TL;DR
Hong Kong introduced its Virtual Asset Trading Platform (VATP) licensing regime in June 2023. Nine VATPs had been licensed by early 2025 [1]. That was phase one. Phase two is happening now, and the scope is dramatically wider.
What's Being Added
In June 2025, the FSTB and SFC jointly published consultation papers proposing two new licensing categories: VA dealing (covering OTC spot trading, brokerage, and block trading beyond exchange matching) and VA custodian services (covering any entity safeguarding private keys or able to transfer client VAs) [2].
Following consultations, they published two additional categories in December 2025: VA advisory services and VA management (portfolio managers investing in virtual assets) [3].
All four regimes are being legislated under the AMLO. Draft legislation is expected in Hong Kong's Legislative Council in 2026 [4].
No Transitional Arrangements
Unlike MiCA in the EU, Hong Kong's new categories will have a hard commencement date with no grandfathering [3]. Providers are being asked to contact the SFC proactively. An expedited process will be available for entities already licensed under VATP or regulated under the Securities and Futures Ordinance [2].
Penalties: up to seven years imprisonment and HK$5 million fine. The regime applies extraterritorially to overseas entities actively soliciting Hong Kong clients [3]. For companies navigating licensing requirements across multiple jurisdictions simultaneously, Hong Kong's hard commencement model stands in sharp contrast to the EU's extended transitional periods.
What This Means for Payment Companies
If your business touches virtual assets in Hong Kong, assess which of the six categories applies. This includes stablecoin payouts, on-ramp/off-ramp services, and custody. Early engagement with the SFC is not optional.
Sources:
[1] Fireblocks. "Hong Kong's VATP Licensing: A Strategic Overview." February 2025. https://www.fireblocks.com/blog/hong-kong-virtual-asset-trading-platform-licensing-strategic-overview
[2] Sidley Austin. "Hong Kong Poised to Expand Licensing Regime." July 2025. https://www.sidley.com/en/insights/newsupdates/2025/07/hong-kong-poised-to-expand-licensing-regime-to-cover-virtual-asset-dealers-and-custodians
[3] Sidley Austin. "Hong Kong to Further Enhance Licensing Regime." January 2026. https://www.sidley.com/en/insights/newsupdates/2026/01/hong-kong-to-further-enhance-licensing-regime-for-virtual-assets-to-cover-advisors-and-managers
[4] CoinDesk. "Hong Kong Targets 2026 Legislation for VA Dealer and Custodian Rules." December 2025. https://www.coindesk.com/policy/2025/12/25/hong-kong-regulators-target-2026-legislation-for-virtual-asset-dealer-and-custodian-rules
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