine peso‑backed stablecoin, PHPC, requiring full 1:1 backing with cash and cash equivalents in Philippine bank accounts and treating its issuance and related services as regulated activity within the central bank’s sandbox.

In Vietnam, the government has moved from a pure grey area to a structured pilot. Resolution 05/2025/NQ‑CP, effective 9 September 2025, establishes a five‑year pilot programme for crypto and digital assets, licensing domestic exchanges, capping foreign ownership in licensed operators at 49%, and allowing new offerings primarily to foreign investors under strict conditions. Crypto remains illegal as a means of payment for goods and services, but ownership and trading on exchanges are tolerated, and a broader legal framework covering ownership, AML, taxation and licensing is expected to be built out by the end of the pilot.

In both markets, adoption has outrun formal rule‑making. Supervisors are pivoting from ‘ignore or informally tolerate’ to ‘sandbox and license’, but with a strong focus on remittances, consumer protection and foreign‑investment controls.

Pulling it Together

Across these markets, some patterns stand out:

• Licensed, institutional‑first hubs: Hong Kong, Singapore, and soon Australia are converging on a model where exchanges, custodians, and stablecoin issuers are licensed, reserves are tightly controlled, and retail is allowed but heavily intermediated.
  
• High‑adoption pragmatists: The Philippines and Vietnam are building structured regimes only after mass usage has emerged, using moratoria and pilots to slow new entrants while they design full frameworks.
  
• Control‑first giants: India talks innovation, but, in practice, is steering activity away from private rails and toward the e‑rupee and tightly supervised channels.
  

That mix is exactly why a regional play can’t rely on a single regulatory narrative. For anyone building Web 3 payment products in APAC, ‘where the lines are drawn’ is now a market‑by‑market question, not a generic risk disclaimer.

 

In the next installment, Part 3, we’ll explore how stablecoins and CBDCs are reshaping APAC’s money rails, and what this shift means in practice for banks, PSPs, and merchants navigating licensing and compliance.

Stay tuned!

About Monica Jasuja

 

Monica Jasuja is Chief Expansion and Innovation Officer at the Emerging Payments Association Asia (EPAA), leading industry working groups on cross-border payments and tokenised money. She represents EPAA on the BIS PIE Task Force. Ranked among the top 3 global payment leaders and top 10 fintech voices worldwide, Monica brings 24+ years of experience across PayPal, Mastercard, and Gojek.

 

About Emerging Payments Association Asia (EPAA)

 

Emerging Payments Association Asia (EPAA) is the region's leading independent voice for the payments industry, convening banks, fintechs, regulators, and technology providers to shape the future of payments across Asia-Pacific. Through working groups, research, and advocacy, EPAA bridges the gap between policy and practice in an era of rapid digital transformation.