Hong Kong's Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) published consultation conclusions on Tuesday for licensing regimes governing virtual asset advisory and virtual asset management services under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. The consultation demonstrated broad market support for the proposed regimes, with respondents largely agreeing with the policy direction under the "same business, same risks, same rules" principle. The framework aligns the scope of virtual asset advisory and management with existing regulated activities covering securities advisory and discretionary asset management. This regulatory development represents the completion of Hong Kong's comprehensive digital asset licensing framework, which also includes parallel proposals for virtual asset dealing and custody services.
Framework Scope and Structure
Under the proposed structure, advisory services would capture business activities involving recommendations on the acquisition or disposal of virtual assets. Management rules would apply where firms exercise discretionary control over virtual asset portfolios.
The regimes set baseline financial resources requirements, including minimum liquid capital of HKD 100,000 ($12,760) for firms not holding client assets, and up to HKD 5 million ($638,095) in paid-up capital alongside HKD 3 million ($328,862) in liquid capital where client assets are held.
Dual Licensing and Capital Requirements
Dually licensed entities will not face double regulatory capital requirements, instead defaulting to the highest capital floor among their authorized activities. This provision simplifies compliance for firms operating across multiple regulated virtual asset services.
Next Steps
The FSTB and SFC aim to introduce a bill to the Legislative Council in 2026. Existing and prospective virtual asset advisory and management service providers are encouraged to engage with the SFC early to initiate pre-application discussions.
SFC CEO Julia Leung stated: "The conclusion of further consultation marks the final leg of our journey to complete the regulatory framework for digital assets, paving the way for the long-term scaling of our ecosystem. The broad market support demonstrates the strong need for robust and comprehensive regulation. Aligning with the standards for traditional financial services, the new regimes will bolster investor protection while fostering responsible innovation."
