Hong Kong licenses payments and digital assets through three regulators and four main licences. The Hong Kong Monetary Authority (HKMA) licenses stored value facilities and stablecoin issuers. The Customs and Excise Department licenses money service operators. The Securities and Futures Commission (SFC) licenses virtual asset trading platforms. Each licence attaches to an activity, so the starting point is what the business does with customer money or assets.
Many groups need more than one. A wallet that also offers international transfers can do both under the SVF licence, because the HKMA allows SVF licensees to provide remittance and money changing as an ancillary service without a separate MSO licence. An exchange that wants to list a Hong Kong dollar stablecoin works alongside a licensed issuer, and a stablecoin issuer reaches the public through banks, SVF licensees and licensed platforms.
| Licence | Regulator and law | Typical holder |
|---|---|---|
| Stored value facility licence | HKMA, Payment Systems and Stored Value Facilities Ordinance (Cap. 584) | Digital wallets, prepaid card issuers, multi-purpose payment balances, travel and transport cards |
| Money service operator licence | Customs and Excise Department, Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) | Remittance firms, cross-border payout and collection businesses, money changers |
| Virtual asset trading platform licence | SFC, Cap. 615 (virtual asset service) and Securities and Futures Ordinance (Cap. 571, Types 1 and 7) | Centralised crypto exchanges serving Hong Kong investors |
| Stablecoin issuer licence | HKMA, Stablecoins Ordinance (Cap. 656) | Issuers of fiat-referenced stablecoins, including any Hong Kong dollar stablecoin |
The licensed populations are small and visible on the regulators' own registers. The HKMA register of SVF licensees listed 11 non-bank licensees at its revision of 14 August 2026, alongside banks that operate stored value facilities. The SFC lists of virtual asset trading platforms showed 13 licensed platforms and 5 applicants at 16 October 2026. The HKMA register of licensed stablecoin issuers lists two licensees, both effective 10 April 2026.
The SVF licence is Hong Kong's licence for holding customer money, equivalent in purpose to an e-money licence elsewhere. The HKMA grants it only if it is satisfied that the minimum criteria in the Ordinance are met at grant and on a continuing basis. Its explanatory note on licensing and guideline on supervision of SVF licensees set out what that means in practice.
A business issuing multi-purpose stored value in Hong Kong needs the licence. Certain limited-group and single-premises facilities are exempt, but the exemption falls away once the float of the facility, or the combined float of several facilities, exceeds HK$1,000,000.
Paid-up share capital of at least HK$25,000,000, or the equivalent in a freely convertible currency the HKMA approves, or other financial resources of at least that amount. The HKMA may require more for the scale and risk of the facility.
The float is kept separate from the licensee's own funds. The supervisory guideline requires an effective trust arrangement giving users a legal right and priority claim to the float, with a bank guarantee or insurance as an alternative or supplement where the licensee justifies it. Holding the float in low-risk assets other than cash or bank deposits needs the HKMA's prior written consent, and the HKMA expects that investment returns on the float are not a business model.
The chief executive and alternate chief executive must be ordinarily resident in Hong Kong. Senior management and the people responsible for financial management, risk management, compliance and internal audit should be based in Hong Kong. The HKMA's benchmark is that one third of the board are independent non-executive directors, and compliance and internal audit run as separate functions.
The HKMA strongly encourages management to discuss the plan with its SVF licensing team before applying. The formal application includes six independent assessment reports covering corporate governance and risk management, float management, anti-money laundering systems, technology risk, payment security and business continuity. Each report is valid for six months after sign-off. An incomplete application is treated as a draft; an application is suspended if requested information misses its deadline, and after six months suspended a fresh application is generally required.
The MSO licence covers remittance (sending money to, or receiving or arranging receipt of money from, a place outside Hong Kong) and money changing. The Customs and Excise Department's licensing guide sets the requirements. Operating a money service without a licence is an offence carrying, on indictment, a fine of HK$1,000,000 and two years' imprisonment.
Authorised institutions, SFC-licensed corporations, authorised insurers and insurance intermediaries, SVF licensees and certain payment system operators do not need the licence where the money service is ancillary to their principal business. The department does not accept applications from exempt persons.
There is no minimum capital requirement. The application includes a business plan and an anti-money laundering policy meeting the department's guidelines, and the department interviews the applicant and inspects the premises before granting the licence.
The SFC has licensed centralised virtual asset trading platforms under Cap. 615 since 1 June 2023. Because a token can move between being a security and a non-security, the SFC asks platforms to apply under both ordinances in one consolidated application through its WINGS portal: a licence for Types 1 (dealing in securities) and 7 (automated trading services) under Cap. 571, and a virtual asset service licence under Cap. 615. The Licensing Handbook for Virtual Asset Trading Platform Operators sets the requirements.
A company incorporated in Hong Kong or a non-Hong Kong company registered with the Companies Registry. Sole proprietorships and partnerships are not accepted.
At least two responsible officers (the senior licensed individuals who supervise the regulated business), at least one ordinarily resident in Hong Kong and at least one an executive director. Every executive director is approved as a responsible officer. The board approves a management structure naming managers-in-charge of the core functions, and changes are notified to the SFC within seven business days.
Client assets are held on trust through an associated entity: a wholly owned Hong Kong subsidiary holding a trust or company service provider licence and conducting no other business. Before licensing, an external assessor engaged under a three-party agreement with the SFC reviews the platform's systems and controls once they are deployed.
The Stablecoins Ordinance commenced on 1 August 2025, and the HKMA granted the first two stablecoin issuer licences on 10 April 2026, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. The HKMA's explanatory note on licensing of stablecoin issuers sets out the criteria.
A business issuing a fiat-referenced stablecoin in Hong Kong in the course of business, issuing one outside Hong Kong that references the Hong Kong dollar in whole or in part, or holding itself out as doing so, including by actively marketing to the Hong Kong public.
The applicant is a company incorporated in Hong Kong or an authorised institution incorporated outside Hong Kong; other overseas groups apply through a Hong Kong subsidiary. Paid-up share capital is at least HK$25,000,000, or an approved equivalent, used for the business and not for dealings with related parties.
The chief executive, alternate chief executive and any stablecoin manager need the HKMA's consent and are expected to be ordinarily resident in Hong Kong. One third of the board are independent non-executive directors, and senior management and key personnel are generally based in Hong Kong. Applications go to the Stablecoin Advisory Committee, which advises the HKMA.
Licensed stablecoins are offered through permitted offerors: licensed issuers, authorised institutions, SVF licensees, SFC-licensed platforms and Type 1 licensed corporations. A stablecoin strategy for Hong Kong therefore usually involves the issuer licence and agreements with one or more of these firms. BCC's stablecoin licensing page compares the Hong Kong regime with the US, EU, UK and Singapore.
Substance in Hong Kong means real decision-makers in the city, not a registered address. Every regime expects the people who run the business, and its records, to be in Hong Kong.
| Licence | Capital | Local people and presence |
|---|---|---|
| SVF | HK$25,000,000 paid-up, or approved equivalent; more if the HKMA requires | Chief executive and alternate ordinarily resident; senior management, risk, compliance and internal audit based in Hong Kong; one third independent board |
| MSO | No minimum | Premises or a local management office; local record store; compliance officer and MLRO; competence assessment |
| VATP | HK$5,000,000 paid-up; liquid capital of at least HK$3,000,000; twelve months of operating expenses in liquid assets in Hong Kong | Two responsible officers, one ordinarily resident and one an executive director; managers-in-charge of core functions; Hong Kong associated entity for client assets |
| Stablecoin issuer | HK$25,000,000 paid-up, or approved equivalent | Chief executive, alternate and any stablecoin manager ordinarily resident; senior management and key personnel based in Hong Kong; one third independent board |
All four licensees are covered by Hong Kong's anti-money laundering framework. MSO and VATP licensees are licensed under Cap. 615 itself. SVF licensees are supervised for anti-money laundering by the HKMA under the SVF regime, which is why they need no separate MSO licence for ancillary remittance. Stablecoin issuers follow the HKMA's dedicated anti-money laundering guideline for licensed stablecoin issuers, published with the regime in August 2025. Each regulator reviews customer due diligence, transaction monitoring, sanctions screening and suspicious transaction reporting, run from Hong Kong.
None of the four regimes sets a statutory decision period. Timing depends on the completeness of the application, the quality of the controls described and the speed of the applicant's responses.
| Licence | Regulator fees | Timing evidence |
|---|---|---|
| SVF | Licence fee of HK$113,020, payable within 14 days of the licence taking effect and annually | No fixed timeframe; incomplete applications stay in draft and six months suspended means a fresh application |
| MSO | From 15 May 2026: HK$3,810 to apply, plus HK$2,440 per additional premises and HK$945 per person tested; renewal HK$910 plus the same per-person fee; non-refundable | No published processing time; licence normally valid for two years, renewed at least 45 days before expiry |
| VATP | HK$4,740 per regulated activity or virtual asset service; HK$2,950 per responsible officer; HK$1,790 per licensed representative; annual fees at the same scale, with HK$4,740 for each responsible officer | No fixed processing time; at 16 October 2026 the oldest pending application was filed on 6 February 2024 |
| Stablecoin issuer | Annual licence fee set in Schedule 3 to the Ordinance, payable within 14 days of the licence taking effect and annually | Early applications invited by 30 September 2025; first two licences granted on 10 April 2026 |
The MSO figures come from the department's schedule of application fees, which took effect on 15 May 2026 and were the first increase since the regime began in 2012. Beyond regulator fees, the main costs are capital, local staff, premises and the independent reports or external assessor.
For planning, BCC works to two to three months after submission for an MSO licence, nine to twelve months for an SVF licence and twelve to eighteen months for a VATP licence. Stablecoin issuer applications are assessed case by case; the first licences were granted just over eight months after the regime commenced. Preparation before filing typically takes ten to sixteen weeks, driven by the independent reports and the hiring of resident officers.
Banking is part of the licence, not a step after it. Each regime builds a bank into the structure, and banks carry out their own due diligence on the business model, the owners and the compliance framework.
Banks open accounts most readily for applicants with a complete anti-money laundering framework, named resident officers and a clear flow of funds, so one pack serves both the regulator and the bank.
Each licence carries continuing obligations from day one.
The framework is widening. On 24 December 2025 the Financial Services and the Treasury Bureau and the SFC published consultation conclusions on new licensing regimes for virtual asset dealing and custodian services, with a bill planned for the Legislative Council in 2026.
The choice follows from what the business holds and moves.
Regional groups commonly pair a Hong Kong licence with Singapore. A business holding balances in both markets typically combines the SVF licence with the Singapore major payment institution licence. Start with the licence that fits today's model, structured so the next one is an extension.
A stored value facility licence from the HKMA under the Payment Systems and Stored Value Facilities Ordinance, unless the facility qualifies for a limited-purpose exemption and its float stays within HK$1,000,000.
No. The HKMA allows SVF licensees to provide remittance and money changing as an ancillary service without a separate MSO licence, because their anti-money laundering supervision sits under the SVF regime.
No. The Customs and Excise Department sets no capital requirement. The applicant needs premises or a local management office, a local record store, a compliance officer and MLRO, and fit and proper directors and owners.
Paid-up share capital of HK$5,000,000 at all times, liquid capital of at least the higher of HK$3,000,000 and the statutory basic amount, and liquid assets in Hong Kong, excluding virtual assets, covering twelve months of operating expenses.
At October 2026 the HKMA register lists two: Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, both effective 10 April 2026.
For an MSO or VATP licence, a non-Hong Kong company registered with the Companies Registry can apply. For an SVF licence the applicant is a company with its principal place of business in Hong Kong. For a stablecoin licence, overseas groups other than authorised institutions apply through a Hong Kong subsidiary.
No regime sets a statutory period. BCC plans for two to three months after submission for an MSO, nine to twelve months for an SVF and twelve to eighteen months for a VATP; the first stablecoin licences came about six months after the early application deadline.
Buckingham Capital Consulting obtains Hong Kong stored value facility, money service operator, virtual asset trading platform and stablecoin issuer licences, and arranges the banking and technology each licence depends on.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.