Hong Kong Stored Value Facility License (SVF license)

Hong Kong Stored Value Facility License (SVF license)

legal threshold | Paid-in capital is not less than HK$25 million | The Hong Kong Monetary Authority strictly examines and approves

Hong Kong Stored Value Facility, SVF) licensing system is established by the Monetary Authority in accordance with the Hong KongPayment Systems and Stored Value Facilities Ordinance (Chapter 584)implement。Non-bank applicants must judge whether to issue or promote the issuance of multi-purpose SVF in Hong Kong based on the actual product,and continue to comply with the subject、Main business、financial resources、personnel、Float protection、AML/CFT、Requirements such as risk management and technical security。

Hong Kong Huitong can assist in business characterization according to the agreed scope.、Application information list、Compilation of policy documents and inquiry responses;Is it regulated?、Whether to accept an application and whether to issue a license shall be determined by the Monetary Authority in accordance with the law.、Decision on application facts and review results。

Release time:Content has been reviewed
Peng Leji
Peng Leji Core Compliance Team
Served:Hong Kong licensed integrated financial group & International Financial Compliance Consulting Agency
permanent residence:Hongkong Experience:15 Year
Expertise in compliance areas:SFC Type 1/4/9 regulated activity application、Money Lenders and MSO Licensing Matters、Anti-money laundering(AML/CTF)review、Financial Structure and Internal Control。
personal note:Peng Leji - Have more than 14 Years of experience in Hong Kong financial regulatory compliance and licensing matters。Core business covers Hong Kong Securities and Futures Commission (SFC) 1st、4and 9 types of regulated activity licenses、Hong Kong money lenders (Money Lender) License and Money Services Operator (MSO) License application and compliance review。
Familiar with the regulatory application process
Professional compliance team
Standardized compliance process
Multi-jurisdictional services

1. Hong Kong Stored Value Facility License (SVF license)core conditions

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statutory paid-in capital

Applicants must maintain a paid-up share capital of not less than HK$25 million,or other financial resources of equivalent value acceptable to the Monetary Authority。This amount is the minimum requirement;The Hong Kong Monetary Authority can determine the size of floating deposits、Number of user accounts、Risk and business complexity impose higher requirements。

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Local entities and main businesses

Non-bank applicants must be companies established in Hong Kong,The main business is to issue or promote the issuance of SVF。Businesses unrelated to the SVF should generally not divert resources;Incidental remittance or currency exchange can be handled according to the instructions of the Hong Kong Monetary Authority,However, SVF licensees are not allowed to engage in financial intermediation or conduct other regulated activities without appropriate licenses。

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Client funds are strictly segregated

Licensees must protect and manage float and SVF deposits,Keep it separate from own funds and other business funds。Supervisory guidance takes effective trust arrangements as the main method;when there is good reason,Valid bank guarantee or insurance may be used instead or in addition,Specific legal priority must be implemented by actual arrangements。

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Fitness and fitness test for senior executives

CEO、Directors and controllers must be fit and proper,Applicants must also have a control system in place to ensure the suitability of managers。The chief executive and at least one alternate chief executive must ordinarily reside in Hong Kong;Directors and chief executive officers must obtain the consent of the Financial Controller before taking office.,Controllers and managers have separate consent or notification procedures that apply。

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Anti-Money Laundering and Compliance System

An AML/CFT system that complies with the Anti-Money Laundering Regulations must be established,Implement customer due diligence (CDD) and transaction monitoring,And implement stepped KYC standards based on product functions。

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independent third party assessment

First-time applicants are required to submit an independent assessment report in six key areas:Corporate Governance and Risk Management、Float management、AML/CFT、Technology risks、Payment Security and Business Continuity。The Hong Kong Monetary Authority’s licensing instructions state that the report will be valid for no more than 6 months from the date of signature.;Evaluate candidates、Scope and update requirements should be confirmed prior to submission。

2. Hong Kong payment instrument classification

香港支付工具分类
Hong Kong payment instrument classification

储值支付工具持牌人纪录册历史截图,最新名单以香港金管局为准

This picture is a historical screenshot,It should not be used to determine the current number or status of licenses.。The HKMA’s online register lists 11 non-bank SVF licensees on 14 August 2026,And another 4 companies are currently issuing、A licensed bank that facilitates the issuance or has no objection from the HKMA to the issuance;The list will change,Should be based on the real-time record book。

References:Register of Stored Value Facilities Licensees-Hong Kong Monetary Authority

3. Hong Kong Stored Value Facility License (SVF license)List of statutory fees

project Current official caliber illustrate
license fee 113,020Hong Kong dollar Instructions for Licensing by the Hong Kong Monetary Authority and Schedule 4 of the Ordinance,Payment must be made within 14 days after the license becomes effective,Thereafter, payable annually on or before each anniversary date;Review the current schedule before payment。
minimum financial resources 2,50010,000 Hong Kong dollars This is the threshold of paid-up capital or equivalent other financial resources accepted,Not a government fee;The HKMA can impose higher requirements。
independent assessment、Audit and testing Quote by project Belongs to third-party professional costs,Not a unified government charge。Evaluate candidates、Scope and cost depend on application and system。
Legal and advisory services Quotation based on agreed range Not a legal uniform amount。The official website originally listed an application fee of HK$150,000 and a budget of HK$3 million to HK$6 million, which are not supported by current official information.,Therefore, it is no longer a fixed expense。

4. Hong Kong Stored Value Facility License (SVF license)application process

first stage:Initial consultation and research

before formal application,Management should take the initiative to conduct preliminary discussions with the SVF Licensing Team of the Hong Kong Monetary Authority,Learn about the latest regulatory expectations;If the group is subject to supervision overseas,Local regulatory authorities need to be consulted in advance。At the same time, evaluate whether your own business falls within the scope of exemption (such as single-purpose SVF)。

second stage:Internal preparation and independent evaluation

Establish a qualified Hong Kong entity and implement minimum financial resources;Prepare business plans and forecasts covering three years;Appoint an independent evaluator to complete corporate governance and risk management、Float management、AML/CFT、Technology risks、Report on six key areas of payment security and business continuity operations。The report is valid for no more than 6 months from the date of signature。

The third stage:Submit a complete set of application documents

Submit the designated application form and the information listed in Annex B to the HKMA。Incomplete applications may first be considered a "draft";Applications that are not submitted within the deadline may be suspended.,Suspensions of 6 months or more usually require re-application。

Stage 4:HKMA audits and on-site inspections

The HKMA may request supplementary information、Interviews with directors and CEO,and conduct on-site or off-site reviews as needed、Independently evaluate or review the auditor's report。Applications will be considered by the Stored Value Facilities Licensing and Advisory Committee and recommendations will be made to the Monetary Authority。

The fifth stage:Approval in principle and conditions met

The Monetary Authority will only do so if it is satisfied that all applicable minimum standards have been and will continue to be complied with,Only then can the cards be dealt。License may be unconditional or subject to capital、Business scope、Float protection、Stored value caps or disclosure conditions;Case communication should not be written as an inevitable "approval in principle"。

Stage six:Official licensing and payment of fees

After all conditions are met,The Hong Kong Monetary Authority officially granted SVF a license and assigned a unique license number。The licensee must pay the first-year license fee within 14 days after the license becomes effective.,And on the physical card、Official website and APP display license number。

5. Hong Kong Stored Value Facility License (SVF license)List of documents required for application

Formal license application form (format specified by the HKMA)

Detailed business plan and financial budget for the next three years (including operating model、target market、product design、fee structure, etc.)

Company registration documents:Registration certificate、Business registration certificate、Articles of Association、Incorporation form (certified by CEO)

Audited financial statements for the three fiscal years before application (new companies must provide capital injection certificates and holding company statements)

All directors、Declaration of “fit and proper person” and supporting documents (resume) of controller and chief executive officer、No criminal record、professional qualifications)

independent evaluation report:Covering corporate governance and risk management、Float management、AML/CFT、Technology risks、Six key areas for payment security and business continuity,Valid for no more than 6 months after signing

AML/CFT Policy and Operating Procedures Manual,Includes risk assessment report、Customer due diligence review rules、Transaction monitoring and suspicious transaction reporting process

Stored value management and investment policy documents (if applicable),Client fund segregation and fiduciary arrangements must be explained

Technology Risk Management Framework、Payment Security Plan and Business Continuity Plan (BCP)

Copy of user agreement and terms and conditions,Operational Rulebook (Including Refunds、Exit plan, etc.)

6. Hong Kong Stored Value Facility License (SVF license)Common reasons for failure and compliance red lines

⚠️ The main body or main business does not match:Non-qualified Hong Kong company,or whose main business is not to issue or promote the issuance of SVF,Will affect compliance with minimum standards;Other financial activities must separately determine the license and business boundaries。

⚠️Insufficient financial resources or unclear evidence:Applicants must demonstrate paid-up capital of HK$25 million or other acceptable financial resources of equivalent value.,and explain the source of funds、Purpose and ongoing maintenance arrangements。

⚠️ Insufficient staff arrangements:CEO、Directors and controllers must pass a fit and proper examination,Managers are subject to appropriate control systems;The chief executive and at least one alternate chief executive must ordinarily reside in Hong Kong。

⚠️ Independent assessment does not meet the requirements:The first-time application report must cover six key areas and be valid for 6 months after signing.;evaluator independence、Both capabilities and scope may be queried。

⚠️Insufficient protection of floating deposits:Float deposits and SVF deposits must be separated from other funds,and by valid trust or accepted bank guarantee、Insurance and other arrangements protect users。

⚠️ Insufficient AML/CFT control:policy、risk assessment、Customer due diligence、Transaction monitoring、Sanctions Screening、Records and suspicious transaction reporting must be proportionate to the product and risk and implemented。

⚠️ Insufficient outsourcing control:Outsourcing does not transfer licensee responsibilities;Data access、right of censorship、service continuity、Incident management and third-party risks must be implemented through contracts and controls。

⚠️ Insufficient exit arrangements:The business continuity and exit plan must describe how to protect the company in the event of cessation of operations.、Redeem and return user funds,and set aside resources to handle associated costs。

7. Hong Kong Stored Value Facility License (SVF license)Frequently Asked Questions(FAQ)

What is a multipurpose Stored Value Facility (SVF)?+

Multipurpose SVF typically stores value,and may be used to make payments to persons other than the issuer。Whether it is a regulated SVF depends on product rights、capital flow、Scope of use and distribution arrangements;single purpose、Incentive schemes or limited-purpose arrangements are only exempt from application if they meet statutory exemptions。

Which businesses need to apply for an SVF license?+

Non-bank institutions that issue or facilitate the issuance of regulated SVF in Hong Kong,Usually required to obtain a license or an explicit exemption applies。A licensed bank is deemed to have been granted a license under section 8G of the Ordinance,However, specific products and distribution arrangements still need to be checked。

What are the paid-in capital requirements for applying for an SVF license?+

The minimum requirement is HK$25 million in paid-up share capital,or other financial resources of equivalent value acceptable to the Monetary Authority。The HKMA may, based on risk、float、Number and complexity of accounts impose higher requirements。

What are the legal requirements for key management personnel?+

CEO、Directors and controllers must be fit and proper,Managers are subject to appropriate control systems。The chief executive and at least one alternate chief executive must ordinarily reside in Hong Kong;Different positions have different prior consent or notification requirements.。

How to protect customers’ stored value funds?+

Licensees must protect and manage float and SVF deposits separately。Regulatory guidance requires the establishment of effective trust arrangements,To implement users’ legal rights and priority claims when the licensee becomes insolvent;Bank guarantees or insurance may be used as an alternative or supplement when justified,Actual results depend on documentation and legal arrangements。

How long does the application process usually take?+

The legislation and the HKMA's licensing instructions do not commit to a fixed review and approval period.。Time depends on application completeness、Business and system complexity、Supplementary parts、Independent assessment and regulatory review;Guaranteed results may not be based on a uniform number of months。

What does the license fee include?+

The license fee listed in the HKMA licensing instructions is HK$113,020,Payment must be made within 14 days after the license becomes effective,Thereafter, pay annually;Schedule 4 of the Ordinance must be reviewed before payment。No official basis for the unified application fee of HK$150,000 was found.,third party assessment、audit、Legal and consulting fees are recognized on a project-by-project basis。

Is it allowed to outsource part of the business?+

Can outsource some activities,However, the licensee, directors and management remain ultimately responsible。Outsourcing must not hinder the HKMA、Access to information by internal or external auditors and evaluators、Conduct on-site or off-site reviews;specific contract、Location and control requirements must be implemented based on risk。

What are the ongoing compliance obligations after being licensed?+

After being licensed, you must continue to meet the minimum standards and license conditions,include financial resources、personnel、Float management、AML/CFT、Risks and Internal Controls、Data and Accounting Systems、Business Conduct、Notices and Reports。audit、Frequency of testing and reporting is regulated by legislation、guidelines、The license conditions and requirements of the Hong Kong Monetary Authority shall prevail.。

Under what circumstances will a license be revoked or revoked?+

The Monetary Authority may suspend the、Cancel、instruct、Actions such as investigations or fines。Revocation does not have immediate and automatic consequences for all violations;Refuse to approve、Revocation and some other decisions have written reasons and applicable review or appeal procedures。

official information use
Payment Systems and Stored Value Facilities Ordinance (Chapter 584) Legal basis、minimum standards、personnel、Fees and regulatory powers
Hong Kong Monetary Authority:Supervision system for stored value payment instruments licensing system、Portal to regulatory tools and official guidance
Summary explanation of the licensing system for stored value payment instruments Apply、minimum standards、Documents and programs
Supervisory Guidelines for Stored Value Facility Licensees Ongoing supervision、personnel、Outsourcing and float protection
AML/CFT Guidelines for Stored Value Facility Licensees Customer due diligence、Continuous monitoring、Records and reports
Register of Stored Value Facilities Licensees current licensee、License number and effective date

9. Comparison of three major payment compliance paths in Hong Kong:SVF、Institutional Embedment and MSO License

Before providing payment or fund transfer functions in Hong Kong,should first be based on the actual capital flow、User rights and contract roles determine whether to issue or promote the issuance of SVF。Use of third-party licensed SVF or bank interfaces does not automatically exempt oneself from license analysis,Cooperation must go through due diligence by the other party、Contractual arrangements and applicable regulatory approvals。

Licensed SVF or banking services:If the third party maintains issuer and regulated liability,Companies can explicitly license technology、Providing services within the scope of distribution or merchants;Bank accounts or API access must not be described as the company itself being issued an SVF license。

MSO license:Only applicable to currency exchange or remittance services,Not a substitute for a license to issue or facilitate the issuance of SVF。If an e-wallet stores value、For third-party payments or other regulated activities,SVF and other systems must be checked separately。

10. Relevant regulations、Regulatory information and further reading

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