Hong Kong SFC VASP licensing regime — VATP regime + licensed CEX overview

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This entry sits under exchanges index. Read it against EU MiCA CASP (Crypto-Asset Service Provider) regime for peer / contrast context and FSA crypto-asset exchange registration system — number system / Local Finance Bureau jurisdiction / registration requirements for the broader system / regulatory boundary.

Regime overview

Hong Kong put the amended AMLO (Anti-Money Laundering Ordinance) into effect in 2023-06-01, newly introducing the VATP (Virtual Asset Trading Platform) regime. It is a framework that applies the existing SFC (Securities and Futures Commission) Type 1 (dealing in securities) + Type 7 (providing automated trading services) licenses to digital-asset platforms, with the SFC serving as a single regulator overseeing both AML/CFT and investor protection. In 2023-08 , retail (零售) trading was opened up, shifting from an institutions-only regime to one accessible to general investors.

Licensing status (as of 2026 )

• HashKey Exchange (HashKey Group) — authorized in 2023-08 as Hong Kong’s first retail VATP. Although backed by mainland-China capital, it is based in Hong Kong and expanding across Asia. It has also entered Japan via its Japanese subsidiary jp-exchange-tokyo-hash.
• OSL Exchange (OSL Group, HKEX-listed 863.HK) — obtained retail authorization at the same time as HashKey in 2023-08 . An institution-centric business model. In Japan, jp-exchange-osl-japan has obtained JVCEA Type 1 membership.
• Pipeline: HKVAX, Bullish, Crypto.com HK, VDX, and many others are applying. The SFC takes a phased-authorization policy and a cautious stance.

Key regulatory requirements

• Capital: HK$5M (approx. 1 億円) or more — a stricter level than Japan (1,000 万円~)
• Customer-asset segregation: assets must be held separately via a trust company (trustee)
• Cold-storage ratio: 98% or more — stricter than Japan’s JVCEA self-regulatory 95%
• Insurance obligation: hot-storage holdings require insurance capable of full compensation (in Japan this is a best-effort obligation)
• AML/CFT: enhanced implementation of the FATF Travel Rule (remittances of HK$8,000 or more)

Tradable tokens

For retail, only large, liquid tokens that have passed strict SFC screening are allowed — limited to BTC, ETH, USDT, USDC, etc. Additional tokens can be handled for institutions, but stablecoins are separately under HKMA supervision per hkma-stablecoin-licensing-overview, forming a parallel licensing structure with the SFC VATP.

International comparison

• Japan FSA/JVCEA — roughly 33 tokens (whitelist system) · jvcea-whitelist-token-listing
• Hong Kong SFC — limited (large liquidity only)
• Singapore MAS DPT (Digital Payment Token) — strict retail restrictions
• UAE VARA — Dubai-centered, more flexible

Japanese corporate entry into Hong Kong is active, with observations of a Tether HK strategy and entry by the Mitsui group. On one hand the SFC VATP is positioned as a Tier 2 base within global-cex-top10-comparison; on the other, discussions of mutual recognition like three-circles-stablecoin-mra-framework are still at an early stage. The Hong Kong VATP regime is referenced along both axes of Global VASP regulatory 8 -pole comparison matrix — JP / KR / HK / SG / EU / US / UAE / UK and Global Stablecoin Regulation: Five-Pole Comparison Matrix, and is worth reading in parallel with HKMA stablecoin licensing implications.

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Source: public-information compilation (SFC announcements, public materials on the HK AMLO amendment articles, HKMA stablecoin issuer announcements, IR of each licensee)