2026 year 4 month update

Hong Kong Virtual asset trading platforms (VATP / VASP) license
Application Complete Guide

 

Virtual Asset Trading Platform Licensing Regulations (Hong Kong VATP / VASP license) – A Comprehensive Guide from Dual-License Structure to Compliant Operation

12

VATP licensed (as of February 2026)

✓ Confirmed

HK$500 million

Minimum Paid-up Capital

✓ Confirmed

HK$14,220

Total company application fee (SFO + AMLO)

✓ Confirmed

12 items

ASPIRe Roadmap Initiatives

✓ Confirmed

01 / 11

Hong Kong VATP license (Hong Kong VASP license): From its inception to maturity

A comprehensive review of the evolution and latest developments of the regulatory framework for Hong Kong virtual asset trading platforms.

Origins of the System and the Dual-License Structure

Hong Kong's VATP licensing regime officially came into effect on June 1, 2023, marking Hong Kong as one of the world's first major financial centers to establish a comprehensive regulatory framework for virtual asset trading platforms. This regime employs a unique dual-license structure – operators must simultaneously obtain Type 1 (securities trading) and Type 7 (providing automated trading services) licenses under the SFO, as well as a Virtual Asset Service Provider (VASP) license under the AMLO. This design ensures that VATP is subject to dual regulation under both securities laws and anti-money laundering laws.

Those operating virtual asset trading platform businesses in Hong Kong must now comply with the new dual licensing system for virtual asset trading platform licenses (virtual asset trading platform license Hong Kong), which came into effect on June 1, 2023.

—Part 5B of the Anti-Money Laundering Ordinance

✓ Confirmed
Chart Upward Trend

Current Status of Market Development

As of February 2026, the SFC had issued licenses to 12 VATPs, including OSL Exchange (December 2020, the earliest to be licensed), HashKey Exchange (November 2022), HKVAX, HKbitEX, Accumulus, DFX Labs, and EX.IO (January 2022). The peak period for license issuance was from late 2024 to early 2025, with many platforms receiving approval after the SFC streamlined its approval process. In January 2025, the SFC launched a streamlined approval process, merging the previous two-stage external assessment into a single assessment, significantly accelerating the approval process.

ASPIRe Roadmap and Future Direction

In September 2025, the SFC released the landmark ASPIRe roadmap (Access, Safeguards, Products, Infrastructure, Relationships), outlining 12 initiatives that provide a clear blueprint for the future development of Hong Kong's virtual asset market. This roadmap marks a strategic shift by the SFC from "prudent regulation" to "proactive development," aiming to attract global platforms and liquidity, expand product lines, enhance infrastructure, and maintain robust investor protection.

Tourism Payment Exception

Supervision Timeline

  • June 2018
    SFC Releases VATP Supervision Framework Concept Document
  • June 2019
    SFC releases VATP position paper and regulatory standards
  • June 1, 2023
    The VATP dual-license system has been officially implemented (AMLO Part 5B is in effect).
  • February 29, 2024
    Application deadline for transitional licenses
  • June 1, 2024
    Upon the end of the transition period, unlicensed platforms must cease operations.
  • January 16, 2025
    SFC streamlines VATP approval process (merging external assessments)
  • April 7, 2025
    SFC issues circular on pledging services
  • June 2025
    Update VATP License Manual
  • June 2025
    SFC releases ASPIRe roadmap (12 measures)
  • November 3, 2025
    SFC releases circular on product expansion and shared order book
  • December 24, 2025
    Release VA Dealing and VA Custody Consulting Summary

key data

VATP licensed

12 companies (as of February 2026)

Dual license structure

SFO Type 1 + Type 7 + AMLO VASP

regulatory agency

SFC (Securities and Futures Commission)

Core laws

SFO (Cap. 571) + AMLO (Cap. 615)

ASPIRe Initiative

12 items (5 pillars)

02 / 11

What is a VATP license?

Gain a thorough understanding of the legal definition, dual-license structure, and related entity requirements for virtual asset trading platforms.

Legal definition of Virtual Asset Trading Platform (VATP)

Providing services through electronic facilities in a business manner such that (i) offers to buy or sell virtual assets are frequently made or accepted, thereby forming or resulting in a binding transaction; or (ii) individuals are frequently introduced or identified to negotiate or enter into transactions involving the buying or selling of virtual assets; and customer funds or customer virtual assets are directly or indirectly in the control of the service provider.

— AMLO Article 53ZRA

✓ Confirmed
文件 (1)

Dual license structure

VATP operators must hold two licenses simultaneously because virtual asset transactions involve two different legal frameworks:

Licensing Laws Licence type Coverage
Securities Law Level SFO (Cap. 571) Type 1 + Type 7 Trading activities involving security tokens
Anti-money laundering law level AMLO (Cap. 615) VASP License All virtual asset trading activities

Important Notes: Even if a platform only trades non-security virtual assets (such as BTC and ETH), it must still hold both an SFO and an AMLO license. The SFC imposes licensing conditions upon issuance, requiring platforms to comply with all requirements of the VATP Guidelines.

✓ Confirmed

Associated Entity

Each VATP must host customer virtual assets through its associated entity. The associated entity must meet the following conditions:

Demand analysis and consulting

SFC has been notified that it has become an associated entity of VATP.

Signing Mou and launching an investigation

Incorporated in Hong Kong

Complete the investigation and sign the Spa

Holding a Trust or Corporate Service Provider License (TCSP) under AMLO

Regulatory applications and approvals

It is a wholly owned subsidiary of VATP

✓ Confirmed

Key attributes

Attributes Details Certainty
License Name SFO Type 1 + Type 7 + AMLO VASP Confirmed
Regulatory laws SFO (Cap. 571) + AMLO (Cap. 615) Confirmed
regulatory agency SFC (Securities and Futures Commission) Confirmed
Core Business Operating a virtual asset trading platform + over-the-counter trading + ancillary services Confirmed
Licence validity period Valid indefinitely (annual fee required; SFC reserves the right to suspend/revoke). Confirmed
Related entity requirements A wholly-owned subsidiary holding a TCSP license, responsible for VA (Visa) hosting for clients. Confirmed
external evaluation An external assessor must be engaged to conduct a comprehensive evaluation (later in 2025). Confirmed

03 / 11

Who needs to apply for a VATP/VASP license?Who needs a VATP / VASP licence?

Understand which entities need to apply for a license, and in what situations can they be exempted.

Marketplaces

Centralized virtual asset trading platform

✓ Confirmed
  • A platform that facilitates the buying and selling of VA through electronic facilities
  • Including spot trading, cryptocurrency trading, etc.
  • Regardless of whether it involves security tokens, a license is required.
Derivatives

Over-the-counter trading platforms (including electronic matching)

✓ Confirmed
  • Providing VA over-the-counter trading matching services through electronic facilities
  • Customer funds or VA are managed by the platform.
  • Pure VA (over-the-counter) dealers will be regulated separately under the new licensing system.
Global 1

Overseas trading platforms (for Hong Kong investors)

✓ Confirmed
  • Overseas platforms actively promoting VA trading services to the Hong Kong public
  • Even if no entity is established in Hong Kong, a license is still required.
  • SFC has added several unlicensed platforms to its suspicious list.

Traditional financial institutions (planning to expand VA transactions)

Pending confirmation
  • Traditional financial institutions such as banks and securities firms that intend to operate VA trading platforms
  • A VATP license is required.
  • Existing compliance frameworks can be leveraged

Exemption List

Exemption type Details Certainty
Non-custodial trading Pure information matching platform that does not involve customer funds or VA (Value Added) transactions. Confirmed
Decentralized exchange A truly decentralized DEX (without a centralized operator controlling customer assets). To be confirmed
peer-to-peer trading A P2P platform that only provides information dissemination, does not facilitate transactions, and does not handle customer assets. To be confirmed
Securities/Futures Trading Platforms that only trade securities and futures contracts (excluding VA) (subject to other terms of the SFO). Confirmed
09 Warning
SFC Suspicious Platform List

The SFC maintains and regularly updates a list of suspicious virtual asset trading platforms, listing unlicensed platforms that may provide services to Hong Kong investors. Investors should only use SFC-licensed VATPs for trading. The SFC also maintains a list of closed/soon-to-be-closed VATPs, listing platforms that were required to cease operations during the transition period due to lack of a license.

✓ Confirmed

04 / 11

VATP license business scope

Understand the core business that a licensed VATP can conduct and the new authorized activities for 2025.

生产过程

Core Business

Activities Explain Certainty
Platform transactions Operate a centralized virtual asset trading platform to facilitate buying and selling transactions. Confirmed
over-the-counter transactions Provide clients with off-platform VA trading services Confirmed
Ancillary services Ancillary services related to platform trading and over-the-counter trading Confirmed
Customer VA Hosting Hosting VA (cold and hot wallet storage) for customers through associated entities Confirmed

New licensing activities in 2025

The following activities, which are newly added or explicitly permitted in the 2025 SFC circular, require prior written approval from the SFC:

New activities Circular date Explain Certainty
Staking service April 7, 2025 Allowing VATP to provide pledging services to clients requires prior written approval from the SFC, and requires VATP to maintain possession or control of the client's VA. Confirmed
Shared order book November 3, 2025 Sharing of order books with overseas affiliates (VATPs regulated locally) requires prior approval from the SFC. Confirmed
Distribute digital asset investment products November 3, 2025 Allowing the distribution of investment products and tokenized securities with exposure to digital assets Confirmed
Extended Hosting Services November 3, 2025 Allow affiliated entities to provide custody services for VA and tokenized securities traded outside the platform. Confirmed

Token Listing Rules Update (Circular of November 3, 2025)

  • Professional investors:The requirement for VA (including stablecoins) to have a trading record for the 12 months prior to listing has been removed.
  • Retail investors (stablecoins):Stablecoins issued by licensed stablecoin issuers can be traded directly with retail investors without requiring a 12-month record.
  • Retail investors (other VA):The requirement of 12 months of transaction history must still be met.
  • Tokenized securities and digital securities:The 12-month transaction record requirement does not apply.
  • New disclosure obligations:The website and app must disclose which VAs have failed to meet the 12-month record requirement and enhance risk disclosure.
✓ Confirmed

VATP can provide staking services only if the following conditions are met:

  • Prior written approval from the SFC is required.
  • The entity must maintain possession or control of all mediums through which customer VA can be withdrawn from the staking service.
  • VA clients who do not allow third-party escrow to participate in pledging
  • Due diligence on blockchain protocols is required.
  • Clients must be informed of: specific VA types, third-party participants, fees, minimum lock-in period, and release procedures.
    Locking process, interruption arrangement
  • Risks to be disclosed include: slashing risk, lockout risk, blockchain technology error/vulnerability risk, hacking risk, and validator inactivity risk.
✓ Confirmed

VATP must meet the following conditions to share its order book with overseas affiliates:

  • Prior written approval from the SFC is required.
  • It can only be shared with 'affiliated companies', i.e., overseas VATP operators.
  • Overseas VATP must be regulated by local regulatory authorities.
  • VATP Hong Kong assumes full responsibility for its clients' transactions.
  • A comprehensive risk control framework must be established.
  • Platform trading requirements must be met as outlined in the VATP Guidelines.
✓ Confirmed

05 / 11

VATP license application requirements

A comprehensive understanding of financial resources, personnel qualifications, technical security, and compliance requirements.

Claim Amount of money Explain
Minimum Paid-up Capital HK$500 million SFO and AMLO dual requirements
Minimum quick capital ≥ HK$500 million (variable quick funds) Take the higher of HK$3 million and the basic amount.
Base amount Calculated by FRR Calculated according to the Securities and Futures (Financial Resources) Rules
Continue to maintain Be Must maintain at least the required quick funds at all times

important hint:VATP requires a "variable quick capital" model, meaning the required quick capital = max(HK$3 million, basic amount). The basic amount is calculated based on FRR and will vary with the scale of business.

✓ Confirmed

The following personnel must pass the SFC's appropriate candidate assessment:

  • License applicant (company)
  • Substantial Shareholders
  • Responsible Officers
  • Licensed Representatives

When evaluating suitable candidates, the SFC will consider:

  • Financial condition or solvency
  • Education or other qualifications or experience
  • Can they conduct related activities in a competent, honest, and fair manner?
  • Reputation, character, reliability and financial integrity
✓ Confirmed
Claim Details
Minimum number of people At least two Operations Representatives (ROs) (at least one of whom must be fully competent)
Eligibility Requirements It must be submitted via LE Paper 1 and Paper 2 (within 3 years prior to application).
Regulatory experience At least one RO must have experience in the virtual asset industry.
Hong Kong-based requirements ROs must be based in Hong Kong and effectively supervise operations.
✓ Confirmed

VATP must designate managers-in-charges for the following core functions:

  • Overall management and supervision
    Senior management responsible for the overall operation of VATP
  • Key business lines
    Responsible for core businesses such as transaction matching and market monitoring.
  • Operational control and review
    Responsible for internal control and compliance review
  • Risk Management
    Responsible for risk identification, assessment and management
  • Finance and Accounting
    Responsible for financial reporting and capital adequacy
  • Information Technology
    Responsible for technical systems and network security
  • Compliance
    Responsible for regulatory compliance and AML/CFT
  • anti-money laundering and counter-terrorist financing
    Responsible for AML/CFT policies and procedures
✓ Confirmed
  • Robust trading systems and infrastructure
  • Network security audit and penetration testing
  • Customer VA hosting arrangement (through affiliated entities, 98% cold storage / 2% hot storage)
  • Insurance or compensation arrangements (50% for cold storage + 100% for hot storage)
  • Market monitoring system (to prevent market manipulation and insider trading)
  • Business continuity and disaster recovery plan
  • External assessment: An external assessor (EA) must be engaged to assess all relevant systems and controls.

ASPIRe Update: The SFC, in its ASPIRe roadmap, proposes exploring more flexible dynamic hosting technologies and storage ratio methodologies, as well as enhancing the insurance and compensation framework. This implies that the 98/2 cold/hot storage ratio and the 50% compensation requirement may be adjusted in the future.

✓ Confirmed ◐ Proposed
  • Compliance with the AML/CFT requirements in Annex 2 of AMLO
  • Customer due diligence (CDD) and ongoing monitoring
  • Suspicious Transaction Report (STR)
  • Records must be kept (for at least 5 years).
  • Sanctions screening
  • Travel Rule Compliance (VA Transfer Information Transmission)
  • Designated MLRO (Money Laundering Reporting Officer)
✓ Confirmed

06 / 11

How do I apply for a VATP license?

A complete guide from pre-application preparation to license issuance

Phase 1 – Pre-Application Consultation

✓ Confirmed
  • Contact SFC (fintech@sfc.hk) to initiate a pre-application consultation.
  • Develop business plans and operational strategies
  • Establish corporate governance structure and staffing
  • Deployment of trading systems, custody systems, and security controls
  • Develop AML/CFT policies and procedures
Process line

Phase 2: Hiring an External Evaluator (EA)

✓ Confirmed
  • Identify suitable external appraisers (who must be practicing certified public accountants).
  • EA must obtain SFC approval.
  • Sign a tripartite agreement (SFC, Applicant, EA)

Phase 3: Submitting the application through the WINGS system

✓ Confirmed
  • Submit license application through SFC's WINGS electronic platform
  • Submit all necessary application forms, supplementary documents, and questionnaires.
  • Pay the application fee (total HK$14,220 for the company).

Phase 4: External Assessment (A Comprehensive Assessment)

✓ Confirmed
  • EA evaluates all relevant systems and controls (which will be streamlined and consolidated into a single evaluation in January 2025).
  • Scope of assessment: Appropriateness of the design and implementation of policies, procedures, systems, and controls.
  • SFC, as a participant in the agreement, oversees the evaluation process.
  • EA submitted a comprehensive evaluation report.

Phase 5: SFC Review

✓ Confirmed
  • SFC reviews application materials and external evaluation reports.
  • Additional information or on-site inspection may be required.
  • Assess the qualifications of suitable candidates
  • The processing time depends on the quality and complexity of the application.

Phase 6: Issuance of License

✓ Confirmed
  • Obtain SFO Type 1 + Type 7 + AMLO VASP licenses
  • SFC imposes standard licensing conditions
  • The first annual compliance report must be submitted within 18 months of obtaining the license.

Streamlined review process (Updated January 2025)

✓ Confirmed

On January 16, 2025, the SFC issued a circular significantly streamlining the VATP approval process:

Changes Old process New process
external evaluation Two phases (Phase 1 + Phase 2) One-time comprehensive assessment
Assessment Report Two independent reports A comprehensive report
EA Selection Applicants choose themselves SFC participates in supervision
Tripartite Agreement No SFC, Applicant, and EA Tripartite Agreement

Standard license conditions

  • Comply with all requirements of the VATP Guidelines at all times.
  • Maintain at least the required quick capital or minimum paid-up share capital.
  • Submit a business activity report to the SFC monthly (within two weeks after the end of the month).
  • Engage an independent professional organization to conduct an annual compliance review
  • Any new services, activities, or major changes must be approved in writing by the SFC in advance.
  • Operating only a centralized online VA trading platform and over-the-counter trading and related services.
✓ Confirmed

07 / 11

Costs and Capital Requirements

A comprehensive understanding of all fees and ongoing capital requirements for a VATP license application.

Application Fee

Fee type SFO license AMLO license Certainty
Company application fee HK$5,070 HK$9,150 Confirmed
Application fee per RO HK$1,790 Confirmed
LR application fee per person HK$860 Confirmed
文件 (1)

Annual Fee

Fee type SFO license AMLO license Certainty
Company annual fee HK$5,340 HK$12,200 Confirmed
Annual fee per RO HK$3,050 Confirmed
Annual fee per LR HK$1,790 Confirmed
Chart Upward Trend

Hidden costs (industry estimates)

Cost items estimation range Certainty
External assessment fees HK$200 million - HK$500 million+ To be confirmed
Legal advisory fees HK$100 million - HK$3 million+ To be confirmed
Technical system construction HK$500 million - HK$2,000 million+ To be confirmed
Compliance team annual salary HK$3 million - HK$800 million+ To be confirmed
insurance cost HK$100 million - HK$500 million+ per year To be confirmed
First year total investment estimate HK$2,000 million - HK$5,000 million+ To be confirmed

Capital Requirements Overview

Minimum Paid-up Capital

SFO + AMLO dual requirements

HK$500 million

Minimum quick capital

Variable quick capital model

≥ HK$500 million


Cold storage ratio

Customer VA's cold storage requirements

≥ 98%

Cold storage compensation

Insurance or compensation arrangements

≥ 50%

Thermal storage compensation

Insurance or compensation arrangements

100 %

Aiying's Tip

While the official application fee for an SFC license is relatively low (approximately HK$14,220 for the entire company), the actual total cost of the license application is much higher. External assessments, legal counsel, technical system setup, and a compliance team are the main hidden costs. Applicants are advised to conduct thorough financial planning before initiating the application process and to allocate at least HK$2,000 million in initial budget for the first year.

Pending confirmation

08 / 11

Continuing compliance obligations

Post-license obligations, oversight mechanisms, and consequences of violations

Centralized virtual asset trading platform

  • Monthly business activity report (to be submitted within two weeks after the end of the month)
  • Annual audited financial statements (within 4 months after the end of the fiscal year)
  • Annual compliance review report (first time: within 18 months of obtaining license)

Obligation to notify immediately

  • Major cybersecurity incidents (must be notified to the SFC immediately)
  • Major system failure or interruption
  • Changes in key personnel (RO, MIC, etc.)
  • Major business changes or new services
  • Any event that may affect the license eligibility
Shield 1

Ongoing compliance requirements

  • Maintain minimum paid-up capital and quick capital
  • Continue to comply with AML/CFT requirements
  • Maintain the client's VA managed storage arrangement (98% cold storage)
  • Maintain insurance or compensation arrangements
  • Regularly conduct network security audits and penetration tests.
Transparency

SFC oversight power

  • On-site inspection and off-site monitoring
  • Information and documents are required.
  • Imposing additional licensing conditions
  • Suspension or revocation of license
  • Disciplinary action (public reprimand, fines, etc.)

Consequences of violations

Violations Punishment Certainty
VATP operating without a license Criminal offence: HK$500 million fine + 7 years imprisonment Confirmed
Violation of AML/CFT requirements A fine of HK$1 million plus two years imprisonment Confirmed
Violation of license conditions SFC may suspend/revoke license and impose disciplinary action. Confirmed
Providing false/misleading information Criminal offenses: fines + imprisonment Confirmed

Compliance Calendar

per month
Submit monthly business activity reports

Within two weeks after the end of the month

Per year
Submit audited financial statements

Within 4 months after the end of the fiscal year

Per year
Annual Compliance Review Report

First time: within 18 months of obtaining the license

Immediately
Important Event Notice

Immediately after the incident

09 / 11

License strategy selection

Choose the most suitable market entry strategy based on the company's resources and objectives.

Strategy A: Apply for a VATP license directly

Suitable for: Companies with ample funding, mature technology, and compliance teams

✓ Confirmed
Advantage

✓ Complete business scope
✓ Brand reputation and market trust
✓ Available directly to retail and professional investors

challenge

✕ High initial investment (HK$2,000 million+)
✕ Lengthy review period
✕ Strict continuous compliance requirements

Strategy B: Acquire existing licensed VATP

Suitable for: Companies that want to enter the market quickly and have acquisition capabilities.

Pending confirmation
Advantage

✓ Shorten the time to market
✓ Existing compliance framework and technology system
✓ May retain existing customer base

challenge

✕ The acquisition price may be very high.
✕ Change of control requires SFC approval
✕ Potential compliance issues arising from historical inheritance

Strategy C: Collaborate with licensed VATP

Suitable for: Companies that want to enter the market with low costs

Pending confirmation
Advantage

✓ Low upfront investment
✓ No need to apply for a license yourself
✓ Flexible cooperation models

challenge

✕ Business scope is limited
✕ Dependence on partners
✕ Profit sharing

Strategy D: Apply for other relevant licenses

Suitable for: Businesses that do not need to operate a trading platform

◐ Proposed
Advantage

✓ Lower application threshold
✓ Focus on specific business
✓ Faster approval speed

challenge

✕ Cannot operate a trading platform
✕ Limited business scope
✕ Multiple licenses may be required

10 / 11

Continuing compliance requirements after obtaining a license

Continuing compliance obligations

12

Licensed Platform

6

Listed Company Background

Suitcase, bag, handbag, luggage bag

5+

Annual Supervision Experience

Chart Upward Trend

100 %

Covering mainstream VA

OSL Exchange

✓ Confirmed

OSL Digital Securities Limited
OSL Digital Securities Co., Ltd.

BPJ213

December 15, 2020

OSL Group (863.HK)

  • Hong Kong's first licensed virtual asset trading platform
  • Provides digital asset brokerage, custody, trading and SaaS services
  • First profit in fiscal year 2024 (HK$4,700 million - HK$5,200 million)

HashKey Exchange

✓ Confirmed

Hash Blockchain Limited

GLP992

November 9, 2022

HashKey Group

  • Certified by ISO 27001 and ISO 27701
  • Provides comprehensive trading services for retail and professional investors
  • Launching Hong Kong's first VA multi-strategy fund in partnership with Virtual Seed

HKVAX

✓ Confirmed

Hong Kong Virtual Asset Exchange Limited
Hong Kong Virtual Asset Exchange Limited

BPW549

October 3, 2024

HKVAX Group

  • Focus on STO and RWA tokenization
  • Offers OTC trading, 24/7 trading platform and custody services
  • Signed a memorandum of understanding with Victory Securities

HKbitEX

✓ Confirmed

Hong Kong Digital Asset EX Limited
Hong Kong Digital Assets Exchange Group Co., Ltd.

BPO721

December 18, 2024

Tykhe Capital Group

  • Plans to expand automated trading and OTC services
  • Covering mainstream virtual assets such as BTC and ETH
  • Provide automated trading services for tokenized products

Accumulus

✓ Confirmed

Accumulus GBA Technology (Hongkong) Co., Limited
Cloud Account Greater Bay Area Technology (Hong Kong) Limited

BUA970

December 18, 2024

Cloud Account Technology (China) Co., Ltd.

  • Expanding Web 3.0 technologies, including blockchain and decentralized systems.
  • The parent company is a leading flexible staffing platform in China.
  • Greater Bay Area Technology Finance Layout

DFX Labs

✓ Confirmed

DFX Labs Company Limited

December 18, 2024

DFX Labs

  • Focus on liquidity provision and wallet services
  • Provide secure storage solutions for virtual assets
  • A bridge between traditional finance and digital asset markets

EX.IO

✓ Confirmed

EXIO Limited

December 18, 2024

Thousand Whales Technology

  • Focus on cryptocurrency trading services
  • Serving individual and institutional investors
  • Emphasis on liquidity and security

PantherTrade

✓ Confirmed

Panthertrade (Hong Kong) Limited
Cheetah Trading (Hong Kong) Limited

January 27, 2025

Futu Holdings

  • Futu Holdings' virtual asset trading brand
  • Supports buying, selling, transferring, and storing BTC and ETH.
  • For advanced traders and crypto beginners

NEAR

✓ Confirmed

YAX (Hong Kong) Limited

January 27, 2025

Tiger Brokers

  • Tiger Brokers' virtual asset platform
  • Provide cryptocurrency custody and trading services
  • Approval of retail business license

Bullish

✓ Confirmed

Bullish HK Markets Limited

BUQ956

February 18, 2025

Bullish Group

  • Platforms that will obtain licenses for the first time in 2025
  • Provide digital asset exchange services
  • Safe and compliant trading environment

BGE

✓ Confirmed Limited access

Hong Kong BGE Limited

BSI739

June 17, 2025

HKE Holdings (listed on the Hong Kong Stock Exchange)

  • Platforms under Hong Kong Stock Exchange listed companies
  • Currently in the limited access phase
  • Open only to specific users

VDX

✓ Confirmed

Victory Fintech Company Limited
Victory Digital Technology Co., Ltd.

BTF116

February 13, 2026

Victory Securities

  • The first approved platform in 2026
  • Provide VA infrastructure for licensed financial institutions
  • Helping financial institutions provide customers with virtual asset capabilities

OSL Exchange

✓ Confirmed

OSL Digital Securities Limited
OSL Digital Securities Co., Ltd.

BPJ213

December 15, 2020

OSL Group (863.HK)

  • Hong Kong's first licensed virtual asset trading platform
  • Provides digital asset brokerage, custody, trading and SaaS services
  • First profit in fiscal year 2024 (HK$4,700 million - HK$5,200 million)

HashKey Exchange

✓ Confirmed

Hash Blockchain Limited

GLP992

November 9, 2022

HashKey Group

  • Certified by ISO 27001 and ISO 27701
  • Provides comprehensive trading services for retail and professional investors
  • Launching Hong Kong's first VA multi-strategy fund in partnership with Virtual Seed

HKVAX

✓ Confirmed

Hong Kong Virtual Asset Exchange Limited
Hong Kong Virtual Asset Exchange Limited

BPW549

October 3, 2024

HKVAX Group

  • Focus on STO and RWA tokenization
  • Offers OTC trading, 24/7 trading platform and custody services
  • Signed a memorandum of understanding with Victory Securities

HKbitEX

✓ Confirmed

Hong Kong Digital Asset EX Limited
Hong Kong Digital Assets Exchange Group Co., Ltd.

BPO721

December 18, 2024

Tykhe Capital Group

  • Plans to expand automated trading and OTC services
  • Covering mainstream virtual assets such as BTC and ETH
  • Provide automated trading services for tokenized products

Accumulus

✓ Confirmed

Accumulus GBA Technology (Hongkong) Co., Limited
Cloud Account Greater Bay Area Technology (Hong Kong) Limited

BUA970

December 18, 2024

Cloud Account Technology (China) Co., Ltd.

  • Expanding Web 3.0 technologies, including blockchain and decentralized systems.
  • The parent company is a leading flexible staffing platform in China.
  • Greater Bay Area Technology Finance Layout

DFX Labs

✓ Confirmed

DFX Labs Company Limited

December 18, 2024

DFX Labs

  • Focus on liquidity provision and wallet services
  • Provide secure storage solutions for virtual assets
  • A bridge between traditional finance and digital asset markets

EX.IO

✓ Confirmed

EXIO Limited

December 18, 2024

Thousand Whales Technology

  • Focus on cryptocurrency trading services
  • Serving individual and institutional investors
  • Emphasis on liquidity and security

PantherTrade

✓ Confirmed

Panthertrade (Hong Kong) Limited
Cheetah Trading (Hong Kong) Limited

January 27, 2025

Futu Holdings

  • Futu Holdings' virtual asset trading brand
  • Supports buying, selling, transferring, and storing BTC and ETH.
  • For advanced traders and crypto beginners

NEAR

✓ Confirmed

YAX (Hong Kong) Limited

January 27, 2025

Tiger Brokers

  • Tiger Brokers' virtual asset platform
  • Provide cryptocurrency custody and trading services
  • Approval of retail business license

Bullish

✓ Confirmed

Bullish HK Markets Limited

BUQ956

February 18, 2025

Bullish Group

  • Platforms that will obtain licenses for the first time in 2025
  • Provide digital asset exchange services
  • Safe and compliant trading environment

BGE

✓ Confirmed Limited access

Hong Kong BGE Limited

BSI739

June 17, 2025

HKE Holdings (listed on the Hong Kong Stock Exchange)

  • Platforms under Hong Kong Stock Exchange listed companies
  • Currently in the limited access phase
  • Open only to specific users

VDX

✓ Confirmed

Victory Fintech Company Limited
Victory Digital Technology Co., Ltd.

BTF116

February 13, 2026

Victory Securities

  • The first approved platform in 2026
  • Provide VA infrastructure for licensed financial institutions
  • Helping financial institutions provide customers with virtual asset capabilities

Source: Hong Kong Securities and Futures Commission website(SFC VATP Lists)Last updated: February 16, 2026

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FAQs

Frequently Asked Questions about Hong Kong VATP License Application

SFC does not have a fixed approval timeline. Based on the experience of licensed platforms, it typically takes 6-18 months from application submission to license issuance, depending on the completeness of the application materials, the progress of the external assessment, and the SFC's review speed. After streamlining the review process in January 2025, the review speed is expected to increase.

Pending confirmation

Yes. Even if a company already holds an SFO Type 1 or Type 7 license, it still needs to apply for an additional VASP license under AMLO if it wants to operate a VATP, and add the VATP-related licensing conditions to its existing SFO license.

✓ Confirmed

Yes. Licensed VATPs can serve both retail and professional investors, but must comply with different investor protection requirements. For example, the types of VAs that retail investors can trade may be restricted (requiring a 12-month trading history, excluding stablecoins), and a more stringent suitability assessment may be required.

✓ Confirmed

If a DEX is truly decentralized (i.e., no centralized operator controls customer assets), it may not fall under the regulatory scope of a VATP license. However, the SFC will judge based on substance rather than form—if a platform that claims to be 'decentralized' is actually controlled by a centralized entity, it may still be considered a VATP.

Pending confirmation

External valuation fees vary depending on the scope and complexity of the valuation, with industry estimates ranging from HK$200 million to over HK$500 million. Following the streamlined process in 2025, the total cost may decrease due to the consolidation of valuations into a single assessment. It is recommended to obtain quotes from multiple valuers before applying.

Pending confirmation

VATP licenses (including SFO and AMLO licenses) remain valid and do not require periodic renewal. However, licensees are required to pay an annual fee and continue to comply with all license conditions and compliance requirements. The SFC has the right to suspend or revoke a license if the licensee breaches the conditions.

✓ Confirmed

The ASPIRe roadmap presents positive development opportunities for existing licensed VATPs, including expanding their product lines (derivatives, tokenized securities, etc.), more flexible custody arrangements, shared order books, and staking services. However, it also implies increased compliance requirements and regulatory scrutiny.

◐ Proposed

The unique feature of Hong Kong's VATP license lies in its dual-license structure (SFO + AMLO), meaning the platform is simultaneously regulated by both securities laws and anti-money laundering laws. In contrast, Singapore's MPI license is primarily based on payments law, while Dubai's VASP license is based on specific virtual asset regulations. Hong Kong's regulatory standards are considered among the most stringent globally.

Pending confirmation

About Aiying

Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring 24/7 professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.
Authoritative guidance

Authoritative guidance

Based on SFC official guidelines and Aiying's practical experience, we provide the most authoritative application guidance.

Useful Checklist

Useful Checklist

Detailed self-checklist and document preparation guide to ensure the completeness and accuracy of application materials

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100+ successful case experience summary, avoid common pitfalls and improve success rate

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Integrate international best practices to ensure the forward-looking and adaptable compliance system

Pre-inspection mechanism

Aiying's "pre-screening mechanism"

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.

Through this mechanism, we can ensure that the materials submitted to the regulatory authorities are highly professional, complete and impeccable, thereby minimizing the number of regulatory inquiries and significantly shortening the approval time.And reduced the license rejection rate by 67%.

VATP / VASP Application Path DeterminationVATP / VASP application route: when this licence matters

Not all virtual asset businesses require VATP, but if they involve centralized matching, trading platform operation, or providing virtual asset trading platform services to Hong Kong customers, it is necessary to determine in advance whether they fall within the scope of VATP/VASP licensing.Not every virtual asset business needs a VATP licence. VATP vs VASP should be distinguished carefully: VATP refers to the virtual asset trading platform route, while VASP is the wider AMLO licensing concept. Under the SFC VATP licensing regime, the wider virtual asset trading platform licensing regime and AMLO VASP licensing framework, a Hong Kong crypto exchange license, crypto exchange license Hong Kong, Hong Kong virtual asset exchange license or SFC VATP license becomes relevant when the business operates a centralized virtual asset trading platform, provides order matching, serves Hong Kong investors, or combines virtual asset trading with Type 1 and Type 7 regulated activities.

Businesses suitable for key evaluationBusinesses that should assess VATP / VASP

Centralized trading platforms, virtual asset exchanges, matching systems, trading platforms targeting Hong Kong clients, or Hong Kong gateways to overseas platforms typically require close evaluation.A VASP license application or VATP license application should be assessed for centralized exchanges, crypto trading platforms, electronic matching systems, overseas platforms targeting Hong Kong users and teams searching for a Hong Kong crypto license for exchange operations. The assessment should also distinguish retail virtual asset trading Hong Kong from professional investor virtual asset trading, because client scope affects product, token admission and ongoing compliance expectations.

Not all Web3 services use VATP.Not every Web3 model is a VATP

For wallets, custody, OTC, stablecoins, advisory services, or technical services, the specific license path should be determined separately, including VA Custody, VA Dealing, MSO, stablecoin issuer, or other SFC licenses.Wallet, custody, OTC, stablecoin, advisory and technology-service models may require VA Custody, VA Dealing, MSO, stablecoin issuer licensing or other SFC permissions instead of a Hong Kong VATP license. In practice, the VATP and VASP difference depends on whether the business is operating a trading platform, dealing with customer asset custody, providing OTC execution or only offering technology support.

Check the four boundaries before applyingFour boundaries before applying

Before applying, you should first confirm the customer's region, matching mechanism, asset custody arrangements, and token listing rules, and then decide whether to apply, upgrade, or adjust the business model.Before starting a Hong Kong VASP license application, the team should clarify client geography, matching mechanism, custody arrangement and token admission rules, then decide whether to apply, upgrade an existing licensed entity or redesign the operating model.