Ask who regulates digital assets in Hong Kong and the honest answer is four roles, depending on the asset. The Securities and Futures Commission (SFC) licenses trading platforms and authorises funds. The Hong Kong Monetary Authority (HKMA) licenses stablecoin issuers. The Financial Services and the Treasury Bureau (FSTB) is preparing, with the SFC, the law for activities that have no dedicated licence yet. The Government is itself an issuer of tokenised bonds. A counterparty that says it is "regulated in Hong Kong" may be talking about any one of them.

This page maps the regime as it stood on 29 September 2026, with each item marked in force, legislated, consulted on or planned. For how Hong Kong compares with other jurisdictions, see what regulators actually permitted in 2026. This is not legal or investment advice.

Trading platforms: the SFC regime

Licensing and retail access

In force since 1 June 2023. Centralised virtual asset trading platforms need an SFC licence under the Securities and Futures Ordinance and/or the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, in what the SFC calls a dual licence arrangement (SFC circular of 31 May 2023). The SFC's list dated 29 May 2026 shows thirteen licensed platforms, from OSL (licensed December 2020) to Bixin.com (18 May 2026). Check the live list before relying on any name; the SFC says publishing it does not guarantee any platform's performance or creditworthiness.

The rule that matters most to a retail-facing counterparty sits in paragraph 7.8 of the SFC's Guidelines for Virtual Asset Trading Platform Operators (June 2023). To be traded by retail clients, a token should at a minimum be an "eligible large-cap virtual asset": included in at least two acceptable indices issued by at least two different index providers. A token that fails that test is, in general, for professional investors only. The same guidelines require 98% of client virtual assets to be held in cold storage, except in limited circumstances the SFC permits case by case. That figure comes from the June 2023 text; the roadmap below says the SFC intends to move custody towards technology-neutral, outcome-based standards, and on 29 September 2026 the version the SFC publishes as current is still the June 2023 text.

The roadmap, and how far it has travelled

The SFC's ASPIRe roadmap (page last updated 23 September 2025) has five pillars: access, safeguards, products, infrastructure and relationships. It is a statement of intent, not a rule, and carries almost no dates. Its one hard target was that legislative preparations for custodian licensing "aim for completion by end-2025". Consultation conclusions arrived on 24 December 2025, with a target of introducing the bill in 2026; as far as we can find, it has not yet been introduced (see below). Treat the roadmap's remaining items as direction of travel.

Two of its promises have become operational. On 3 November 2025 the SFC issued two circulars:

  • In force, 3 November 2025. Shared liquidity: with the SFC's prior written approval, a licensed platform may combine its order book with that of an affiliated overseas platform, provided orders are fully pre-funded, the overseas platform sits in a FATF member jurisdiction with aligned regulation, trades settle at least once a day on a delivery-versus-payment basis, and a reserve fund of at least the unsettled trade limit is held. Retail clients must give express consent after the overseas settlement risks are explained.
  • In force, 3 November 2025. Expansion of products and services: the 12-month track record requirement is lifted for virtual assets offered to professional investors; platforms may distribute tokenised securities and digital asset-related products, and may apply to offer custody for assets not traded on their own platform.

The roadmap frames new token listings, derivatives, margin financing, staking, and borrowing and lending as services for professional investors, but the circulars since then are not uniform. Staking, in force since 7 April 2025: under the SFC's staking circular, a platform needs the SFC's prior written approval for each blockchain protocol it offers for staking to retail clients, and need only notify the SFC in advance where the service is for professional investors only. Perpetual contracts, framework published 11 February 2026: the SFC's high-level framework says they should only be offered to professional investors, and invites platforms to propose structures. Margin financing, circular of 11 February 2026: circular 26EC5 lets virtual asset brokers that already offer securities margin financing extend credit to those margin clients for virtual asset dealing. Check the current circular for each before assuming what a retail client can access.

Stablecoins: the HKMA regime

Legislated and in force since 1 August 2025. The Stablecoins Ordinance began operating on that date, per the Government's notice of 6 June 2025. It requires a licence, under section 15, for regulated stablecoin activities, while professional investors may receive specified stablecoins from unlicensed issuers. A law firm summary lists a minimum of HK$25 million in paid-up capital, reserve assets whose market value is at all times at least equal to the par value of coins in circulation, and redemption without unduly burdensome conditions or unreasonable fees (CMS, 6 June 2025). The same summary says the Ordinance reaches coins that purport to maintain a stable value against the Hong Kong dollar, wherever they are issued.

Licences granted, 10 April 2026. The HKMA granted the first two, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. The release says the licensees intend to launch business "in the coming few months" and says nothing about further licences. The HKMA's register of licensees, last revised on 23 April 2026, still listed only these two when we checked on 29 September 2026.

Licensing is not launching. CoinDesk, which describes Anchorpoint as a joint venture between Standard Chartered, Animoca Brands and HKT, reported on 12 August 2026 that it had begun a limited beta rollout of HKDAP, a Hong Kong dollar token, for institutional and professional investors through HashKey Exchange and OSL, with retail access possible "as early as the end of 2026". We found no confirmed HSBC launch.

In force, 27 May 2026. The SFC's circular 26EC26 deals with "Relevant Stablecoins": specified stablecoins issued by an issuer licensed under the Ordinance. For those coins, the SFC says the liquidity and index requirements for retail trading need not apply, so the two-index test above falls away. Platforms must still disclose the stabilisation mechanism and redemption arrangements, consider suitability when they recommend, and notify the SFC in advance before admitting, suspending or removing a coin. Knowledge assessment is not required for clients served only in Relevant Stablecoins. The circular refers to a companion HKMA circular issued the same day. The November 2025 circular had already exempted licensed issuers' coins from the track record requirement and opened them to retail.

For what these instruments are and are not, see the institutional view of stablecoins; for the conversion question, onchain FX.

Dealing, custody, advice and management: the bill

Consulted on, concluded, not legislated. Dealing and custody consultation conclusions were published on 24 December 2025 after 101 submissions on dealing and 93 on custody. The dealing regime "will largely align with" Type 1 dealing in securities. The custodian regime "will focus on managing risks relating to safekeeping private keys of client VAs in Hong Kong". The same day the FSTB and SFC opened a further consultation on advisory and management regimes, which ran to 23 January 2026 and concluded on 26 May 2026, with majority support and scopes aligned to Type 4 (advising on securities) and Type 9 (asset management) under the "same activity, same risks, same regulation" principle.

The stated plan, repeated on 26 May 2026 and in a Legislative Council background brief for the Panel on Financial Affairs meeting of 1 June 2026, is to introduce a single bill covering all four types of provider into the Legislative Council within 2026. As at 29 September 2026 we found no Government notice that it has been gazetted or introduced; verify against the Legislative Council record. JSM reports that the authorities do not plan transition or deeming arrangements for existing providers, though they will allow for the time firms need to adjust when setting commencement dates (JSM, January 2026). Stephenson Harwood reports the same for advisers and managers: they must be licensed from commencement (Stephenson Harwood, July 2026).

The licence categories the bill would create do not yet exist. For an institution using an over-the-counter desk or a custodian in Hong Kong, which licence the counterparty actually holds today is a diligence question this page cannot answer. Our note on who actually holds the asset covers the questions to ask.

Tokenised products and spot ETFs

Spot virtual asset ETFs: in force. The first six bitcoin and ether spot ETFs listed on 30 April 2024, from Bosera, China Asset Management (Hong Kong) and Harvest. Christina Choi, the SFC's Executive Director, Investment Products, at the time, said at the listing that they differ from overseas products by offering in-kind subscription and redemption, and that authorisation "is by no means tantamount to endorsing" the underlying assets. The Investor and Financial Education Council's page, last updated 27 October 2025, lists bitcoin, ether and solana as held by authorised spot ETFs, and says intermediaries will assess an investor's knowledge before a trade. The creation and redemption mechanics are in our piece on ETF plumbing.

Tokenised investment products: partly in force, partly planned. The November 2025 circular lets licensed platforms distribute tokenised securities. In the 2026 Policy Address (paragraph 49) the SFC is to "improve the regulatory framework for tokenised investment products", including gold and other real-world assets, and promote trading of regulated stablecoins on licensed platforms. That is a commitment, not a rule. The earlier Policy Statement 2.0 of 26 June 2025, built on the LEAP framework, is likewise policy, not law.

Government tokenised bonds and the settlement layer

Issued. The Government issued tokenised green bonds in 2023 and 2024. The third offering was priced on 10 November 2025 at about HK$10 billion across four currencies: HK$2.5 billion for two years at 2.5%, RMB 2.5 billion for five years at 1.9%, US$300 million for three years at 3.633% and EUR 300 million for four years at 2.512%. The Government's release of 11 November 2025 describes it as the first digital bond offering in the world to integrate tokenised central bank money, with e-CNY and e-HKD offered as a settlement option for the Hong Kong dollar and renminbi tranches. HSBC Orion was the platform. A fourth offering, of around HK$20 billion in the same four currencies, was priced on 28 September 2026 and announced on 29 September; the release calls it a new record for the largest digital bond issuance in the world, and says tokenised deposits, via EnsembleTX, were added to settlement for the Hong Kong dollar tranche.

Pilot, running through 2026. The HKMA's EnsembleTX, announced on 13 November 2025, opened the pilot phase of Project Ensemble for real-value transactions in tokenised deposits, with early focus on tokenised money market fund transactions and real-time liquidity management. That release gave no date for round-the-clock settlement in tokenised central bank money.

Planned, per the Policy Address of 16 September 2026. Chapter 3 says the HKMA will test tokenisation of Exchange Fund Bills by year's end; CMU OmniClear will establish a digital asset platform "this year" for digital bond issuance and settlement; and the HKMA plans central bank digital currency settlement and 24/7 operations under EnsembleTX "by around the end of this year". It also says digital bonds issued in Hong Kong took nearly half of the global market between 2025 and the first half of 2026. None of it is operating yet. For collateral and settlement more broadly, see tokenised collateral and market infrastructure.

Open questions for an institution

  • When does the bill land, and when does it commence? The target has been "2026" since December 2025. If there is no deeming arrangement, as law firms report, counterparties that are unlicensed today face a hard commencement date.
  • Which custody text applies? The guidelines we read require 98% cold storage; the roadmap points to outcome-based standards; the bill will add a separate custodian regime focused on private keys held in Hong Kong. Ask counterparties which they are supervised against.
  • How deep is the licensed stablecoin supply? Two issuers hold licences and, on CoinDesk's reporting, one has a beta product for professionals. A treasury that needs a licensed Hong Kong dollar coin at scale should ask about availability dates, not licence status.
  • Who bears the risk in a shared order book? Liquidity may be pooled with an overseas affiliate whose home rules differ. The SFC's answer is pre-funding, daily settlement and a reserve fund; the residual question is client protection abroad.
  • What is a claim on a tokenised product worth? The SFC allows distribution under existing rules. Settlement finality, legal title and the role of tokenised central bank money are still at pilot stage.
  • Do the year-end promises land? Exchange Fund Bill tokenisation, the CMU OmniClear platform and EnsembleTX settlement are all promised by around the end of 2026.

The regime is real, licensed and moving quickly, and several headline items are still announcements. Keep the four labels beside every claim you read about it, ours included.