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Stablecoins, serving as a crucial bridge between traditional finance and crypto assets, have experienced rapid growth in global financial markets in recent years. The 2022 TerraUSD (UST) collapse triggered heightened concerns among global regulators regarding the systemic risks of stablecoins. The EU pioneered a unified regulatory framework through the MiCA regulation, the US pushed for the GENIUS Act, and Singapore's MAS released its stablecoin regulatory framework—major global financial centers are accelerating their stablecoin legislation processes. Hong Kong, as an international financial center, has also actively responded to this trend, officially implementing the Stablecoin Ordinance (Cap. 656) on August 1, 2025, becoming one of the first jurisdictions in the Asia-Pacific region to establish a dedicated stablecoin issuer licensing system.
The Stablecoin Ordinance (Cap. 656) established the Hong Kong stablecoin issuer license system, with the Hong Kong Monetary Authority (HKMA) acting as the licensing and regulatory body.
Source: HKMA, Explanatory Note on Licensing of Stablecoin Issuers (July 2025)
Since releasing its discussion paper on crypto assets and stablecoins in January 2022, the Hong Kong Securities and Futures Commission (HKMA) has, after more than four years of policy research, public consultation, and legislative procedures, finally established a comprehensive stablecoin issuer licensing system. On April 10, 2026, the HKMA officially issued the first two stablecoin issuer licenses to Infintech and HSBC, marking a new stage in Hong Kong's stablecoin regulation.
The core objective of Hong Kong's stablecoin licensing regime is to balance financial innovation and risk management—maintaining monetary and financial system stability while promoting the sustainable development of Hong Kong's virtual asset ecosystem. Initially, the regime focuses on fiat-referenced stablecoins (FRS), which are stablecoins pegged to one or more fiat currencies. These are currently the most widely used type of stablecoin in the market (such as USDT and USDC). The HKMA retains the power to expand its regulatory scope to other types of stablecoins in the future.
| Item | content |
|---|---|
| Licensed issuers | 2 companies (as of April 2026) |
| regulatory agency | HKMA (Hong Kong Monetary Authority) |
| Core laws | Stablecoin Regulations (Cap. 656) |
| Scope of application | Fiat-backed stablecoins (FRS) |
| Minimum capital requirements | HK$2,500 million |
| Annual license fee | HK$113,020 |
| Jurisdiction | regulatory agency | Effective Time |
|---|---|---|
| Hong Kong | HKMA | June 2025 |
| European Union | competent authorities of each member state | June 2024 |
| Singapore | MAS | June 2023 |
| United States | Federal/state regulators | In legislation |
| Japan | FSA | June 2023 |
| United Arab Emirates | VARA/CBUAE | 2024 |
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Understanding the core definitions and key concepts in the Stablecoin Ordinance
Stablecoins are digital representations of value that are protected in a cryptographic manner, (i) expressed in units of account or as a store of economic value; (ii) used or intended to be used as a publicly accepted medium of exchange (for payment of goods or services, settlement of debts or investments); (iii) can be transferred, stored or traded electronically; and (iv) operate on a distributed ledger or similar asset database.
— Article 3 of the Stablecoin Ordinance
Designated stablecoins are those that claim to maintain a stable value solely based on the following assets: (i) one or more fiat currencies; (ii) a unit of account designated by the Hong Kong Monetary Authority (HKMA); and (iii) a store of economic value designated by the HKMA. Currently, the scope of designated stablecoins only covers stablecoins that claim to maintain a stable value solely based on one or more fiat currencies, commonly referred to as "fiat-referenced stablecoins" (FRS).
— Article 4 of the Stablecoin Ordinance + Section 2.2 of the HKMA Summary
| Activity type | Explain |
|---|---|
| Issued in Hong Kong | Issuing designated stablecoins in Hong Kong through business operations |
| Overseas issuance linked to Hong Kong dollar | Issuing designated stablecoins pegged to the Hong Kong dollar through business operations outside of Hong Kong. |
| Actively promote | Actively promoting themselves or appearing to be involved in regulated stablecoin activities to the public. |
Important Note: Even if the stablecoin issuer is located outside Hong Kong, it must apply for an HKMA license if its issued stablecoin is pegged to the Hong Kong dollar. Furthermore, even if the actual issuance activity does not take place in Hong Kong, actively promoting it to the Hong Kong public is considered engaging in regulated activities.
Digital currencies (such as CBDCs) issued by central banks, governments, or their authorized entities.
Limited-use digital tokens as defined in Article 53ZR of AMLO
Securities or futures contracts as defined in Appendix 1 of SFO
PSSVFO defines the floating amount or SVF deposit.
Deposits as defined in the Banking Regulations
Stablecoins pegged to gold, commodities, or crypto assets
| Attributes | Details |
|---|---|
| License Name | Stablecoin Issuer Licence |
| Regulatory laws | Stablecoin Regulations (Cap. 656) |
| regulatory agency | HKMA (Hong Kong Monetary Authority) |
| Scope of application | Fiat currency references stablecoin (FRS) issuance |
| Licence validity period | Valid indefinitely (license fee payable annually). |
| Is an exemption possible? | HKMA may exempt issuers or categories with low risk. |
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Understand the scope of application, judgment criteria, and the offeror system.
No person may engage in or appear to be engaged in regulated stablecoin activities without a license or exemption. Violators are liable to a maximum fine of HK$5,000,000 and imprisonment for up to 7 years, with a daily fine of HK$100,000.
— Article 8 of the Stablecoin Ordinance
The HKMA will adopt a holistic approach, considering all relevant factors to determine whether a stablecoin is "issued in Hong Kong":
The factors mentioned above are not exhaustive or decisive. The HKMA will make a determination based on the specific circumstances of each case.
Factors considered by the HKMA in determining whether something constitutes "aggressive selling":
| Entity type | Is a license required? | Explain |
|---|---|---|
| Companies issuing fiat stablecoins in Hong Kong | need | The core eligible applicants must hold an HKMA license. |
| Companies issuing Hong Kong dollar-pegged stablecoins overseas | need | Even if a business does not operate in Hong Kong, it must be licensed if it is pegged to the Hong Kong dollar. |
| Offshore companies actively promoting stablecoins to Hong Kong residents | need | Active sales practices themselves constitute regulated activities |
| Recognized institutions (banks) | need | A license is required, but the requirement for full capital contribution and certain minimum liability conditions is waived. |
| Platforms that only trade/custody stablecoins | No need | VATP/VA Dealing licenses under the jurisdiction of SFC |
| Companies that issue non-fiat currencies refer to stablecoins | No need | It is not a designated stablecoin and is currently outside the scope of regulation. |
| Small issuers with low risk | It depends on the situation | HKMA may grant exemption at its discretion. |
Licensed stablecoin issuers can only authorize "licensed offerors" to offer (sell) their stablecoins to the public. Licensed offerors include five types of entities:
1
2
3
4
5
— Article 9 of the Stablecoin Ordinance
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The 12 minimum requirements cover aspects such as company status, financial resources, reserve management, and compliance obligations.
The applicant must be a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622) or an authorized institution (bank) incorporated outside Hong Kong. Any non-authorized institution incorporated outside Hong Kong must establish a subsidiary in Hong Kong, with that subsidiary acting as the license applicant.
The applicant must be a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622) or an authorized institution incorporated outside Hong Kong.
— Summary of the Hong Kong Monetary Authority, paragraph 3.2.1
| Claim | Amount/Standard |
|---|---|
| Minimum Paid-up Capital | HK$2,500 million (or equivalent in freely convertible currencies) |
| Minimum quick capital | HK$3 million |
| Excess quick funds | At least equal to 12 months of operating costs |
| Restrictions on the Use of Funds | The portion equivalent to the financial resource requirements can only be used for business activities. |
Recognized institutions (banks) are exempt from the requirement of full payment of share capital.
A white paper must be published, providing comprehensive and transparent information about stablecoins.
The white paper must include: issuer information, stablecoin details, reserve asset management, and issuance/redemption procedures.
Return/distribution mechanism, underlying technology, and related risks
Offers to the public can only be made after the white paper has been published on the website.
Reserve assets and independent audit results must be disclosed regularly.
Information on complaint handling and remediation mechanisms must be provided.
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The core safeguards for stablecoin value pegging: 100% full reserves, asset segregation, and face value redemption.
Reserve asset management is a core pillar of the stablecoin licensing regime. The HKMA requires issuers to maintain an independent reserve asset pool for each designated stablecoin, ensuring that the market value of the reserve assets is never less than the face value of the circulating stablecoin (100% full reserve), and expects issuers to maintain over-collateralization to cope with market volatility.
The Stablecoins Ordinance (Cap. 656) establishes a licensing regime for persons who carry on regulated stablecoin activities in Hong Kong, with the Monetary Authority as the licensing authority.
— HKMA, Explanatory Note on Licensing of Stablecoin Issuers (July 2025)
| Asset type | Requirements/Restrictions |
|---|---|
| cash | Priced in reference currency |
| bank deposits | Expiry date not exceeding 3 months |
| Government/Central Bank Securities | Maturity date not exceeding 1 year, credit rating AA- or above |
| Tokenized assets | Must meet HKMA qualification standards |
| Repurchase Agreement | Collateralized by eligible securities |
The right to redeem is a core right of stablecoin holders. The HKMA requires issuers to ensure that holders have the absolute right to redeem at par value and to process redemption requests within a reasonable timeframe.
| Redemption elements | Claim |
|---|---|
| Redemption rights | Holders have the absolute right to redeem their shares at par value. |
| Processing time limit | Within 1 business day (unless specially approved by the HKMA for a delay) |
| Redemption fees | Unreasonable fees must not be charged. |
| Redemption Barriers | Undue obstacles must not be set up. |
| bankruptcy protection | Holders have the right to dispose of the reserve asset pool proportionally. |
| Redeem currency | Redeemed in reference fiat currency |
100 %
≥ 100%
Over-collateralization is recommended
Currency matching
Reserve assets must be denominated in the reference currency.
Asset segregation
Completely separate from the issuer's own assets
Independent hosting
Custody by a qualified independent custodian
Regular audit
Independent auditors conduct periodic audits
Aiying has extensive experience in virtual asset compliance, providing global clients with a one-stop service from license application to ongoing compliance.
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Complete process guide from pre-application communication to license approval
01
It is recommended to do it 3-6 months in advance.
02
Preparation time depends on the specific case.
03
The review time depends on the complexity of the case.
04
Valid after approval
01. License Application Form (HKMA-specified format)
03. Organizational Chart and Equity Structure Chart
05. Detailed business plan (including financial forecasts)
07. Risk Management Framework Documents
09. IT System and Security Assessment Report
11. External Legal Opinion
13. Recovery Plan and Business Exit Plan
02. Company registration certificate
04. Personal information and suitability assessment data of directors, senior executives, and controlling shareholders.
06. Reserve Asset Management Policies and Procedures
08. AML/CFT Policies and Procedures
10. Stablecoin White Paper Draft
12. Qualification verification of independent auditors
14. Complaint Handling Procedures
The above list of documents is compiled based on the HKMA summary and regulatory guidelines; specific requirements may vary on a case-by-case basis.
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A list of license application fees, annual license fees, and minimum financial resource requirements.
| Expense items | Amount (HK$) | Explain |
|---|---|---|
| License application fee | 113,020 | One-time payment, payable upon application. |
| Annual license fee | 113,020 | Pay annually to maintain the validity of the license. |
| License plate condition change application fee | 56,510 | Pay when applying for a change of license plate conditions |
| License renewal fee | not applicable | The license remains valid and does not require renewal. |
| Requirement type | Amount/Standard | Suitable |
|---|---|---|
| Minimum Paid-up Capital | HK$2,500 million | Non-accredited organizations |
| Minimum quick capital | HK$3 million | All licensed issuers |
| Excess quick funds | ≥ 12 months of operating expenses | All licensed issuers |
| Fully paid-up share capital (approved institution) | Exempt | Recognized institutions (banks) |
The minimum paid-up share capital requirement is HK$25 million (or its equivalent in a freely convertible currency). Authorized institutions are exempt from this requirement.
— Summary of the Hong Kong Monetary Authority, paragraph 3.2.2
License application fee
HK$113,020
Annual license fee
HK$113,020
Minimum Paid-up Capital
HK$25,000,000
Minimum quick capital
HK$3,000,000
HK$28,226,040
Excluding excess quick funds, legal counsel fees, system construction fees, etc.
The fees listed above are only the statutory fees charged by the HKMA. In the actual application process, additional costs such as legal counsel fees, compliance system construction fees, audit fees, and technology development fees must be considered, and the overall investment may be far higher than the amounts mentioned above.
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Post-licensing regulatory requirements, reporting obligations, and penalties for violations
Conduct on-site and off-site inspections, and review ledgers and records.
Reprimand, fine, suspension or revocation of license
Issue instructions requiring the issuer to take or cease specific actions
Request any information and documents related to licensed activities.
| Violations | Maximum penalty |
|---|---|
| Unlicensed operation of regulated stablecoin activities | A fine of HK$5,000,000 + imprisonment for 7 years + a daily fine of HK$100,000 |
| Violation of license conditions | A fine of HK$5,000,000 plus two years' imprisonment |
| Distribution to non-licensed offerees | A fine of HK$5,000,000 plus two years' imprisonment |
| Failure to comply with reserve asset requirements | A fine of HK$5,000,000 plus two years' imprisonment |
| Paying interest on stablecoins | A fine of HK$5,000,000 plus two years' imprisonment |
| Providing false or misleading information | A fine of HK$1,000,000 plus two years' imprisonment |
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Aiying's expert team provides strategic advice based on practical experience.
It is recommended to communicate with the HKMA licensing team 3-6 months before formally submitting the application to understand regulatory expectations and application requirements.
Engage legal and compliance advisors with experience in virtual asset regulation to assist in preparing application materials and establishing a compliance framework.
Issuers of stablecoins issued before the regulations came into effect must submit license applications during the transition period (before October 31, 2025).
The processing time for a license application depends on the complexity of the case. It is recommended to allow sufficient time to prepare application materials and deal with any possible supplementary requirements.
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HKMA-approved stablecoin issuers and latest regulatory updates
Anchorpoint Financial Technology Limited
Standard Chartered Bank (Hong Kong) holds a 50.5% stake and has formed a joint venture with Hong Kong Telecom and Anxi Group.
HKDAP (Hong Kong Dollar Pegged Stablecoin)
Planned for phased launch starting in the second quarter of 2026.
April 10, 2026
One of the first stablecoin issuers to receive a license
Composed of traditional banks, telecommunications companies and Web3 companies
The stablecoin will be pegged to the Hong Kong dollar and will be targeted at retail and institutional users.
The Hongkong and Shanghai Banking Corporation Limited
wholly owned subsidiary of HSBC Group
Hong Kong dollar stablecoin (name to be announced)
Scheduled for release in the second half of 2026
April 10, 2026
One of the first stablecoin issuers to receive a license
The first Global Systemically Important Bank (G-SIB) to receive a license
It will seamlessly integrate with PayMe and HSBC Mobile Banking App.
With the official implementation of the licensing system, the HKMA has begun accepting license applications.
Issuers of stablecoins issued before the regulations came into effect must submit their applications before this date.
The deadline for submitting applications for temporary licenses for existing issuers has passed.
Dingdian Financial Technology and HSBC were among the first to receive stablecoin issuer licenses.
HKMA issued its first two stablecoin issuer licenses to Dingdian Financial Technology and HSBC.
The Stablecoin Regulations have officially come into effect, and the licensing system has begun to be implemented.
HKMA releases supervision guidelines SI-1 to SI-5 and AML/CFT guidelines.
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Frequently Asked Questions about Hong Kong's Stablecoin Issuer Licensing Regime
Currently, the HKMA licensing system only applies to specified stablecoins, namely stablecoins that claim to maintain a stable value entirely based on one or more fiat currencies (fiat-referenced stablecoins, FRS). Stablecoins pegged to gold, commodities, or crypto assets, as well as algorithmic stablecoins, are not currently regulated. However, the HKMA reserves the right to expand its regulatory scope in the future.
Offshore companies that are not recognized institutions cannot directly apply for a Hong Kong stablecoin issuer license. They must register a subsidiary in Hong Kong, which will then act as the license applicant. However, recognized institutions (banks) can apply directly even if they are registered outside of Hong Kong.
Stablecoin issuers that are not authorized institutions must maintain a minimum paid-up capital of HK$2,500 million, a minimum of HK$3 million in quick capital, and excess quick capital equal to at least 12 months of operating expenses. Authorized institutions (banks) are exempt from the paid-up capital requirement.
HKMA does not publish a fixed processing timeline. Processing time depends on the complexity of the case, the completeness and quality of the application materials. It is recommended to communicate with HKMA 3-6 months before formally submitting the application and allow sufficient time to prepare the application materials.
No. The Stablecoin Ordinance explicitly prohibits licensed stablecoin issuers from paying or allowing the payment of any interest on their designated stablecoins. Profits generated from reserve asset management belong to the issuer, not the holders.
Eligible reserve assets include: cash (denominated in the reference currency), bank deposits with a maturity of no more than 3 months, government/central bank securities with a maturity of no more than 1 year and a credit rating of AA- or above, tokenized assets that meet HKMA standards, and repurchase agreements secured by eligible securities. Investments in crypto assets, corporate bonds, stocks, commodities, or derivatives are prohibited.
If a VATP operator only trades or holds stablecoins, they do not need to apply for a stablecoin issuer license (which is governed by the SFC). However, if a VATP operator also issues stablecoins, they must apply for a stablecoin issuer license separately from the HKMA.
Direct operation is not permitted. Even if a license has been obtained in another jurisdiction, a license from the HKMA is still required if engaging in regulated stablecoin activities in Hong Kong (including issuing, issuing, or actively marketing Hong Kong dollar-pegged stablecoins in Hong Kong). There are currently no cross-border recognition arrangements.
Issuers must process redemption requests as quickly as possible, generally within one business day, unless specially approved by the HKMA for an extension. Unreasonable fees or undue obstacles must not be charged.
Based on SFC official guidelines and Aiying's practical experience, we provide the most authoritative application guidance.
Detailed self-checklist and document preparation guide to ensure the completeness and accuracy of application materials
100+ successful case experience summary, avoid common pitfalls and improve success rate
Integrate international best practices to ensure the forward-looking and adaptable compliance system
To maximize your success rate, Aiying conducts an internal mock review of your application materials before formal submission. Our expert team acts as a regulator, scrutinizing each document from the most rigorous perspective to identify logical loopholes, data inconsistencies, and compliance gaps in advance.
This mechanism allows us to ensure that the materials submitted to regulators are highly professional, complete, and impeccable, thereby minimizing regulatory inquiry rounds, significantly shortening approval times, and reducing the license rejection rate by 67%.