#香港财库局与证监会就虚拟资产服务发牌制度展开公众咨询 Core Progress (2025-12-24, Hong Kong Financial Services and the Treasury + Securities and Futures Commission)
- Release of the consultation summary on the licensing system for trading/custody services (August consultation, received 101/93 submissions), and simultaneously launch a new round of public consultation for virtual asset advisory services and asset management licensing system, lasting 1 month (until 2026-01-23).
- Core principles: Same business, same risk, same rules, the Securities and Futures Commission is the main licensing and regulatory authority, implementing the ASPIRe roadmap.
Confirmed key points for trading/custody licensing
- Trading services: Covering cryptocurrency-to-cryptocurrency, cryptocurrency-to-fiat exchanges, brokerage, bulk transactions, etc.; licensing must meet requirements of 'fit and proper', financial resources, risk control, customer asset segregation, etc.
- Custody services: Unified licensing by the Securities and Futures Commission; banks/value storage payment tool licensees are supervised by the Monetary Authority; stablecoin issuers only managing their own stablecoins are regulated by the Monetary Authority; requirements include record-keeping in Hong Kong, compliance of key personnel, dual responsible personnel, and core positions holding personal licenses.
New round of consultation adds two types of licenses
- Virtual asset advisory services: Including investment advice, research reports, ratings, etc., proposed to be included under licensing/registration, strengthening disclosure and conflict of interest management.
- Virtual asset management services: Covering funds, asset management plans, etc., applicable to similar regulations as those currently in place by the Securities and Futures Commission, emphasizing investor suitability and risk disclosure.
Market impact and strategy
- Impact: Accelerated regulatory coverage, increased compliance costs, small and medium institutions clearing or consolidating; institutional funds more willing to enter the market, strengthening Hong Kong's position as a virtual asset hub.
- Trading and compliance reminders:
- Short term: News is neutral, compliance expectations materialize, volatility may be limited; focus on platforms with high licensing expectations and custody-related targets.
- Medium term: Prioritize institutions that have connected with Hong Kong regulation and have first-mover advantages; prepare licensing application materials in advance, ensure customer asset segregation and KYC/AML upgrades.