Hong Kong licenses virtual asset trading platforms, and the bar is high. The SFC has licensed 13 platforms. Six applications are pending. Seventeen have been returned, refused or withdrawn — including OKX, Gate.HK, Huobi HK and BitMart. Minimum paid-up capital is HK$5,000,000 and 98% of client assets must sit in cold storage.
Compiled from SFC, HKMA and Hong Kong e-Legislation sources only. Reference, not legal advice.
Key facts
| Regulator | Securities and Futures Commission |
| Instrument | VATP licence — dual regime under the SFO (Cap. 571) and AMLO (Cap. 615) |
| Regime commenced | 1 June 2023; transitional non-contravention period ended 1 June 2024 |
| Regulated activities | Type 1 (dealing in securities) + Type 7 (automated trading services), plus the AMLO virtual asset service |
| Legal form | HK-incorporated company, or overseas company registered with the Companies Registry |
| Paid-up capital | HK$5,000,000 |
| Liquid capital | Higher of HK$3,000,000 and the basic amount, at all times |
| Cold storage | 98% of client virtual assets |
| Responsible Officers | At least two; at least one ordinarily resident in Hong Kong; at least one an executive director |
| Application fee | HK$4,740 per regulated activity, plus HK$4,740 for the VA service |
| Public register | SFC list of licensed VATPs — 13 licensed |
The 13 licensed platforms
| # | Platform | Licensed entity | CE ref | Licensed |
|---|---|---|---|---|
| 1 | OSL Exchange | OSL Digital Securities Ltd | BPJ213 | 15/12/2020 |
| 2 | HashKey Exchange | Hash Blockchain Ltd | BPL992 | 09/11/2022 |
| 3 | HKVAX | Hong Kong Virtual Asset Exchange Ltd | BPW549 | 03/10/2024 |
| 4 | HKbitEX | Hong Kong Digital Asset EX Ltd | BPO721 | 18/12/2024 |
| 5 | Accumulus | Accumulus GBA Technology (Hongkong) Co., Ltd | BUA970 | 18/12/2024 |
| 6 | DFX Labs | DFX Labs Company Ltd | BUN619 | 18/12/2024 |
| 7 | EX.IO | EXIO Ltd | BUT670 | 18/12/2024 |
| 8 | PantherTrade | Panthertrade (Hong Kong) Ltd | BUY578 | 27/01/2025 |
| 9 | YAX | YAX (Hong Kong) Ltd | BUT913 | 27/01/2025 |
| 10 | Bullish | Bullish HK Markets Ltd | BUQ956 | 18/02/2025 |
| 11 | BGE | Hong Kong BGE Ltd | BSI739 | 17/06/2025 |
| 12 | VDX | Victory Fintech Company Ltd | BTF116 | 13/02/2026 |
| 13 | Bixin.com | NewBX Ltd | BUY737 | 18/05/2026 |
Source: SFC lists of virtual asset trading platforms, page self-dated 29 May 2026.
Who did not get in — the more useful list
Seventeen applications have been returned, refused or withdrawn. They include OKX, Gate.HK, Huobi HK (twice), HKVAEX, BitMart, Bitcoin World, HKX, HKDAX, VAEX, Meex, Ammbr, BitHarbour, IBTCEX and QuanXLab, plus an earlier Bybit application. That ratio — 13 through, 17 out — is the single most informative number about this regime, and it is why Hong Kong is not a jurisdiction you apply to speculatively.
Six applications are pending: bitV (HighBlock), Crypto.com (Foris DAX HK), WhaleFin (Whalefin Markets), Matrixport HK (Flying Hippo Technologies), Nebulas and Bybit (Spark Fintech). Three of those — Crypto.com, WhaleFin and Matrixport HK — are “deemed-to-be-licensed” under Schedule 3G of the AMLO. The SFC footnotes that Matrixport HK has ceased VATP business.
Requirements that actually filter applicants
- Custody. 98% of client virtual assets in cold storage (SFC VATP Guidelines).
- Compensation arrangement. SFC-approved cover for 50% of client VA in cold storage and 100% in hot or other storage — via third-party insurance, ring-fenced funds or assets held on trust, or a Hong Kong bank guarantee.
- Capital. HK$5,000,000 paid-up; liquid capital at the higher of HK$3,000,000 and the basic amount, continuously.
- Responsible Officers. Two minimum, one ordinarily resident in Hong Kong, one an executive director (Licensing Handbook).
- Retail token admission. A token offered to retail must be an “eligible large-cap virtual asset” — included in at least two acceptable indices from two different independent index providers, at least one IOSCO benchmark-compliant.
Stablecoins — a separate regime, two licensees
The Stablecoins Ordinance (Cap. 656) took effect 1 August 2025. Issuing fiat-referenced stablecoins in Hong Kong is a licensed activity supervised by the HKMA, with minimum paid-up share capital of HK$25,000,000 (not applicable to authorized institutions).
The HKMA Register of Licensed Stablecoin Issuers, last revised 23 April 2026, lists two: Anchorpoint Financial Limited (FRS01) and The Hongkong and Shanghai Banking Corporation Limited (FRS02), both effective 10 April 2026.
Enforcement
The SFC maintains an alert list of suspicious virtual asset trading platforms. Published actions include a joint SFC–Police warning on MEXC (9 February 2024), which was added to the alert list with police steps to block associated websites, plus warnings on Bybit, Tokencan, VBIT Exchange and HKD.com.
Unable to confirm from primary source as of 7 August 2026: the total number of entries on the alert list (rendered client-side), any published SFC service standard for application processing time, and whether the December 2025 VA dealing and custodian bill has been gazetted. Check the alert list and the e-Gazette.
What changed recently
- 11 February 2026 — SFC opens VA margin financing by licensed brokers and a framework for perpetual and leveraged contracts, professional investors only.
- 24 December 2025 — FSTB and SFC conclude consultations on VA dealing and custodian licensing; a bill is targeted for LegCo in 2026.
- 3 November 2025 — Circular 25EC57 removes the 12-month track-record requirement for professional-investor tokens and for stablecoins from licensed issuers offered to retail.
- 1 August 2025 — Stablecoins Ordinance regime commences.
- 19 February 2025 — SFC publishes the ASPIRe roadmap: 5 pillars, 12 initiatives.
How to apply for a Hong Kong crypto licence: the five stages
Since the SFC’s circular of 17 February 2025, the VATP licence application runs as a single track with one external assessment instead of the old two-phase model. The stages below are the regulator’s own sequence; the timing notes are what licensed applicants and Hong Kong law firms report, not SFC service standards — the SFC publishes none.
- Application bundle. Licence forms for Type 1 and Type 7 under the SFO plus the AMLO virtual asset service, written policies and procedures, the identity of your external assessor and a statement of that assessor’s capability. The application fee is HK$4,740 per regulated activity plus HK$4,740 for the VA service.
- SFC assessment. The SFC reviews business structure, financial resources, the fitness and properness of every Responsible Officer and Manager-in-Charge, and whether it accepts your choice of external assessor. Applications are returned or refused at this stage — that is where most of the 16–17 failed applicants fell out.
- Systems deployment. Build and switch on every control the VATP Guidelines require: 98% cold storage, the compensation arrangement, token admission committee, market surveillance, cybersecurity, AML/CFT screening.
- Tripartite engagement and assessment. You, the external assessor and the SFC sign a tripartite agreement. The assessor then tests the live systems as a direct assurance engagement under HKSAE 3000 (or equivalent). Law firms put this phase at 6–12 months depending on how ready the platform is.
- Report and licence. The assessor’s report goes to the SFC. If findings are closed, the licence is granted and the platform appears on the public list. Bixin.com (NewBX Ltd), licensed 18 May 2026, is the most recent to complete the track.
Realistic total timeline: Hong Kong law firms advise clients to expect at least 12 months from acceptance of the application, with 12–18 months typical for a well-prepared applicant and longer if the SFC contests personnel or the assessor.
What a Hong Kong VATP licence actually costs
| Item | Amount | Source / note |
|---|---|---|
| Application fee | HK$4,740 per regulated activity + HK$4,740 for the VA service (≈ HK$14,220 for Type 1 + Type 7 + VA) | SFC fee schedule |
| Paid-up share capital | HK$5,000,000 | VATP Guidelines |
| Liquid capital | Higher of HK$3,000,000 and the “basic amount”, at all times | VATP Guidelines |
| Operating reserve | Liquid assets equal to 12 months of operating expenses (virtual assets do not count) | VATP Guidelines |
| Compensation arrangement | Cover for 50% of client assets in cold storage and 100% in hot storage — insurance, bank guarantee, escrowed deposits or reserve virtual assets | VATP Guidelines |
| Responsible Officers | Two minimum, one ordinarily resident in Hong Kong — salaried, full-time, licensed individuals | Licensing Handbook |
| External assessor | Not published; a mandatory professional engagement under HKSAE 3000, priced case by case | SFC circular, Feb 2025 |
| Annual licence fees | Charged per regulated activity and per RO under the SFO fee rules; the VA dealing regime’s fees are benchmarked to Type 1 | SFO (Fees) Rules; FSTB/SFC conclusions Dec 2025 |
The regulator’s own fees are trivial. The real cost is the capital you must lock up, twelve months of opex held in liquid assets, two resident ROs on payroll, and the assessor and legal engagements — which is why Hong Kong suits exchanges with a balance sheet, not start-ups looking for a badge.
Coming in 2026: dealing and custodian licences
On 24 December 2025 the FSTB and SFC concluded consultations on two new AMLO licences. A bill is expected in the Legislative Council during 2026, with no transitional or deeming period once it commences — firms that deal in or custody virtual assets in Hong Kong today should open pre-application discussions now.
- VA dealing service provider: HK$5,000,000 paid-up capital, HK$3,000,000 liquid capital; must use SFC-regulated custodians; derivatives and structured products referencing VAs stay under the SFO.
- VA custodian service provider: HK$10,000,000 paid-up capital, HK$3,000,000 liquid capital; covers anyone safekeeping private keys or transfer instruments, including banks; HKMA-licensed stablecoin issuers safekeeping only their own coin and non-custodial wallet providers are exempt.
- Still open: VA advisory and management regimes (further consultation closed 23 January 2026), staking, lending and borrowing rules.
Application checklist
- Hong Kong-incorporated company (or overseas company registered with the Companies Registry)
- HK$5m paid-up capital injected; liquid capital and 12-month opex reserve evidenced
- Two Responsible Officers identified, one ordinarily resident in Hong Kong, one an executive director
- Managers-in-Charge named for all eight core functions
- External assessor appointed, with capability statement
- Compensation arrangement term sheet (insurer, bank guarantee or trust structure)
- Cold-storage architecture for 98% of client assets
- Token admission and review committee charter; retail tokens limited to eligible large-cap virtual assets
- AML/CFT, market surveillance, cybersecurity and business continuity policies
- SFO Type 1 + Type 7 and AMLO VA service application forms, fees paid
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How Hong Kong compares
| Hong Kong | UAE — Dubai | Georgia | European Union | |
|---|---|---|---|---|
| Instrument | VATP licence | VASP licence | Registration | MiCA authorisation |
| Prudential supervision | Yes — heavy | Yes | Expressly excluded | Yes |
| Min. capital | HK$5m paid-up | By category | Not published | €50k–€150k |
| Authorised firms | 13 | 50+ | 42 | Varies by state |
| Rejection rate | 17 out vs 13 in | Not published | 1 cancelled | Not published |
Hong Kong and Georgia sit at opposite ends of the same spectrum. Georgia registers you in 60 days with no prudential oversight; Hong Kong will turn you down. Neither is better — they are different products, and counterparties price them differently.
Frequently asked questions
How many crypto exchanges are licensed in Hong Kong?
Thirteen, per the SFC list last updated 29 May 2026. Six applications are pending and seventeen have been returned, refused or withdrawn.
What capital do you need?
HK$5,000,000 paid-up share capital, plus continuous liquid capital of at least the higher of HK$3,000,000 and the basic amount.
Can retail investors trade crypto in Hong Kong?
Yes, in eligible large-cap tokens only — included in at least two acceptable indices from two independent providers, at least one IOSCO benchmark-compliant.
How much must be in cold storage?
98% of client virtual assets, with an SFC-approved compensation arrangement covering 50% of cold-storage assets and 100% of hot-storage assets.
Who is licensed to issue stablecoins?
Anchorpoint Financial Limited and HSBC, both effective 10 April 2026, per the HKMA register revised 23 April 2026.
Sources
- SFC — lists of virtual asset trading platforms
- SFC — Guidelines for Virtual Asset Trading Platform Operators
- SFC — Licensing Handbook for VATPs
- HKMA — Register of Licensed Stablecoin Issuers
- SFC — suspicious virtual asset trading platforms alert list
All sources retrieved 7 August 2026. Compiled by Vaibhavv Ali from primary regulatory sources. Cryptonite takes no referral fees and has no relationship with any firm named here. Part of the global crypto licensing tracker. Reference only — not legal advice.