Hong Kong
A mandatory VATP licensing regime with prescriptive custody rules and a stablecoin regime alongside it.
Who regulates this
Securities and Futures CommissionSFC
Virtual Asset Trading Platforms under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, plus securities-token activity under the SFO.
Hong Kong Monetary AuthorityHKMA
Stablecoin issuance under the Stablecoins Ordinance.
Licences and permissions
VATP licence
Operating a virtual-asset trading platform in Hong Kong or marketing to Hong Kong investors.
Retail access is permitted only for tokens meeting SFC eligibility criteria, with suitability and knowledge assessments.
What it takes
Capital
HK$5,000,000 paid-up capital and prescribed liquid-capital maintenance, with insurance or a compensation arrangement covering custodied assets.
Timeline
Twelve months or more. External assessment reports form part of the process.
Substance
Hong Kong incorporation, two Responsible Officers, and a local operational footprint.
Where a software vendor sits
The SFC expects a licensed platform to own and control its critical systems, and to evidence that control. A white-label arrangement is workable but is examined closely: expect questions on source-code escrow, change control, and what happens to the venue if the vendor disappears.
What catches people out
The custody rules are among the most prescriptive anywhere — 98% of client virtual assets in cold storage, held through a licensed subsidiary. Architect for that from day one or retrofit painfully.
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