Hong Kong Licenses VA Advisory Services

Hong Kong Licenses VA Advisory Services

Mid-2026 consultation conclusions by the FSTB and SFC mandate AMLO-based licenses for virtual asset management.

Hong Kong has officially set the foundation to close the remaining gaps in its digital asset regulatory perimeter. In mid-2026, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) published their consultation conclusions on a standalone licensing regime for virtual asset (VA) advisory and management service providers.

Historically, some of these activities operated in a grey area or relied on the Securities and Futures Ordinance (SFO) framework. The new regime clarifies that pure virtual asset management will require a specific Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) based license.

The regulatory expectations are stringent. Firms providing VA advisory or management services face strict financial requirements. The baseline mandates a minimum paid-up share capital of HK100,000 for firms not holding client assets, escalating to HK$3 million if client assets are held. Notably, the SFC explicitly excluded tokenised securities from this VA definition, meaning they will continue to be regulated under the existing SFO framework.

Compliance departments must prepare for rigorous suitability obligations, strict financial reporting, and comprehensive technology audits. Engaging with regulators early in the pre-application phase will be critical to ensuring a smooth transition. For compliance consultants, guiding clients through this new licensing maze will be a primary focus as the bill enters the Legislative Council.