1. Hong Kong Stored Value Facility License (SVF license)core conditions
statutory paid-in capital
The applicant must be a Hong Kong registered limited company，and maintain a paid-up share capital of not less than HK$25 million。HKMA can impose higher capital requirements based on business risks，The funds must be used purely for SVF business。
Local entities and main businesses
The applicant must be a company established in Hong Kong，The principal business must be the issuance or promotion of the issuance of multi-purpose SVF。In addition to ancillary remittance and currency exchange services，Not concurrently engaged in credit or other regulated financial activities。
Client funds are strictly segregated
The stored value amount and deposit must be completely isolated from the company's own funds，Deposited in an independent trust or designated bank account，Ensure that users have priority in making claims in the event of bankruptcy。
Fitness and fitness test for senior executives
per chief executive、director、Controllers and managers must pass extremely stringent “fit and proper” checks，The chief executive officer and alternate chief executive officer must be resident in Hong Kong，Appointment of senior management requires the prior written consent of the HKMA。
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。
independent third party assessment
A qualified independent assessor must be appointed to issue a report covering corporate governance、Stored value management、AML/CFT、Technology risks、"Independent Assessment Report" on six major areas of payment security and business continuity operations，The report is only valid for 6 months。
2. Hong Kong payment instrument classification
References：Register of Stored Value Facilities Licensees-Hong Kong Monetary Authority
3. Hong Kong Stored Value Facility License (SVF license)List of statutory fees
| Expense items | Amount/range (HKD) | illustrate |
|---|---|---|
| Application fee (payable to the HKMA) | 150,000 | A one-time payment is required when submitting the formal application.，Non-refundable。 |
| Annual license fee (statutory) | 113,020 | Pay the first-year fee within 14 days after the license is issued，Thereafter, the payment shall be renewed every year on the license anniversary date.。 |
| Paid-in capital requirements (minimum) | 25,000,000 | Must be fully paid upon application，and continue to maintain，The HKMA may require higher capital。 |
| Independent assessment and system audit | Approximately 1,500,000 – 3,000,000 | Independent assessment in six categories、Penetration testing and subsequent regular audits，Depends on business complexity。 |
| Compliance advisory and legal fees | Approximately 1,500,000 – 3,000,000 | Hire local lawyers and compliance consultants to assist with the application、Build AML/KYC system，The total budget is about 3 million to 6 million or more。 |
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
Set up a Hong Kong company and meet the minimum share capital requirements；Prepare business plan、financial forecast；Engage an independent third party to issue documents covering corporate governance、Stored value management、AML/CFT、Technology risks、Assessment Report on Six Major Areas of Payment Security and Business Continuity Operations。The report must be issued within 6 months before submission。
The third stage：Submit a complete set of application documents
Submit a formal application form to the HKMA、Audited financial statements、business operating rules、AML/CFT Policy、A complete set of information including independent evaluation reports。Incomplete information will be considered "draft" and processing will be suspended.，After everything is complete, you will be confirmed to enter the "formal application"。
Stage 4：HKMA audits and on-site inspections
The HKMA conducts in-depth assessment of applicants，Includes interviews with executives、On-site inspection、System audit and penetration testing。There may be multiple rounds of requests for additional information.。The application is ultimately submitted to the HKMA’s high-level ad hoc committee for review and recommendations。
The fifth stage：Approval in principle and conditions met
If the Management Committee is initially satisfied，"Approval in principle" may be issued with certain licensing conditions (such as additional capital、Perfect system、Limit the upper limit of stored value, etc.)。Applicants must complete all conditions within the specified time limit。
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 Assessment Report" issued by an independent third party (covering corporate governance、Stored value management、AML/CFT、Technology risks、Six major areas of payment security and business continuity operations，6Valid within one month)
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
⚠️Business subject does not match：The applicant is not a Hong Kong registered company，or its main business is not the issuance of SVF，Even running credit、Securities and other prohibited financial activities，will directly result in the application being rejected。
⚠️ Insufficient paid-in capital or suspicious source：Failure to provide clear bank certificate showing that the minimum capital of HK$25 million has been paid in full，or funds are used for related-party transactions，The HKMA will not accept it。
⚠️ Executives failed to pass the fit and proper review：CEO、The director or controller has a bad credit record、Lack of bankruptcy history or relevant professional experience，Especially if the CEO is not based in Hong Kong，would constitute a fatal flaw。
⚠️ The independent assessment report is not compliant：Failure to hire a qualified independent evaluator，Or the report is valid for more than 6 months，Or the assessment scope falls short of the six statutory core areas.，Application will be returned。
⚠️Customer fund isolation plan invalidated：Failure to effectively establish trust arrangements，Or confuse users’ stored value funds with their own funds，Violates the core user protection principles。
⚠️ The AML/CFT system is just a formality：Lack of graded KYC measures for product risks，For high-risk transactions (such as P2P transfers、Cross-border payments) No enhanced due diligence has been implemented，Weak anti-money laundering monitoring system。
⚠️ Lack of outsourcing control：Core systems or compliance functions are outsourced without a clear SLA，or failure to ensure that the HKMA and auditors have unrestricted access rights to service providers，The licensee shall bear ultimate responsibility。
⚠️ Lack of business exit plan：Failure to formulate a detailed plan for fully refunding user funds upon completion and reserving additional administrative costs in the operating rules，Failure to comply with ongoing regulatory requirements。
7. Hong Kong Stored Value Facility License (SVF license)Frequently Asked Questions(FAQ)
According to Hong Kong’s Payment Systems and Stored Value Facilities Ordinance (Chapter 584)，Multipurpose SVF refers to instruments that store value，The value can be used to purchase goods or services from third parties other than the issuer，or pay debts。Common examples include the Octopus、Alipay Hong Kong、WeChat Pay Hong Kong and other electronic wallets。Single-purpose SVF (such as gift cards that can only be used in your own store) are exempted。
Any non-bank institution that issues or facilitates the issuance of multi-purpose SVF in Hong Kong，All are required to apply for a license from the Hong Kong Monetary Authority。Legislation exempts SVF issued by licensed banks，and specific single-purpose、Reward programs and limited-use tools。
The statutory minimum paid-in capital is HK$25 million or its equivalent in foreign currency。This is only the threshold，The HKMA can adjust the business scale、Total stored value and risk profile impose higher capital requirements。Funds must be used for business operations，Not used for related party transactions。
per chief executive、director、Both controllers and managers must pass the "fit and proper" test，including good character、Professional ability and financial stability。The chief executive officer and alternate chief executive officer must be resident in Hong Kong，The appointment of senior executives requires the prior written consent of the HKMA。
Licensees must completely segregate customers' stored value amounts and deposits from their own funds.，Deposited in a separate trust account or designated licensed bank。This arrangement ensures that in the event of bankruptcy or liquidation of the licensee，Users have the priority right to claim，It is strictly prohibited to use reserve fund investment income as the main income。
The full set of applications will be officially accepted from，Usually 12 to 24 months or longer，Depends on business complexity、Document preparation quality and HKMA review progress。It is strongly recommended to conduct preliminary consultation with the Hong Kong Monetary Authority in advance to shorten the preparation time.。
A one-time application fee of HK$150,000 is required to be paid to the HKMA，And the annual fee after approval is HK$113,020。also，The budget for independent assessment and compliance consulting fees is generally HK$3 million to HK$6 million or more.。
Outsourcing allowed，However, the licensee and its directors、CEO must bear ultimate responsibility for compliance。Due diligence review of outsourcers required，Sign a clear service agreement，and must ensure that the HKMA monitors the premises of internal and external service providers、Unrestricted access to systems and records。
Must continue to comply with minimum capital requirements、Submit regular financial and compliance reports、Arrange annual system audits and penetration testing、Strictly enforce AML/KYC procedures、Display license number on all media，and promptly notify the Monetary Authority of any major changes.。
If you are unable to pay your debts、Submit false information、Breach of licensing conditions、Conduct that seriously damages the reputation of Hong Kong as an international financial center (such as money laundering、Violation of sanctions) etc.，The HKMA may immediately revoke or suspend the license，and may impose fines。
1、Hong Kong Monetary Authority"Summary Explanation of the Licensing System for Stored Value Facilities"
9. Comparison of three major payment compliance paths in Hong Kong：SVF、Institutional Embedment and MSO License
Hong Kong Huitong Tips：Regarding carrying out stored-value payments in Hong Kong (such as issuing recharge cards、Electronic wallet, etc.) business，Currently, the Hong Kong Monetary Authority (HKMA) has extremely strict policies for applying for stored value facility (SVF) licenses.。
In view of the fact that independently applying for an SVF license must face 2500 Minimum paid-up share capital requirement of HK$10,000、High anti-money laundering (AML) compliance costs and uncertain approval cycles，The following more efficient alternative compliance paths are recommended:：
Alternative 1：Rely on the [licensed SVF/banking institution] recognized by the Hong Kong Monetary Authority for service embedding
How it works：Direct access to approved local licensed institutions in Hong Kong (such as Octopus、Alipay Hong Kong、WeChat Pay Hong Kong、HSBC Bank, etc.)，Or integrate its payment capabilities through compliant API interfaces。
Advantages：Eliminate the huge cost of applying for a license independently，Ensure business compliance and legality，At the same time, it greatly shortens the commercialization launch cycle.。
Alternative 2：Apply for a [Money Service Operator (MSO)] license in accordance with the law
How it works：If the business scope only involves cross-border remittance or currency exchange (and does not involve storing funds in an electronic wallet)，Then you can apply for an MSO license from the Hong Kong Customs in accordance with the law.。
Advantages：Compared to SVF license，The statutory entry threshold for MSO licenses in specific business scenarios is more reasonable，Sufficient to meet the compliance needs of most cross-border capital flows。
