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Hong Kong's mandatory VATP licensing regime under the SFC has been in force since June 2023 and now covers twelve licensed platforms (as of Feb 2026, following the Victory Fintech/VDX approval). A second wave of AMLO-based licensing proposals covering virtual asset dealing, custodial, advisory and management services is pre-enactment, targeted for 2026 LegCo introduction following a 190+ response consultation, with proposed capital-adequacy thresholds for the advisory/management track.
The more consequential development in this module is prospective rather than settled. The FSTB and SFC are targeting 2026 for the introduction to LegCo of legislative proposals establishing AMLO-based licensing regimes for virtual asset dealing and custodial services, following a public consultation that drew more than 190 responses. A parallel track targets a bill establishing AMLO-based licensing for virtual asset advisory and management services, following consultation conclusions published this cycle. Neither has yet been formally tabled, and both remain classified as proposed rather than enacted. The advisory/management track carries an emerging capital-adequacy architecture: baseline financial-resources requirements are proposed at HKD 100,000 minimum liquid capital for firms that do not hold client assets, rising to as much as HKD 5,000,000 in paid-up capital plus HKD 3,000,000 in liquid capital for firms that do hold client assets. These thresholds are themselves still proposed, not in force, and could be revised before any bill is tabled.
Read together, these two tracks represent a deliberate second wave of perimeter expansion beyond the existing VATP and stablecoin licensing regimes — extending statutory coverage to categories of virtual-asset intermediary (dealers, custodians, advisers, managers) that currently sit outside any dedicated Hong Kong licensing requirement. This sequencing mirrors a broader pattern in Hong Kong's approach: core, high-materiality activities (exchange trading, stablecoin issuance) are brought into force first, with secondary categories of intermediary activity following via a slower consultation-to-bill pipeline. For counterparties assessing Hong Kong risk, this matters: the presence of a mature core regime does not imply equivalent certainty for firms whose primary business lies in dealing, custody, advisory or management services falling outside the current VATP and stablecoin scope.
Outlook
The immediate open questions are procedural rather than substantive: whether the dealer/custodian bill and the advisory/management bill are in fact introduced to LegCo within 2026 as targeted, and what effective dates and final capital-requirement schedules they carry once tabled. Until introduction occurs, firms conducting dealing, custody, advisory or management activity involving virtual assets outside the current VATP and stablecoin perimeters continue to operate in a regulatory grey zone that the SFC and FSTB have signalled an intent, but not yet a binding requirement, to close. The pace of VATP registry growth — a single new licensee in the eight months to February 2026 — suggests the existing licensing pathway, while mandatory, is not attracting rapid new entry, a data point worth tracking alongside the second-wave legislative timeline as an indicator of overall market appetite for Hong Kong's licensed perimeter.
Crypto Licensing
Hong Kong's existing Virtual Asset Trading Platform licensing requirement, in force under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap.615) Part 5B and the Securities and Futures Ordinance (Cap.571) Part V since 1 June 2023, remains unchanged and settled this cycle. Against that stable backdrop, the SFC's own applicant register recorded the withdrawal of Flying Hippo Technologies Limited, operating as Matrixport HK, from the VATP applicant pool on 12 October 2026, with a required close-down of any unlicensed activity by 12 January 2027. The application had been pending since 26 February 2024, so the withdrawal removes a long-standing entrant from the licensing queue rather than reflecting a newly rejected application.
The more structurally significant movement is the continued progress of an AMLO amendment bill that would create standalone licensing for virtual asset dealing and virtual asset custody, expected to be introduced to the Legislative Council before the end of 2026. As reported, the bill would require HK$5 million in paid-up capital for virtual asset dealing activity and HK$10 million in paid-up capital for virtual asset custody activity. Critically, the reported design includes no deeming arrangement and no non-contravention period for firms currently conducting dealing or custody activity outside the existing VATP perimeter, meaning such firms would face a hard cut-over into the new licensed regime at commencement rather than a transitional compliance window. This finding is carried at probable confidence from a legal commentary source rather than the bill text itself, since the pinpoint statutory provision and exact commencement date are not yet available, the bill not having been published.
The SFC's standing enforcement framework for licensed VATPs and intermediaries remains unchanged: the maximum fine is the higher of HK$10 million or three times the profit gained or loss avoided, with reprimand and suspension or revocation of licence also available, under the SFC's standing disciplinary framework. This framework applied, separately, in the SFC's HK$7 million enforcement action against a licensed intermediary for due-diligence failures, though that action sits within the financial-integrity rather than crypto-licensing lens of this record.
Outlook
The central open question for Hong Kong's crypto licensing architecture is whether the AMLO amendment bill reaches LegCo introduction before the end of 2026 as currently targeted, and whether the reported absence of a deeming arrangement is retained in the bill as introduced. If retained, firms currently dealing in or custodying virtual assets outside the VATP perimeter would face a materially compressed compliance timeline once the new regime commences. The Matrixport HK withdrawal, read alongside this pending bill, is consistent with a jurisdiction progressively tightening its licensing perimeter across virtual-asset activity types, even as the existing VATP regime itself remains settled and unchanged.
1 earlier distinct update(s)
Crypto Licensing
Hong Kong's existing centralised virtual asset trading platform licensing requirement, administered by the Securities and Futures Commission under the Securities and Futures (Amendment) Ordinance 2022, has been in force since June 2023 and is unchanged this cycle. The material development is the reconfirmation, reported on 29 September 2026 and again via 5 October 2026 remarks to the Legislative Council Finance Committee, of a planned single amendment bill to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap.615) that would create licensing regimes for virtual-asset dealing, custody, advisory and management. The proposal, as currently described, carries no transitional deeming arrangement: firms engaged in these activities without a licence once the regime commences would be required to cease the activity rather than operate under a grandfathered status.
Secondary commentary ahead of the bill's text has floated an administrative fine of up to HK$5 million for unlicensed activity under the proposed regime, and a standalone VA custody framework carrying minimum paid-up capital of HK$10 million and minimum liquid capital of HK$3 million, together with internal-control and insurance arrangements. None of these figures appears in a gazetted instrument as of this cycle, and the bill itself has not been introduced to the Legislative Council. The absence of a deeming arrangement is a notable design choice relative to some other jurisdictions' VASP transition regimes, and it means existing unlicensed providers of dealing, custody, advisory or management services face a binary cliff-edge once the regime takes effect rather than a phased compliance runway.
Outlook
The principal question for this module is whether the bill is gazetted and introduced to LegCo within the reconfirmed end-2026 target, and whether the final text retains the no-deeming design and the consultation-stage capital and penalty figures currently circulating only in secondary commentary.
Sources and findings (26)
- T4 · The BlockSFC virtual asset trading platform (VATP) regime — Mandatory licensing regime for virtual asset trading platforms (VATPs), allowing licensed exchanges to offer retail trading services, launched June 2023. retrieved M5 binding in force
- T3 · CoinDeskSFC VATP register — 12 licensed VATP platforms as of February 2026, following approval of Victory Fintech (VDX) — the first new licensee since June 2025. retrieved M2 non-binding updated
- T3 · CoinDeskFSTB/SFC virtual asset dealing & custodial services licensing proposal — Introduction of legislative proposals to LegCo in 2026 establishing AMLO-based licensing for virtual asset dealing and custodial services, following a public consultation (190+ responses). retrieved M4 binding proposed new
- T4 · The BlockFSTB/SFC virtual asset advisory & management services licensing proposal — Introduction of a bill to LegCo in 2026 establishing AMLO-based licensing regimes for virtual asset advisory and management services. retrieved M4 binding proposed new
- T4 · The BlockProposed virtual asset advisory/management licensing regime — Baseline financial resources requirements: HKD 100,000 minimum liquid capital for firms not holding client assets; up to HKD 5,000,000 paid-up capital plus HKD 3,000,000 liquid capital where client assets are held. retrieved M3 binding proposed new
- T1Flying Hippo Technologies Limited (Matrixport HK) — VATP applicant since 26 Feb 2024, withdrawn 12 Oct 2026, closing-down date 12 Jan 2027. retrieved M3 binding in force new
- T1Securities and Futures Commission (SFC) — Operating a VATP in Hong Kong requires an SFC licence under AMLO Cap.615 Part 5B / SFO Part V, in force since 1 June 2023. retrieved M5 binding in force
- T1SFC / FSTB — Consultation conclusions (para. 29, VA dealing) set baseline financial resources at a minimum paid-up share capital of HK$5,000,000 and minimum required liquid capital up to HK$3,000,000; banks exempt as HKMA-regulated entities. M4 binding proposed
- T3SFC / AMLO (Cap. 615) — Unauthorised VA dealing outside a licensed trading platform, once AMLO amendment commences, will carry a maximum penalty of HK$5,000,000 and 7 years' imprisonment (parity with existing Part 5B sanction). M5 non-binding in force
- UnsourcedStablecoins Ordinance (Cap. 656) — First two stablecoin issuer licences granted 10 April 2026 to Anchorpoint Financial Limited and HSBC.
- UnsourcedSFC VATP Guidelines - compensation arrangement — Compensation arrangement covering 50% cold storage / 100% hot storage.
- UnsourcedSFC-licensed VASP — Phishing-resistant authentication required for VASPs; OTP no longer acceptable; deadline 2027-07-08.
- T1SFC-licensed virtual asset trading platforms — 11 licensed VATPs as of early July 2025, with 9 additional applications in process. M3 non-binding
- T3SFC-licensed virtual asset trading platforms — 13 SFC-licensed VATPs as of May 2026, including OSL Digital Securities Limited and HashKey Exchange. M3 non-binding updated
- T1Flying Hippo Technologies Limited (Matrixport HK) / Spread Technologies Hong Kong Limited (BitMart) — SFC's VATP register records withdrawal of VATP licence applications by Flying Hippo Technologies Limited (Matrixport HK, withdrawn 12 Oct 2026) and Spread Technologies Hong Kong Limited (BitMart, withdrawn 28 Aug 2025); multiple other applicants (OKX HK, Huobi HK, etc.) also withdrew in 2024-2025. retrieved M3 non-binding
- T3Securities and Futures Commission (SFC) — A person carrying on a business of operating a virtual asset exchange in Hong Kong, or actively marketing an offshore VA exchange to the HK public, must hold an SFC VASP licence under AMLO Part 5B. M5 binding in force
- T3Securities and Futures Commission (SFC) — A licensed VATP's custody of client virtual assets must be provided by its own wholly-owned subsidiary (associated entity); at least 98% of client virtual assets must be held in cold storage, with no more than 2% in hot/other storage. M5 binding in force
- T1Securities and Futures Commission (SFC) — A licensed VATP must implement real-time reconciliation of on-chain client assets with ledger balances, due diligence on HSM providers, air-gapped generation and safeguarding of seeds/private keys, and prevent 'blind signing' by displaying complete transaction details before signing. M4 binding in force
- T3Securities and Futures Commission (SFC) — On 6 January 2026 the SFC publicly reprimanded and fined Saxo Capital Markets HK Limited HK$4 million for failures in distribution of unauthorised virtual-asset-related products/funds to retail clients on its online platform over a four-year period. M4 non-binding new
- T1Securities and Futures Commission (SFC) — SFC Annual Report 2025-26: fined 13 licensed corporations a total of HK$84.5 million and disciplined 23 individuals (firm-wide, not crypto-isolated); 12 VATPs were licensed by year-end. M3 non-binding
- T1FSTB / SFC proposed VA dealing and custodian licensing regimes — FSTB and SFC jointly published consultation conclusions on 24 December 2025 for legislative proposals establishing licensing regimes for VA dealing and custodian service providers; not yet enacted into law. M3 non-binding proposed new
- T1SFC-licensed VASP — SFC-licensed VASPs must adopt phishing-resistant authentication (e.g. passkeys, bound devices) for client login and device binding; OTP is not considered phishing-resistant and VASPs should no longer use it for these processes; deadline no later than 8 July 2027. M4 binding in force
- T3Virtual Asset Trading Platform (VATP) / Virtual Asset Service Provider (VASP) — The AMLO VASP licensing regime, as amended by the AML/CTF (Amendment) Ordinance 2022, established a dual-licensing centralised virtual asset exchange licensing regime effective 1 June 2023. M5 binding in force
- T3SFC Guidelines for Virtual Asset Trading Platform Operators — A licensed VATP must maintain paid-up share capital of at least HK$5,000,000, liquid capital of at least HK$3,000,000, and liquid assets covering at least 12 months of operating expenses. M5 binding in force
- T1FSTB/SFC Consultation Conclusions on VA dealing and custodian service providers — Consultation conclusions on VA dealing and custodian licensing regimes published 2025-12-24; not yet enacted into law. M3 non-binding
- T3AMLO amendment bill for VA dealing and custody licensing — A bill to further amend the AMLO, expanding the VA regulatory perimeter to cover VA dealing and custody, is expected to be introduced into the Legislative Council in 2026. retrieved M3 non-binding