HK VASP licensing under SFC/HKMA joint circulars; Stablecoins Ordinance 2023; Basel cryptoassets standard 2026
Hong Kong operates a dual-regulator regime for virtual assets, with the SFC overseeing licensing for virtual asset trading platforms and advisory services, and the HKMA regulating authorized institutions' exposure and custody activities. The SFC and HKMA jointly issued circulars establishing licensing conditions, mandating omnibus accounts and strict custody standards for intermediaries.
The Stablecoins Ordinance provides a specific licensing framework for stablecoin issuers and authorized institutions dealing in relevant stablecoins. Additionally, the HKMA has implemented the Basel Committee's cryptoassets standard, effective 1 January 2026, which sets prudential capital and disclosure requirements for banks' cryptoasset exposures.
Regulatory direction emphasizes investor protection, robust custody arrangements (including cold storage), and anti-money laundering compliance. The regime is evolving to include staking services and tokenized traditional assets under specific conditions.
Securities and Futures Commission (SFC)
Primary regulator for virtual asset trading platforms, dealing, and advisory services under the SFO.
[1][2][3]Hong Kong Monetary Authority (HKMA)
Regulates authorized institutions' prudential treatment of cryptoassets, custody standards, and stablecoin-related activities.
[4][5][6]Stablecoins Ordinance (2023)
Establishes the licensing regime for stablecoin issuers and regulates authorized institutions' engagement with authorized stablecoins.
[5][7]Banking (Capital), (Disclosure), and (Exposure Limits) (Amendment) Rules (2025)
Implements the Basel Committee's cryptoassets standard, setting prudential capital and disclosure requirements for banks' cryptoasset exposures, effective 1 January 2026.
[6][8][9]Securities and Futures Ordinance (SFO) (N/A)
Provides the legal basis for SFC licensing of virtual asset dealing and advisory services, as detailed in joint circulars.
[1][3]Virtual Asset Trading Platform (VATP) License
Required for entities operating platforms for virtual asset trading. Conditions mandate omnibus accounts, strict custody, and operational resilience.
[1][3]Stablecoin Issuer License
Required for issuing stablecoins under the Stablecoins Ordinance. Authorized institutions may also deal in authorized stablecoins under specific conditions.
[5][7]Virtual Asset Fund Manager
Regulated under SFC Type 4 (Advising on Securities) and Type 9 (Asset Management) licenses with specific terms for virtual asset exposure.
[10]Intermediaries must conduct virtual asset dealing through omnibus accounts with SFC-licensed platforms. Retail investor restrictions apply to most virtual asset products.
[1][11]Authorized institutions must adhere to strict custody standards, including cold storage and segregation of client assets, when providing custodial services.
[4][12]Virtual asset financing is permitted only with specified collateral and subject to strict credit risk assessments and haircuts.
[2][13]Regulatory framework is maturing with the implementation of the Basel cryptoassets standard and refined guidance on staking and tokenized assets. Focus remains on prudential stability and investor protection.
[6][14]HKMA Supervisory Incubator for DLT continues to support innovation while managing risks, indicating a balanced approach to technological adoption.
[15]Email alerts for Hong Kong updates
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