Trusts, trustees, and stablecoins: an analysis of Hong Kong’s Stablecoins Ordinance and its implications for trust law

This article examines the Stablecoins Ordinance, due to commence on 1 August 2025, and its effect on Hong Kong trust law. It explores whether licensed stablecoins qualify as trust property, analyses the fiduciary and statutory duties of trustees who hold them, discusses the Ordinance’s requirement that reserve assets be placed in trust, and outlines potential legal reforms for emerging challenges. Drawing on recent case law, international regulatory comparisons, and practical considerations for fiduciaries, the article argues that stablecoins can strengthen, rather than disrupt, established trust principles in Hong Kong.