First, separate fiat currency remittance from stablecoin transactions
The Hong Kong Customs and Excise Department's 2026 MSO licensing guidelines set out access requirements, business information and continuing obligations in relation to money changing and remittance. Accordingly, the fact that a company holds an MSO licence proves only its eligibility under that regime; it does not by extension prove that wallet custody, stablecoin sales or virtual asset platform business are all permitted. Nor is the specific combination a mechanical stacking of licences: the incidental money services of certain regulated institutions benefit from statutory exemptions, and this must be confirmed on the basis of the entity and the actual business.
MSOs are not on the list of permitted stablecoin providers
According to the Hong Kong Monetary Authority's guidance on stablecoin licensing, the permitted providers of specified stablecoins include licensed stablecoin issuers, authorized institutions, licensed SVF licensees, SFC-licensed virtual asset trading platforms and corporations licensed for Type 1 regulated activity. Holding an MSO licence alone does not place a company on this list. The Hong Kong Government's reply to the Legislative Council also makes clear that ordinary over-the-counter virtual asset trading institutions cannot offer specified stablecoins to retail or professional investors merely by virtue of their operating status.
Calling a product "remittance" does not allow the stablecoin offer analysis to be skipped
Assume a customer delivers Hong Kong dollars, the platform quotes and undertakes to deliver a certain US dollar stablecoin to the customer's wallet, and the customer then pays a supplier. Here there is not only a remittance narrative; there may also be an arrangement under which the platform sells stablecoins to the customer. The offer analysis under the Stablecoins Ordinance focuses on whether, in the course of business, information on the currency, terms and channel sufficient for the other party to decide to purchase is conveyed; it cannot be assumed that a quote in a private chat, or the customer making the first inquiry, is necessarily unrestricted.
Cooperation may involve a division of labour, but it must be clear with whom the customer is transacting
Another assumption is that the customer directly enters into a stablecoin transaction with an institution that meets the requirements, and the MSO undertakes only fiat currency remittance within its lawful scope. The contracts, quotations, asset control and refund liability under the two arrangements should genuinely differ; it is not enough merely to change the name in the agreement. Hong Kong's new regimes for virtual asset trading, custody and the like remain subject to the final legislation and commencement documents; published consultation conclusions cannot be treated as ready-made licences, nor as a reason to disregard the existing stablecoin restrictions. In practice, changes of counterparty, the addition of supported currencies and adjustments to refund paths should also be set as triggers for review, so that an initial review does not permanently cover subsequent products.
Recommended actions
- Identify the actual seller on each page, chat quotation and order step, and check whether a specified stablecoin offer is constituted.
- Verify the counterparty's status as a permitted provider and its specific business restrictions, and check the currencies and customer types it may accept.
- Form separate access conclusions for fiat currency remittance, stablecoin sales, custody and transfer, and check whether the funds and liabilities are consistent with the contract.
Information note: This article provides general information only and does not replace legal advice based on specific facts.
References
- Licensing Guide for Money Service Operators, May 2026 — Hong Kong Customs and Excise Department
- Explanatory Note on Licensing of Stablecoin Issuers, sections 2.9–2.10 — Hong Kong Monetary Authority
- LCQ10: Regulation of digital assets, 10 September 2025 — Hong Kong Government
- FSTB and SFC conclude consultations on virtual asset dealer and custodian regimes, 24 December 2025 — Financial Services and the Treasury Bureau / Securities and Futures Commission
