Asia/HK/Comparables
Hong Kong
Securities and Futures Commission
Two live statutes, two regulators, one city. VATPs are licensed by the SFC under the SFO (Types 1 and 7) and AMLO (VA service). Specified stablecoins are licensed by the HKMA under the Stablecoins Ordinance, in force 1 August 2025, with the first issuer licences granted 10 April 2026. Listing on a licensed VATP is a platform fact, not an SFC endorsement of the token.
VATP dual licence
SFO + AMLO
SO live
1 Aug 2025
First SO licences
10 Apr 2026
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
CASP / platform analogue
- In force
ART/EMT analogue — specified stablecoin issuance
- In force
Intermediary treatment of HKMA-licensed stablecoins
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 | Virtual asset (AMLO) vs security token (SFO) | Partial | Dual-licence platforms because the token might be either. |
| Rule 200 / 300 | No CIC offering exemption; token admission on a VATP | Inverse | Retail access is a platform-admission question, with product filters. |
| Stablecoin (not in RCA) | Cap. 656 specified stablecoin + HKMA licence | Analogue | Closest live Asian analogue to MiCA Titles III–IV. |
| Rule 400 | None | No analogue | No Howey off-ramp. |
Analysis
What the file is
Hong Kong licensed the platform first (VATP regime under the SFO and AMLO) and the fiat-referenced token second (Stablecoins Ordinance Cap. 656). A centralised platform that trades security tokens needs Types 1 and 7; one that trades non-security virtual assets needs the AMLO VA-service licence; most applicants file both. Token admission onto a licensed VATP is governed by SFC product filters, not by an issuer NOR.
Cap. 656 is live, not a consultation
The Stablecoins Ordinance commenced on 1 August 2025. The HKMA granted the first two issuer licences on 10 April 2026. The SFC’s 27 May 2026 circular then lightened intermediary treatment of “Relevant Stablecoins” (specified stablecoins issued by an HKMA-licensed entity): licensed corporations may deal and custody them in segregated accounts without routing through a VATP, knowledge assessments are disapplied for stablecoin-only services, and the product is not automatically treated as complex or professional-investor-only. That is a payments-instrument decision. It is not a model for Rule 103 website disclosure of a CIC.
Research
The record
- SFC licence lists are the primary public evidence of platform status. “Hong Kong regulated” on a marketing page, without the licence number and the activity, is incomplete on its face.
- From 3 November 2025 the SFC disapplied the twelve-month track-record requirement for HKMA-licensed stablecoins admitted to trading on licensed platforms.
- The 12-month track record remains relevant for other virtual assets offered toward retail. Product filter ≠ issuer exemption.
Ideation
What to file
- If you plan a Hong Kong VATP admission of a token that is a CIC in the US, you have two characterisations of the same instrument. Put both in the comment. Staff need to hear that Rule 100’s “not itself a security” filter will not travel.
- Cap. 656 is the exhibit for “the US should finish the stablecoin statute and keep it out of 33-11434.”
Analysis
What the file is
Hong Kong licensed the platform first (VATP regime under the SFO and AMLO) and the fiat-referenced token second (Stablecoins Ordinance Cap. 656). A centralised platform that trades security tokens needs Types 1 and 7; one that trades non-security virtual assets needs the AMLO VA-service licence; most applicants file both. Token admission onto a licensed VATP is governed by SFC product filters, not by an issuer NOR.
Cap. 656 is live, not a consultation
The Stablecoins Ordinance commenced on 1 August 2025. The HKMA granted the first two issuer licences on 10 April 2026. The SFC’s 27 May 2026 circular then lightened intermediary treatment of “Relevant Stablecoins” (specified stablecoins issued by an HKMA-licensed entity): licensed corporations may deal and custody them in segregated accounts without routing through a VATP, knowledge assessments are disapplied for stablecoin-only services, and the product is not automatically treated as complex or professional-investor-only. That is a payments-instrument decision. It is not a model for Rule 103 website disclosure of a CIC.
Primary sources on file
SFC — licensing regime for virtual asset trading platforms
Hong Kong Securities and Futures Commission/1 Jun 2023/RCA review 28 Jul 2026
Primary regulatory
Stablecoins Ordinance (Cap. 656)
Hong Kong e-Legislation / HKMA/1 Aug 2025/RCA review 8 Sept 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.