Hong Kong virtual asset trading platform licensing and ongoing supervision framework

Virtual assets — Overview

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Overview

The SFC is one of the first and few regulatory authorities in a major jurisdiction to introduce a comprehensive regime regulating a wide range of virtual asset-related activities.The SFC’s regulatory regime seeks to capture all the dimensions of the public’s interface with virtual assets, providing for investor protection and market integrity while managing key risks to financial institutions.

The SFC’s regulatory philosophy is based on the overarching principle of “same business, same risks, same rules”.

The SFC regulates the following virtual asset-related SFC-licensed or registered intermediaries:

Virtual asset fund managers

Intermediaries dealing in or advising on virtual assets

Intermediaries distributing virtual asset-related products

For SFC's publications regarding virtual assets, please click here.

Related Info

Alert List

Enforcement actions

Virtual asset trading platform operators

Welcome to the Fintech Contact Point

Fintech enquiry form

SFC Regulatory Sandbox

International cooperation agreements

Global Financial Innovation Network

Important links

FAQs on licensing related matters

FAQs on conduct related matters

Under the Securities and Futures Ordinance (Cap. 571) (SFO) and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO), centralised virtual asset trading platforms carrying on their businesses in Hong Kong, or actively marketing their services to Hong Kong investors, are required to be licensed and regulated by the SFC.

SFO regime AMLO regime

Type of licence Type 1 regulated activity (dealing in securities) & Type 7 regulated activity (providing automated trading services) Providing a virtual asset service (operating a virtual asset exchange)

Licensing scope Centralised platforms providing trading services in security tokens* using an automated trading engine which matches client orders and also providing custody services as an ancillary service to their trading services Centralised platforms providing trading services in non-security tokens* using an automated trading engine which matches client orders and also providing custody services as an ancillary service to their trading services

Persons to be licensed Licensed corporations (LCs) Licensed representatives of LCs (including responsible officers) Licensed providers (LPs) Licensed representatives of LPs (including responsible officers)

* Given that the terms and features of a virtual asset may evolve over time, a virtual asset's classification may change from a non-security token to a security token (or vice versa). To avoid contravention of the licensing regimes and to ensure business continuity, it would be appropriate for virtual asset trading platforms to apply for licences under both the SFO and AMLO regimes.

How to apply

Please submit the licensing application to the SFC through WINGS. Please refer to the user guides and online demo of WINGS on the SFC's website on how to open a WINGS account and how to prepare an application on WINGS.

To streamline the application process, applicants for licences under both the SFO and AMLO regimes can submit a single consolidated application online and indicate that they are applying for both licences simultaneously.

Application documents

Please submit to the SFC:

Application forms

(1) Copies of the VATP applicant’s written policies and procedures, (2) documentation to show that a suitable EA has been identified to perform an external assessment for the VATP applicant and (3) the capability statement of the EA, in the application bundle.

For details, please refer to the circular issued on 16 January 2025 and the FAQ on external assessment reports for licence applications.

Fees

The application fees are as follows:

Type of application Type of licence Application fee amount

Licensed corporation (under SFO) Types 1 & 7 regulated activities $4,740 per regulated activity

Licensed virtual asset service provider (under AMLO) Providing a VA service $4,740 for a VA service

Licensed representative (under SFO) Types 1 & 7 regulated activities $1,790 per regulated activity

Licensed representative (under AMLO) Providing a VA service $1,790 for a VA service

Approval to become responsible officer (SFO) Types 1 & 7 regulated activities $2,950 per regulated activity

Approval to become responsible officer (AMLO) Providing a VA service $2,950 for a VA service

Licensing Handbook for Virtual Asset Trading Platform Operators (VATP Licensing Handbook)

The VATP Licensing Handbook provides a handy licensing guide for virtual asset trading platform operators. It sets out detailed procedures to guide them on how to apply for a licence as well as the relevant ongoing notifications and other applications required of them after obtaining a licence.

Please refer to the VATP Licensing Handbook for more information on the application procedures and process.

Other relevant documents

The SFC has also issued a circular on the implementation of the licensing regimes under the SFO and the AMLO and a circular on the transitional arrangements under the AMLO.

FAQs on licensing-related matters

FAQs on conduct-related matters