Hong Kong VATP Licence: SFC Requirements, Capital and Process
SFC virtual asset trading platform licensing in Hong Kong: AMLO Part 5A, responsible officers, HK$5m paid-up capital, cold storage, retail access and ongoing obligations.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 28 August 2026.
The short answer
Hong Kong does not issue a general crypto licence. It licenses specific activities. A centralised virtual asset trading platform operating in Hong Kong, or actively marketing to Hong Kong investors, must be licensed by the Securities and Futures Commission under Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, which took effect on 1 June 2023. Where the traded tokens are securities, Type 1 and Type 7 licensing under the Securities and Futures Ordinance applies in parallel.
The applicant must be a locally incorporated company or a registered non-Hong Kong company with a place of business in Hong Kong. Sole proprietorships and partnerships are not accepted. At least two responsible officers are required, of whom at least one must be ordinarily resident in Hong Kong and at least one an executive director, and all executive directors must be approved responsible officers.
Financial resources are paid-up share capital of not less than HK$5 million, and liquid capital of not less than the higher of HK$3 million or the required liquid capital calculated under the SFC guidelines. At least 98 per cent of client virtual assets must be held in cold storage, with compensation arrangements covering client assets.
Other Hong Kong virtual asset activity sits elsewhere. Fiat-referenced stablecoin issuance is licensed by the Hong Kong Monetary Authority under the Stablecoins Ordinance, which commenced on 1 August 2025. A separate regime for virtual asset dealing and custodian services was the subject of consultation conclusions published in December 2025 and remained in the legislative process during 2026, so its final requirements and commencement should be confirmed before relying on it.
Key facts at a glance
| Regulator | Securities and Futures Commission |
|---|---|
| Legislation | AMLO (Cap. 615) Part 5A, in force 1 June 2023, with SFO Type 1 and Type 7 where tokens are securities |
| Who needs it | Operators of centralised virtual asset trading platforms in Hong Kong or actively marketing to Hong Kong investors |
| Entity form | Hong Kong incorporated company, or a registered non-Hong Kong company with a place of business in Hong Kong. Sole proprietorships and partnerships are not accepted |
| Responsible officers | At least two, at least one ordinarily resident in Hong Kong and at least one an executive director. All executive directors must be approved responsible officers |
| Paid-up share capital | Not less than HK$5 million |
| Liquid capital | Not less than the higher of HK$3 million or the required liquid capital under the SFC guidelines |
| Custody | At least 98 per cent of client virtual assets in cold storage, with compensation arrangements for client assets |
| Retail access | Permitted subject to token admission criteria, suitability, risk profiling and knowledge assessment |
| SFO application fee | HK$4,740 per regulated activity for a licensed corporation, with the Type 7 fee waived where incidental to Type 1 or Type 2 |
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What is the Hong Kong Virtual Asset Trading Platform Licence?
Hong Kong licenses virtual asset trading platform operators through the Securities and Futures Commission under Part 5A of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, in force since 1 June 2023, with Securities and Futures Ordinance Type 1 and Type 7 licensing applying where the tokens traded are securities. It is an activity-specific licensing regime with substantive capital, personnel, custody and client protection requirements, not a general crypto permission.
Who Needs Hong Kong Virtual Asset Trading Platform Licence?
Operators of centralised virtual asset trading platforms with a Hong Kong presence or that actively market to Hong Kong investors.
- - Centralised exchanges operating in Hong Kong
- - Offshore platforms actively marketing to Hong Kong investors
- - Platforms trading tokens that are securities, which additionally need Type 1 and Type 7 licensing
- - Groups planning custody offerings alongside a trading venue, which must also track the proposed dealing and custodian regime
The prevailing misconception is that Hong Kong has one crypto licence. It has an activity-based perimeter: platform operation is licensed by the SFC, fiat-referenced stablecoin issuance by the HKMA under the Stablecoins Ordinance from 1 August 2025, and fiat money changing and remittance by Customs and Excise under the money service operator regime. A second misconception is that the deemed licensing transition remains available. It does not.
The Hong Kong virtual asset perimeter
Describing all of this as a Hong Kong crypto licence is not a shorthand, it is a planning error. Each regime has a different regulator, a different statutory basis and different capital and personnel requirements.
- - Centralised virtual asset trading platforms: SFC licensing under AMLO Part 5A, and SFO Type 1 and Type 7 where the tokens are securities
- - Fiat-referenced stablecoin issuance in or from Hong Kong, or referencing the Hong Kong dollar: Hong Kong Monetary Authority licensing under the Stablecoins Ordinance, commenced 1 August 2025
- - Virtual asset dealing and custodian services: a separate regime, with consultation conclusions published in December 2025 and legislation still progressing during 2026
- - Money changing and remittance in fiat currency: Money Service Operator licensing by Customs and Excise, which is not a virtual asset regime at all
Structure, personnel and fitness
- - A locally incorporated company or a registered non-Hong Kong company with a Hong Kong place of business
- - At least two responsible officers, at least one ordinarily resident in Hong Kong and at least one an executive director
- - All executive directors approved as responsible officers
- - Licensed representatives accredited to the platform operator for staff conducting the regulated activity
- - Fit and proper assessment of the corporation, its substantial shareholders and its officers
Financial resources and client asset protection
Client asset protection is where the SFC has concentrated its supervisory attention, and it reinforced its custody expectations in a circular issued in August 2025. Platforms that treat the 98 per cent requirement as a target rather than a control design constraint do not pass.
- - Paid-up share capital of not less than HK$5 million
- - Liquid capital of not less than the higher of HK$3 million or the required liquid capital under the SFC guidelines for virtual asset trading platform operators
- - At least 98 per cent of client virtual assets held in cold storage, with controls on the balance held in hot wallets
- - Compensation arrangements, through insurance or funds, covering client virtual assets consistent with the cold and hot storage split
- - Segregation of client virtual assets and client money, held through an associated entity as the SFC requires
Token admission and retail access
Licensed platforms may serve retail investors, but only within a framework. Tokens must satisfy the SFC admission criteria before they are made available, and retail onboarding requires suitability assessment, risk profiling and a knowledge assessment.
The token admission process is a continuing governance obligation, not a one-off exercise at launch. The platform must be able to evidence why each listed token remains admissible.
Transitional status and the current position
The transitional arrangement that deemed pre-existing platforms to be licensed was tied to applications submitted by 29 February 2024, and the associated non-contravention period has ended. New entrants apply under the standard regime.
The SFC publishes and updates lists of licensed platforms, applicants and closed platforms. Because that list changes, any headline count of licensed platforms should be checked against the SFC list at the time of enquiry rather than taken from a secondary source.
Ongoing obligations
- - Continuing compliance with the SFC guidelines and terms and conditions for virtual asset trading platform operators
- - Anti-money laundering obligations under Cap. 615, including customer due diligence, monitoring, travel rule information on transfers and suspicious transaction reporting to the Joint Financial Intelligence Unit
- - Liquid capital monitoring and financial resources reporting
- - Custody controls, key management, insurance or compensation arrangement maintenance and independent assessment
- - Notification of changes to responsible officers, substantial shareholders and business operations
- - Annual licensing fees, which the SFC resumed collecting from 1 April 2025
Hong Kong virtual asset regimes at a glance
Three different regulators, three different statutory bases. The right question is which activity is being carried on.
| Activity | Regulator | Basis and key requirement |
|---|---|---|
| Operating a centralised virtual asset trading platform | Securities and Futures Commission | AMLO Part 5A, with HK$5 million paid-up capital, two responsible officers and 98 per cent cold storage |
| Trading tokens that are securities | Securities and Futures Commission | SFO Type 1 and Type 7 regulated activity licensing, HK$4,740 application fee per regulated activity |
| Issuing fiat-referenced stablecoins | Hong Kong Monetary Authority | Stablecoins Ordinance, commenced 1 August 2025, with transitional guidance for pre-existing issuers |
| Money changing and remittance in fiat | Customs and Excise Department | AMLO money service provisions, MSO licence, no minimum capital |
A dealing and custodian services regime was consulted on with conclusions published in December 2025 and had not completed the legislative process during 2026. Confirm its status before planning around it.
Key Requirements
Corporate structure
A Hong Kong incorporated company, or a non-Hong Kong company registered in Hong Kong with a place of business there. Sole proprietorships and partnerships are not accepted.
Responsible officers
At least two responsible officers, at least one ordinarily resident in Hong Kong and at least one an executive director, with all executive directors approved as responsible officers, supported by accredited licensed representatives.
Financial resources
Paid-up share capital of not less than HK$5 million, and liquid capital of not less than the higher of HK$3 million or the required liquid capital under the SFC guidelines.
Client asset custody
At least 98 per cent of client virtual assets in cold storage, segregation of client assets, and compensation arrangements covering client virtual assets.
Token admission and retail safeguards
Token admission criteria applied on an ongoing basis, with suitability, risk profiling and knowledge assessment before retail onboarding.
AML framework
Customer due diligence, ongoing monitoring, travel rule information on virtual asset transfers, record keeping and suspicious transaction reporting to the Joint Financial Intelligence Unit.
What SFC virtual asset licensing costs
The SFC fee is trivial next to the capital and control build. Realistic budgeting for a platform application is dominated by capital, custody infrastructure, insurance and the cost of hiring responsible officers the SFC will approve.
- - SFO application fee: HK$4,740 per regulated activity for a licensed corporation, with the Type 7 fee waived where incidental to Type 1 or Type 2
- - Annual licensing fees: resumed by the SFC from 1 April 2025 for intermediaries and licensed individuals
- - Paid-up share capital: not less than HK$5 million, permanently committed
- - Liquid capital: not less than the higher of HK$3 million or the required liquid capital, tested continuously
- - Compensation arrangements: insurance or funds covering client virtual assets, priced by the cold and hot storage split
- - Third-party costs: custody technology, external audit and assessment, legal opinions, responsible officer recruitment and anti-money laundering systems
- - Regulatory Counsel: fixed fee agreed on scoping
The Application Process
Perimeter analysis
Determine which Hong Kong regime applies: SFC platform licensing, SFO Type 1 and Type 7, HKMA stablecoin licensing, or the money service operator regime for fiat activity.
Entity and personnel
Establish the Hong Kong entity and recruit responsible officers who will meet the SFC fit and proper and competence expectations.
Capital and controls
Put paid-up share capital and liquid capital in place, and build the custody, key management, segregation and compensation arrangements.
Policy and governance build
Token admission governance, client onboarding and knowledge assessment, conflicts, market surveillance, anti-money laundering framework and operational resilience.
Application and assessment
File with the SFC and manage a substantive assessment, including detailed questions on custody and controls and any external review required.
Approval conditions and launch
Satisfy conditions, complete any pre-commencement assessments and operate the control framework from the first day of trading.
The SFC does not publish a determination period for virtual asset trading platform applications. Responsible officer availability and custody design maturity are the principal determinants of elapsed time.
How long SFC virtual asset licensing takes
The SFC does not publish a fixed determination period for virtual asset trading platform applications, and the assessment is substantive rather than administrative. The dominant variables are the availability of approvable responsible officers, the maturity of the custody and key management design, and the strength of the compensation arrangements.
Applicants should assume an extended engagement with the SFC involving detailed questions on custody architecture, token admission governance and client onboarding, together with external assessment of systems and controls.
- - Entity establishment and Hong Kong place of business
- - Recruitment and approval of at least two responsible officers
- - Custody architecture, cold storage design and key management build
- - Capital in place and liquid capital monitoring operational
- - Compensation and insurance arrangements agreed
- - SFC assessment, including external review of systems and controls
Why Applications Fail - and How We Prevent It
Responsible officers sourced late
Two approvable responsible officers, one Hong Kong resident and one an executive director, are a hard requirement. Applications built around individuals the SFC will not approve stall entirely.
Custody designed for convenience
The 98 per cent cold storage requirement constrains operational design. Platforms optimised for hot wallet throughput must be re-engineered rather than documented differently.
Assuming a general crypto licence
Applying for the wrong regime, or assuming a dealing or custodian licence already exists, wastes months. The perimeter is activity based and regulator specific.
Retail access without the safeguards
Token admission criteria, suitability, risk profiling and knowledge assessment are conditions of serving retail investors, not marketing preferences.
Practitioner notes
- - Responsible officer recruitment is the critical path. Start it before the application, not after
- - Design custody to the 98 per cent cold storage requirement from the outset. Retrofitting hot wallet operations to the rule is expensive and visible
- - Token admission governance must be documented as an ongoing control, with evidence for each listed token
- - Do not assume a dealing or custodian licence exists yet. Confirm the legislative position for the specific activity before structuring around it
- - Where the business also moves fiat, assess the Money Service Operator requirement separately. The two regimes are not alternatives
How Regulatory Counsel Can Help
Perimeter and strategy
We establish which Hong Kong regime applies to each activity before any application is filed, including where the money service operator regime also applies.
Application and control build
Governance, token admission, custody policy, client onboarding and anti-money laundering documentation prepared to SFC expectations.
Ongoing compliance
Liquid capital monitoring, custody controls, reporting and supervisory engagement after licensing.
Regulatory Counsel advises firms on Hong Kong virtual asset licensing and on the compliance framework that follows it. We do not maintain a Hong Kong office and we do not claim local staff. What we provide is regulatory depth across the SFC, HKMA and Customs and Excise perimeters, and continuity between the application and supervision.
Related Licences
Hong Kong MSO Licence
The separate Customs and Excise permission for fiat money changing and remittance.
EU MiCA CASP Authorisation
The European crypto-asset service provider regime.
UK Cryptoasset AML Registration
The UK registration requirement for exchange and custodian wallet providers.
Frequently Asked Questions
No. Hong Kong regulates by activity. Centralised trading platforms are licensed by the SFC under AMLO Part 5A, fiat-referenced stablecoin issuance is licensed by the HKMA under the Stablecoins Ordinance from 1 August 2025, and fiat money changing and remittance require a money service operator licence from Customs and Excise.
Paid-up share capital of not less than HK$5 million, and liquid capital of not less than the higher of HK$3 million or the required liquid capital calculated under the SFC guidelines for platform operators.
At least two, of whom at least one must be ordinarily resident in Hong Kong and at least one must be an executive director. All executive directors must be approved as responsible officers.
At least 98 per cent of client virtual assets must be held in cold storage, with strict controls over the remainder, alongside compensation arrangements covering client assets. The SFC reinforced its custody expectations in a circular issued in August 2025.
Yes, subject to safeguards. Tokens must meet the SFC admission criteria, and retail clients must be assessed for suitability, risk profile and knowledge before onboarding.
No. It applied to platforms operating before 1 June 2023 that applied by 29 February 2024, and the associated non-contravention period has ended. New entrants apply under the standard regime.
Consultation conclusions on a dealing and custodian services regime were published in December 2025, and the legislation was still progressing during 2026. The final requirements and commencement date should be confirmed before structuring around that regime.
Under the Securities and Futures Ordinance fee schedule a licensed corporation pays HK$4,740 per regulated activity, with the Type 7 fee waived where it is incidental to Type 1 or Type 2. Annual licensing fees resumed from 1 April 2025.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- SFC: virtual asset trading platform operators
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
- SFC licensing fees schedule
- HKMA: stablecoin issuers
Last reviewed by the Regulatory Counsel team on 28 August 2026.