Stablecoin Compliance Issuance: JD's Framework Reveals Corporate Licensing Path

Written by: Portal Labs

Original Title: From the Perspective of JD.com's Structure, What Kind of Enterprises Can Legally Issue Stablecoins?

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. Consequently, the Web3 market, particularly in China (Mandarin-speaking regions), is turning its attention to the internet giants participating in the sandbox program.

Since June, discussions related to stablecoins have been ignited domestically, led by JD.com. On June 17, according to Sina Finance, Liu Qiangdong of JD.com stated that JD hopes to apply for stablecoin licenses in all major currency countries globally to facilitate currency exchange between global enterprises. On the 18th, Liu Peng, CEO of JD Coin Chain Technology, stated in an exclusive interview with Bloomberg Businessweek that the Hong Kong Dollar and multi-currency stablecoins have been successfully advancing in the sandbox testing by the Hong Kong Monetary Authority, with hopes to officially obtain licenses and go live in early Q4 of this year.

As always, whenever there is good news from Hong Kong, there will inevitably be many voices in the domestic sphere signaling "domestic opening signals"; this time is no exception. However, while expectations may exist, as practitioners, Portal Labs still believes that we should look beyond the surface and examine the underlying logic.

So, why can JD.com, as a Chinese internet giant, issue stablecoins? This must be because its underlying architecture meets the conditions for stablecoin issuance in Hong Kong. (That's right, not China, only Hong Kong)

From the composition of the project itself, its compliance path, initiating entity, and business positioning are all extremely clear.

JD Stablecoin Project Entity

The reason JD can advance its stablecoin project in Hong Kong is that its underlying architecture must meet the basic requirements of the Hong Kong Stablecoin Regulation regarding the "issuer entity." According to the draft of the Hong Kong Stablecoin Regulation, issuers must:

• Registered in Hong Kong;
• With a paid-in capital of over HKD 25 million;
• Possess stable financial and risk control capabilities;
• Can maintain a 100% high-quality and highly liquid asset reserve;
• Accept audit supervision and establish a clear redemption mechanism.

The establishment of JD Coinlink Technology Hong Kong Limited is to meet the regulatory container's institutional requirements. The company is registered in Hong Kong, with JD Technology Group as its shareholder, possessing independent legal status, allowing it to isolate its finances, assets, and operations from its parent company. This structural arrangement not only ensures that it meets the basic qualifications of an issuer but also guarantees that its business operations can independently conduct compliance responses during sandbox testing, risk assessment, and the formal licensing process.

From a compliance perspective, why doesn't JD Group apply for a license directly? The reason is that JD, as a large group in mainland China, cannot directly become a "local registered issuer" under the Hong Kong stablecoin regulations. By establishing a wholly-owned subsidiary, the group can achieve unified coordination in technology and resources, while also being able to accept regulation from the Hong Kong Monetary Authority as an independent entity, thereby completing the legal relationship between the issuer and reserve custody, as well as compliance reporting.

This arrangement is essentially no different from Circle establishing Circle Internet Financial LLC in the U.S. as the issuer of USDC: the "issuer" must have an independent and auditable legal identity to accept local regulatory and business penetration requirements, rather than relying on the overall qualifications of the parent company.

In other words, JD is qualified to participate in the stablecoin sandbox not because it is "in China", but because it is "in Hong Kong and meets Hong Kong regulatory requirements". This is the first principle behind the establishment of the project and a prerequisite for judging its replicability.

JD Stablecoin Project Design

Meeting the regulatory qualifications is merely the starting point for the compliant issuance of stablecoins. The real "ability to issue" hinges on design capability—whether an institution can establish a regulated, auditable, and redeemable stablecoin issuance and operation system.

This capability is often reflected in three areas: governance structure, financial capacity, and infrastructure.

Governance Structure: Institutional Arrangement from Group Separation to Independent Risk Control

According to the Hong Kong "Stablecoin Regulation Draft", issuers must meet a series of regulatory requirements at various governance levels: including the establishment of internal audits, risk control, and information disclosure mechanisms, as well as clarifying the boundaries of directors' responsibilities and statutory regulatory obligations. The purpose is to treat issuers as quasi-financial institutions, subject to review with a transparent governance structure.

The reason why JD Coin Chain Technology can become a sandbox pilot institution is not primarily because its parent company is an internet giant, but because it has established a governance structure as a "quasi-financial issuer". According to public information, the company has an independent director structure in its statutory documents and complies with local Hong Kong laws for financial report audits and routine regulatory submissions. This means that its issuance activities do not rely on the guarantees or reputation of the parent group, but instead assume legal responsibilities based on its "own governance system".

Capital Structure: Behind the Compliance Reserve Mechanism and High Credit Threshold

Hong Kong's regulatory requirements for stablecoin reserves are extremely strict: not only must they be 100% pegged, but they must also consist of "high-quality and highly liquid assets," such as Hong Kong dollars, bank deposits, and short-term government bonds, and a dedicated custody account must be established for asset segregation and auditing.

This threshold naturally excludes a large number of small and medium-sized crypto projects, leaving only companies with ample funds and strong financial risk control capabilities to be qualified. JD.com, as a large enterprise with abundant daily cash flow, has the ability to set up equivalent reserve accounts and cooperate with financial institutions for asset custody. It is understood that during the sandbox testing period, it has established a mechanism for stablecoin exchange and redemption, and has promised users that they can redeem fiat currency "at face value, without additional fees," which is consistent with the basic requirements outlined in the draft.

More importantly, its stablecoins are not anchored to virtual assets, but are 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 distinctly different from solutions based on "algorithms" or "on-chain collateral" in the crypto market.

Infrastructure Capability: Can it independently complete settlement, verification, and compliance?

Issuing stablecoins is not a technological innovation, but a reconstruction of "compliant financial facilities." Under the regulatory framework of the Monetary Authority, issuers must have a clearing and settlement system, identity verification processes, KYC/AML mechanisms, system auditing, and emergency response capabilities. In short, stablecoins cannot simply be issued by writing a smart contract and having a frontend; it is a comprehensive engineering system.

In this regard, JD.com has accumulated rich experience in B-end scenarios such as e-commerce payments, consumer finance, and cross-border settlement for a long time. Its subsidiary JD Digits has previously built multiple payment and account systems, capable of operating millions of financial users. This provides a natural infrastructure for stablecoins. In other words, what JD.com issues is not a "on-chain token," but rather a "financial instrument" with a real exchange mechanism.

In contrast, many crypto-native projects, even with licenses overseas, find it difficult to establish supporting infrastructure in actual operations, thus failing to meet the core requirement of Hong Kong regulators for "full-process controllability of the stablecoin system."

JD Stablecoin Business Scenarios

The core demand of regulation is not just "Can you issue it?" but also "Once you have issued it, can it operate within the regulatory view?" From this perspective, the use cases of stablecoins are not only about business expansion logic but also serve as a bridge of regulatory trust.

At this point, JD's stablecoin project is clearly positioned to "serve cross-border remittances and corporate payments," with its entry point being the existing business system rather than rebuilding an on-chain ecosystem. This approach, which starts from the "extension of the existing system," perfectly aligns with the regulatory tone emphasized by the Hong Kong Monetary Authority of "integration with the real economy."

Enterprise Payment: Not creating a C-end wallet, but a B-end settlement tool

The JD stablecoin project is a B2B-level settlement tool. According to CEO Liu Peng in an interview with Bloomberg, its goal is to provide enterprise clients with a more efficient means of exchanging between different national fiat currencies, reducing the intermediary links and foreign exchange loss costs in traditional cross-border settlements.

This means that the primary function undertaken by the JD stablecoin is to "enhance corporate foreign exchange efficiency." Its circulation path is inherently closed, and users have clear control. For regulators, this highly certain scenario is highly acceptable: it does not involve speculative trading, is not aimed at retail investors, and has controllable risks and clear uses—this is precisely the ideal "financial technology enhancement tool" rather than a "quasi-financial asset."

Off-chain connectivity: Integration with existing supply chain finance and cross-border settlement closed loops

JD has already laid out systems such as supply chain finance, cross-border clearing and settlement, and warehousing fulfillment in its cross-border business. The integration of stablecoins is essentially a natural extension of the "on-chain certificate + off-chain fulfillment" logic. Compared to most Web3 projects on the market that follow the path of "launching tokens first and then finding use cases," JD itself has a demand side, which naturally creates scenarios for the use of stablecoins.

In other words, JD's stablecoin is not designed to be "issued for the sake of issuance," but rather to address the pain points of currency circulation within the existing system: the lack of transparency in multi-currency settlements, high transaction fees, and unstable arrival times. In this system, stablecoins are not for C-end showmanship, but for improving efficiency on the B-end.

Regulatory Friendly: Clear Scenario Path, User Verifiable, Predictable Returns

Compared to many stablecoin models that construct "anchoring relationships" through DeFi protocols and contract mechanisms, what JD provides is a set of "disclosable, reportable, and controllable" commercial application pathways.

The 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 scenarios it is used for, and how it is settled after use. Every step of the entire process includes KYC, auditing, and traceability mechanisms. To some extent, it is closer to a "on-chain settlement certificate operating on the regulatory map" rather than a freely traded asset in the market.

Conclusion

The JD stablecoin project proves one thing: today, as stablecoins enter the institutional track, the project's "structural adaptability" is becoming the core variable that determines success or failure.

It's not about who issued the coin first, nor about who understands smart contracts better, but about who can build a complete framework that is accepted by regulators, validated by scenarios, and recognized by the market. This framework is not imagined from a white paper, but needs to be realized in:

• Localized issuers and reserve isolation accounts;
• A clearing and settlement system and risk control mechanism that meets financial-grade requirements;
• Clear value closure in the scenario, especially the real needs of the B-end.

In other words, the future of stablecoins is not an "extension of crypto projects" but a "new journey for infrastructure-level enterprises."

Portal Labs believes that true benefits will not come in the form of "regulatory easing", but will be gradually released in the form of "institutional stability + compliance capabilities rising."

For companies looking to enter this field, the first question they should ask themselves is: Am I ready to become a financial issuer?