Hong Kong’s crypto rulebook is about to grow again. On October 5, Christopher Hui, the Secretary for Financial Services and the Treasury, told a policy briefing of the Legislative Council Panel on Financial Affairs that the government will introduce an amendment bill this year creating separate licensing regimes for four virtual asset services: dealing, custody, advisory and management.
The plan follows two rounds of public consultation by the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC). It would extend oversight beyond virtual asset trading platforms and stablecoin issuers to over-the-counter dealers, custodians, investment advisers and asset managers. None of it is in force yet. The bill still has to go to the Legislative Council and clear the legislative process before it becomes law.
Four Services, Four Reference Points
Each of the four regimes was designed separately. Regulators spent more than a year on them and are now folding them into a single bill as the next stage of Hong Kong’s crypto framework.
The dealing regime targets business such as OTC matching and buying and selling on clients’ behalf, the trades that never touch an exchange order book. Its scope would largely match Type 1 regulated activity (dealing in securities) under the Securities and Futures Ordinance. The SFC would license and supervise dealers, and exemptions similar to those in the traditional securities market are under consideration. The consultation conclusions also require licensed dealers to keep client assets with SFC-regulated custodians.
The custody regime is aimed at firms that hold private keys for clients. Consultation conclusions published in December 2025 said it will focus on the risks of safekeeping clients’ virtual asset private keys in Hong Kong, including controls meant to protect client assets.
Advisory and management services get licenses of their own. The SFC said in May that the advisory rules would broadly track Type 4 regulated activity (advising on securities), while virtual asset management would follow Type 9 (asset management). The whole design rests on the principle of “same business, same risks, same rules.” Anyone carrying on any of the four businesses in Hong Kong would need an SFC license or registration unless exempt, and authorized institutions such as banks, along with stored value facility licensees, would also have to register with the SFC to offer these services. Actively marketing such services to the Hong Kong public without a license would carry penalties in line with the existing trading platform regime.
Both Consultations Are Done
The consultation on dealing and custody opened on June 27, 2025 and closed on August 29, drawing 101 and 93 submissions respectively, close to 200 in all. The FSTB and the SFC published their conclusions on December 24 and moved on to drafting the bill.
The same day, the two agencies opened a separate one-month consultation on advisory and management services, which ran until January 23, 2026. It reportedly drew 51 submissions from market participants, industry bodies and professional organizations.
Conclusions on advisory and management followed on May 26 this year, with responses mostly supportive. Regulators said they would finalize the legislative proposals for all four regimes under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and kept the target of introducing the bill into the Legislative Council in 2026.
The SFC is also encouraging firms that already offer, or plan to offer, virtual asset advisory or management services to contact it before the law takes effect. Early engagement, the regulator says, gives firms a clearer view of the proposed requirements and helps them prepare their license applications.
Trading Platforms and Stablecoins Are Already Licensed
The new bill would sit alongside the existing regimes rather than replace them.
Since June 2023, Hong Kong has run a licensing regime for virtual asset trading platforms. Exchanges serving the local market must be licensed by the SFC and meet requirements on investor protection, corporate governance, asset handling and anti-money laundering controls. Custody requirements for licensed platforms were tightened separately: in August 2025 the SFC issued stricter custody standards covering cold wallets, withdrawals and cybersecurity controls.
Stablecoins fall under the Hong Kong Monetary Authority (HKMA). The Stablecoins Ordinance took effect on August 1, 2025 and requires issuers of fiat-referenced stablecoins within its scope to hold a license. After completing its first round of reviews, the HKMA granted the first two issuer licenses in April 2026, to Anchorpoint Financial and HSBC. Licensees must meet requirements on reserve assets, governance, redemption and anti-money laundering.
Beyond Licenses: Surveillance Tools and Settlement Infrastructure
The 2026 Policy Address, released in September, goes well beyond the four licenses. The government said the SFC will keep refining the virtual asset licensing regime and issue more detailed regulatory guidance for service providers. It will also push for regulated stablecoins to trade on licensed platforms and to settle tokenized money market funds, and extend the framework for tokenized investment products to suitable real-world assets, including gold.
Surveillance is being stepped up as well. The SFC plans to launch a digital asset custody monitoring system in the second half of this year and, in 2027, to add big-data market surveillance and anti-money laundering monitoring components to its CrypTech project.
At the central bank level, the HKMA plans to complete arrangements for central bank digital currency settlement and round-the-clock operation on EnsembleTX around the end of this year, and to explore more uses for tokenized deposits. EnsembleTX is the pilot phase of Project Ensemble. Taken together, these pieces add up to a full chain: regulated stablecoins, tokenized assets and digital settlement infrastructure that runs 24/7.
Next Up: The Text of the Bill
Hui’s remarks on October 5 confirm that the four-service licensing bill remains on the government’s 2026 legislative agenda. So far, however, the authorities have not announced when the new regimes will take effect.
Once introduced, the bill must pass through the Legislative Council before it can take effect. The exact start date, the final exemptions and the application process will all depend on the final text and on follow-up regulatory guidance. For businesses in these areas that do not yet hold an SFC or HKMA license, this is the window to prepare.
Other financial market projects are moving forward under the same policy agenda. Hong Kong’s central clearing and settlement system for gold is scheduled to go live in the first quarter of 2027, and Hong Kong Exchanges and Clearing is expected to release details this year of a new renminbi-denominated, physically delivered gold futures contract, part of the city’s push to build out its gold and commodities markets.
On virtual assets, the SFC’s message is clear: firms that already provide, or plan to provide, dealing, custody, advisory or management services should start talking to the regulator before the new licensing regimes take effect.
This article is for informational purposes only and does not constitute investment advice.
