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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.
No periodic updates recorded against this sub-brief.
Sources and findings (5)
- T4SFC 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 M5bindingin force
- T4SFC VATP register — 12 licensed VATP platforms as of February 2026, following approval of Victory Fintech (VDX) — the first new licensee since June 2025.retrieved M2non-bindingupdated
- T4FSTB/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 M4bindingproposednew
- T4FSTB/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 M4bindingproposednew
- T4Proposed 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 M3bindingproposednew