Hong Kong built its regime in deliberate layers. Virtual asset trading platforms have required a Securities and Futures Commission license since June 1, 2023 under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, with retail access permitted subject to knowledge tests, suitability, and listing standards; operating without a license is a criminal offence. The Stablecoins Ordinance (Cap. 656) added the second layer on August 1, 2025: issuers of fiat-referenced stablecoins in Hong Kong, or of Hong Kong dollar-referenced stablecoins anywhere, must be licensed by the Hong Kong Monetary Authority, with full reserve backing and par redemption; existing issuers had to apply by October 31, 2025 or wind down, and the first licenses were expected in early 2026.
The 2025–2026 agenda has been expansion rather than construction. The government's second policy statement and the SFC's ASPIRe roadmap set out licensing for custody and dealing services, in November 2025 the SFC allowed licensed platforms to share order books with qualifying overseas affiliates to reach global liquidity, and in April 2026 the SFC opened a framework for secondary-market trading of tokenized SFC-authorized investment products. Hong Kong positions the whole stack, exchanges, stablecoins, custody, tokenized funds, as a single architecture for institutional digital asset business adjacent to a mainland where the activity is banned.
The instruments
AMLO virtual asset trading platform licensing
Mandatory SFC licensing for centralized virtual asset exchanges operating in Hong Kong or marketing to Hong Kong investors: fit-and-proper management, 98% cold storage through associated entities, insurance, listing due diligence, and retail-access safeguards.
Stablecoins Ordinance
HKMA licensing for issuers of fiat-referenced stablecoins issued in Hong Kong, and of HKD-referenced stablecoins wherever issued: full backing in high-quality liquid assets, redemption at par, segregation, disclosure, and fit-and-proper requirements. Only licensed stablecoins may be offered to Hong Kong retail investors. Application cutoff for pre-existing issuers: October 31, 2025.
Tokenization and market-expansion measures
SFC circulars authorize tokenized securities and tokenized SFC-authorized funds; November 2025 measures permit shared order books with qualifying overseas affiliates and broaden products for professional investors; the April 2026 framework pilots secondary-market trading of tokenized authorized products. Consultations on custody and dealing licensing continue.