There is no single Hong Kong virtual-asset licence. The proposals cover four separate services: dealing, custody, advising and managing. Anyone carrying on any of them in Hong Kong would have to be licensed by or registered with the SFC unless exempt, and there is no deemed-licensing transitional arrangement for providers already trading.
Four numbers to read before the rest
Under the proposals, dealing, custody, advising and managing would each be licensed in their own right, and most Hong Kong crypto licence summaries still describe only the trading-platform regime. The proposals also reach offshore. Not sure which authorisation your model needs? Start at licence selection; for a jurisdiction comparison see jurisdictions.
Three things to carry away
- The proposed marketing prohibition is drafted to bite "whether in Hong Kong or elsewhere", so incorporating offshore does not answer it.
- There is no deeming arrangement. Commencement day is commencement day.
- Nobody can guarantee an approval, and nobody can commit a regulator to a date.
On this page10 sections
How many Hong Kong virtual-asset licences are there?
The Acting Secretary for Financial Services and the Treasury set the scope plainly in his 1 June 2026 remarks to the LegCo Panel on Financial Affairs: on the principle of same business, same risks, same rules, anyone carrying on a business of virtual-asset dealing, custody, advising or managing in Hong Kong would have to be licensed by or registered with the SFC unless exempt.
Three of the four sit on the existing securities perimeter: dealing, advising and managing align substantially with Type 1 (dealing in securities), Type 4 (advising on securities) and Type 9 (asset management) under the Securities and Futures Ordinance. The existing track is in the same remarks: 13 licensed virtual-asset trading platforms under the regime that commenced in June 2023, and two stablecoin-issuer licences granted.
Settle one thing before reading further: this page draws on two consultation papers, one for dealing and one for custody. The thresholds below are from those two, and neither paper proposes definitions for advising or managing.
Which of your activities needs a VA dealing licence?
Dealing is wider than running an exchange. Paragraph 1.10 of the VA dealing consultation states that the captured services include conversion as well as more complex services such as brokerage activities, block trading activities and other relevant activities of advisors or asset managers.
What you actually do, and the regime it falls in
| What you actually do | Proposed regime | The part people miss |
|---|---|---|
| Operate a centralised trading platform | Dealing (the existing VATP licence does not cover it) | Already licensed, and still expected to obtain the new dealing licence or registration (para 2.12) |
| OTC trades, brokerage, block trades, converting for clients | Dealing | The first consultation was written for OTC specifically |
| Hold clients' private keys or transfer credentials | Custody | Can trigger separately even when incidental to dealing |
| Manage client crypto portfolios or a crypto fund | Managing (dealing may also apply) | VA fund managers are named expressly |
| Publish research, advice or recommendations only | Advising | You never touch an asset and still need to be licensed |
| HKMA-licensed stablecoin issuer, primary-market issue or redemption of its own coin | Proposed exemption | Covers that issuer's own primary-market activity |
Mapping across jurisdictions is in which licence does a crypto exchange need; terms are in the glossary.
What triggers a VA custodian licence?
Paragraph 2.13 of the VA custody consultation defines the service as the safekeeping, by way of business, of clients' VAs or of instruments enabling transfer of clients' VAs, including but not limited to private keys. Paragraph 2.14 of the same paper adds that the second limb captures private keys and similar instruments: smartcards, and the authentication credentials used to access those private keys.
Self-custody, where only you hold the key, sits outside the definition. Where the wallet line falls is in when does a wallet need a custody licence.
The same paper leaves one narrow door: incidental exemptions for SFC- or HKMA-regulated entities where safekeeping client VAs is wholly incidental to the principal business, conditional on not holding clients' private keys. Individuals responsible for the service would also have to be licensed representatives or relevant individuals accredited to the provider, modelled on Type 13 regulated activity.
Does an existing VATP or SFO licence carry over?
No. Paragraph 2.12 of the dealing consultation names four groups expected to obtain a licence or registration: existing SFC-regulated intermediaries, SFC-licensed VATPs, unregulated VA dealing operators and VA fund managers. The LegCo remarks add that authorized institutions and stored-value-facility licensees providing any VA service in Hong Kong must also register with the SFC.
An expedited approval process is proposed for existing intermediaries already through the SFC's or the HKMA's assessment process for their VA dealing services. Why an MSO licence never covered crypto is in can an MSO or MSB cover crypto.
The queue is on the record: as of end-June 2025 the SFC had formally licensed 11 VATPs, with 10 further applicants not yet approved, four of them deemed-to-be-licensed. Eleven licences in the regime's first two years is the realistic yardstick.
What happens on commencement day if you are already trading?
The 1 June 2026 LegCo remarks are explicit: there is no transitional arrangement under which existing service providers would be treated as already licensed or registered. Paragraph 2.41 of the custody consultation is to the same effect: "we are not inclined to provide a deeming arrangement to pre-existing VA custodian service providers". It is inclined instead for the regime to become fully effective on the commencement date of the relevant statutory provisions.
The government will take full account of the time participants need to adjust their business models when it sets that date. The date can move; the requirement does not. Paragraph 2.29 of the dealing consultation spells out the consequence: stakeholders who fail to reach out may suffer undue interruptions to their business operations, having to cease operating on the commencement date.
How much capital does each regime need?
Dealing proposes a minimum paid-up share capital of HK$5 million; custody proposes HK$10 million. Both add a minimum required liquid capital of up to HK$3 million depending on the business model, and dealing alone adds excess liquid capital equal to at least 12 months of actual operating expenses. Fees diverge further: dealing is benchmarked to SFO Type 1 fees, custody to Type 3.
Capital and fees: the two regimes side by side
| Item | Dealing | Custody |
|---|---|---|
| Minimum paid-up share capital | HK$5 million | HK$10 million |
| Minimum required liquid capital | Up to HK$3 million (business model dependent) | Up to HK$3 million (business model dependent) |
| Excess liquid capital | At least 12 months of actual operating expenses | — |
| Proposed fee benchmark | SFO Type 1 fees: HK$4,740 application and annual (licensed corporation); HK$23,500 / HK$35,000 (registered institution) | At least the SFO Type 3 amounts: HK$129,730 application and HK$129,730 annual for a licensed corporation |
Paragraph 2.32 of the dealing consultation benchmarks dealing fees to SFO Type 1: HK$4,740 each for a licensed corporation's application and annual fee; HK$23,500 and HK$35,000 for a registered institution. Custody is proposed to cost far more. Paragraph 2.44 of the custody consultation proposes an application fee and annual fee of at least the amounts currently applicable to SFO Type 3 regulated activity, which for a licensed corporation stand at HK$129,730 each. Neither paper proposes capital or fee figures for advising or managing.
For a dealing applicant the heaviest line is still the excess liquid capital: compliance team, audit and systems on the balance sheet before you earn anything. What recurs every year is in crypto licence annual obligations.
Does this reach you if you are not in Hong Kong?
Yes, if you actively market to the public of Hong Kong, wherever you are incorporated. Paragraph 2.33 of the dealing consultation proposes to prohibit any person from actively marketing, whether in Hong Kong or elsewhere, to the public of Hong Kong the provision of, or holding out as providing in Hong Kong, VA dealing services unless licensed by or registered with the SFC.
Paragraph 2.45 of the custody consultation says the same for custodian services. How a counterparty verifies the licence is in how to check a crypto licence is real.
Where is the bill, and what should you do now?
The first consultation ran from February to April 2024 on a licensing regime for OTC trading services; this is its revised version. Conclusions have been published, and the government's target is to introduce the amendment bill to LegCo within 2026. The bill is not yet law, so everything on this page is a published proposal.
One action is available today, and it is the government's own recommendation: stakeholders already in, or intending to enter, these businesses are encouraged to contact the regulators early to begin pre-application processes. If Singapore is on your shortlist, see which Singapore licence you need.
Common questions
My company is not in Hong Kong but some of my clients are. Do I need a licence?
Yes, if you actively market to the public of Hong Kong. The proposals would prohibit that, from inside Hong Kong or elsewhere, unless you are licensed by or registered with the SFC. What matters is who the marketing is aimed at, wherever the company is incorporated.
I only hold clients' private keys and never trade. Is that custody?
Yes. The proposed definition is safekeeping, by way of business, of clients' VAs or of instruments enabling transfer of their VAs, including but not limited to private keys. Self-custody, where only you hold the key, is outside it.
Will an existing VATP licence convert automatically?
No. The government does not intend to provide a deemed-licensing transitional arrangement, and the custody consultation is to the same effect. Existing intermediaries already assessed by the SFC or HKMA for their VA dealing services can use an expedited approval process, but that only speeds up the application.
A note on what this is
This describes published legislative proposals and a statement to a legislature. It is not legal advice; the bill has not passed and the detail can change. CryptoLicense is the licensing-advisory brand of CL GLOBAL SDN BHD (1421939-T), in business since 2020; the group's Hong Kong entity is Elmbridge Advisory Limited (78559566, registered 1 August 2025), with the records in entity proof. Hong Kong is one of the twelve markets we cover, and we have scoped licence selection for 100+ companies. No application can be guaranteed; the regulator retains full discretion over the outcome and the timing.
Part of a series: the full guide is at licence selection.