Hong Kong VASP/VATP virtual asset trading platform license

Hong Kong VASP/VATP virtual asset trading platform license

According to the Anti-Money Laundering Regulations(AMLO)and the Securities and Futures Ordinance(SFO)Regulatory Dual Licensing System

Hong Kong Virtual Asset Service Provider (VASP) and Trading Platform Operator (VATP) License, Regulated by the dual licensing regime of the Hong Kong Securities and Futures Commission (SFC) (covering SFO No. 1, 7Class and AMLO license, The practice is collectively referred to as "1+7+VASP"). Since the compulsory licensing system comes into effect in June 2023, Capital threshold for industry entry (5 million paid/3 million quick), High legal standards have been established in terms of asset custody (AE+TCSP and 98% cold wallet reserve) and external assessment (EAR). Hong Kong Huitong provides applying entities with coverage of the establishment of Hong Kong corporations., TCSP trust subsidiary structure construction, Coordination of external evaluation reports, Full-process application and compliance support services for responsible officer (RO) eligibility review and SFC administrative inquiry defense.

Release time: Application preparation reference
Hong Kong Huitong service teamApply for support
Document preparation and project coordination
work focus: business needs, Document consistency and matters to be confirmed
Service direction: Business description, Sorting out application materials and ongoing compliance matters
Service Description: Organize disclosure regulatory requirements based on proposed business operations, Material list and project nodes. Involving legal opinions, During audit or professional assurance, The corresponding professionals and service scope should be confirmed separately.; Competent agencies and banks make independent review decisions.
Familiar with the regulatory application process
Professional compliance team
Standardized compliance process
Multi-jurisdictional services

1. VASP/VATP license legal access conditions and core establishment

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Physical and workplace substance

Must be a company incorporated in Hong Kong or a registered non-Hong Kong company. Mandatory requirement to provide a non-residential local physical office address (commercial office building) for statutory record keeping and SFC surprise inspections, Never accept virtual addresses or purely overseas remote operations.

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Legal capital and current reserves

Must always maintain at least 500 paid-up share capital of HK$10,000 and 300 10,000 HKD liquid capital. also, Must have beneficial ownership in Hong Kong sufficient to cover the future 12 Monthly statutory current assets for actual operating expenses (it is strictly prohibited to use any virtual assets to offset this indicator).

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Executive configuration (RO & MIC)

The platform must appoint at least 2 Responsible Officer (RO), of which at least 1 executive director, And at least 1 resident in Hong Kong. At the same time, a core functional manager (MIC) must be appointed in accordance with the law to cover 8 Large control areas. All senior executives must be approved by the Securities Regulatory Commission as a fit and proper candidate (Fit & Proper) review.

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Asset custody and insurance mechanism

The custody of client assets must be regulated by the China Securities Regulatory Commission (CSRC) on related entities., trust arrangement, Preparation of applicable requirements for wallet and private key management, FATF background guidelines cannot be regarded as Hong Kong custody qualifications or licenses. For specific arrangements, please refer to the Securities Regulatory Commission’sVirtual asset regulatory information, And check according to the rules in effect at the time of business and application.

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Absolutely prohibited business red lines

At this stage, SFC strictly prohibits licensed platforms from providing virtual asset futures and related derivatives transactions; Leverage/margin financing is prohibited; Proprietary trading by the platform or affiliated companies is strictly prohibited (except for back-to-back transactions); And it is strictly prohibited to use customer assets for financial management, Activities such as pledging to earn interest.

Hong Kong Securities and Futures Commission (SFC) office logo
Hong Kong Securities and Futures Commission (SFC) office logo. The Securities and Futures Commission of Hong Kong is responsible for the licensing and supervision of virtual asset trading platforms in Hong Kong.

2. 2023-2026 Evolution of Hong Kong’s virtual assets regulatory framework and bill revisions

  • 2024December

    External Evaluation (EAR) Program Optimization: SFC releases circular, Streamline and optimize the original long-time "two-stage external independent expert evaluation procedure" to "mainly one-time evaluation", Significantly shorten the compliance rectification cycle. same day, Several Chinese-backed platforms were collectively approved under simplified procedures.

  • 2024March-April

    Spot ETF and stablecoin sandbox launched: Asia’s first virtual asset spot ETF launched in 4 Listed in month; at the same time, Hong Kong Monetary Authority (HKMA) launches stablecoin issuer sandbox, JD Coin Chain, Yuancoin Innovation and other entities enter the box to test the issuance of legal currency stablecoins.

  • 2025February-August

    Roadmap Release and Stablecoin Legislation: SFC launchedVirtual Asset Market Regulation Roadmap (ASPIRe), Planning staking and derivatives rules; "Stablecoin Ordinance" 2025 Year 8 moon 1 Officially effective on, It is expressly stipulated that the issuance of fiat stablecoins in Hong Kong requires a license, Trading is not currently open to retail investors.

  • 2026year progress

    Discussion on Tokenized Securities Retail Trading: SFC is developing relevant regulatory requirements and risk management and control guidelines, Consider allowing licensingVirtual asset trading platformProviding secondary market trading services for tokenized securities to retail investors, Broaden business outreach.

3. Statutory Application Submission File and Substantive Examination Elements

Consolidated Application Form for Category 1 and 7 Regulated Activities and VASPs, Comes with documents for a penetrating review of all ultimate owners (UBOs) and corporate structures.

Capital verification report in compliance with the Financial Resources Rules, as well as 12 Proof of liquidity reserve for monthly operating expenses.

External Evaluation Expert Report (EAR), Covers platform system design, Asset custody structure, Cybersecurity and AML/CFT enforcement effectiveness audits.

Token Inclusion and Review Committee Procedures, Smart Contract Independent Audit Report, and risk disclosure and transaction limit assessment systems for retail investors..

responsible officer (RO), Proof of Competency for Core Function Managers (MIC) and Licensed Representatives (LR), Dual certification of HKSI examination results and no criminal record.

Statutory compensation arrangement documents that comply with SFC regulatory requirements (including third-party insurance policy Binder or evidence of own funds set aside in trust).

Hong Kong Victoria Harbor and financial center urban environment
Commercial offices and financial institutions gather on both sides of Victoria Harbor in Hong Kong.

4. Hong Kong Huitong application and compliance support: Dual license application end-to-end process

Stage one: Pre-communication and structure placement (1-2months)

Conduct informal communication (Pre-application Engagement) with SFC to define product boundaries. Set up a company in Hong Kong and establish an AE subsidiary to obtain a TCSP license, Match Responsible Personnel (RO) with practical experience.

Stage 2: System construction and external evaluation (3-4months)

Write business plan and AML/CFT policy (including Travel Rule implementation plan), Finish 98% Cold wallet and private key physical infrastructure construction in Hong Kong. Engage a qualified independent third party to complete the external assessment report (EAR).

Stage three: WINGS declaration and administrative inquiries (4-6months)

Officially submit the "1+7+VASP" comprehensive application through the SFC WINGS system. Response to the China Securities Regulatory Commission’s response to the custody structure, Multiple rounds of questioning on the anti-money laundering system and token listing mechanism.

Stage four: AIP approved and officially licensed (1-2months)

Obtain conditional approval in principle (AIP) from the China Securities Regulatory Commission. After completing the final walkthrough of the system, After the insurance agreement takes effect and the core personnel are officially hired,, Replace a formal virtual asset trading license.

5. Analysis of SFC statutory fees and VASP rigid compliance operating costs

Categories of funds and fees Legal regulatory standards and amount assessment
statutory capital bottom line Minimum paid 50010,000 Hong Kong dollars; Minimum liquid capital 30010,000 Hong Kong dollars; An equivalent value must be kept independently 12 Legal non-crypto liquid assets for monthly operating expenses.
SFC official application and annual fee Institutional virtual asset services/category 1/category 7 application fees each 4,740Hong Kong dollar; Personal RO Application Fee 2,950HKD/item, LR application fee 1,790HKD/item. Pay an equal annual fee every year after obtaining the license.
External evaluation and system audit Hire an independent expert to issue an EAR assessment report of approx. 8010,000-3 million Hong Kong dollars; Annual network security and system penetration testing costs approx. 5010,000-1.5 million Hong Kong dollars.
Insurance and core labor costs Covering 100% of hot wallets/50% of cold wallets with premiums reaching millions. Dual license RO, The estimated annual salary expenditure for MIC and IT compliance teams is between 60010,000-15 million Hong Kong dollars.

 

香港虚拟资产服务提供者(VASP)牌照于2023年生效
Hong Kong Virtual Asset Service Provider (VASP) license to take effect in 2023

6. The absolute red line that triggers SFC disapproval or administrative penalties

Private key and cold wallet violations: not at least 98% of customers’ virtual assets are stored in cold wallets, Or the encryption seed/private key is not securely stored in an entity in Hong Kong, Directly trigger qualification rejection.

Derivatives and interest-earning business cross the line: Platform violates regulations by providing virtual asset futures to customers, Margin leverage trading, Or use customer assets without authorization to conduct DeFi pledge lending and interest-generating activities.

Not approved for M&A closing: Attempts to bypass approval by acquiring existing licensed/pending platforms, Significant equity (≥10%) "delivered first and then submitted for approval" without prior written approval from SFC, a serious illegal act.

7. Industry cutting edge: Approval and implementation cases of Chinese-funded/Chinese-backed entities

Internet brokerage cross-border

Futu (Panthertrade) with tiger (NEAR) approved

2025January, Cheetah Trading, a subsidiary of Futu Holdings, and YAX, a subsidiary of Tiger International, obtained VATP licenses in accordance with the law. This marks the successful extension of the leading Chinese-funded Internet securities firm's securities trading risk control system to the Web3 native asset trading field..

Cross-border payment platform is in place

DFX Labs, a wholly-owned subsidiary of Lianlian Digital, was approved

2024December, Cross-border payment giant Lianlian Digital 100% DFX Labs, a majority-owned company, successfully obtained a license under the simplified “one-time assessment” procedure, Establish a legal closed loop from compliance payment to underlying liquidation of virtual assets.

Primeval Web3 Predecessor

OSL and HashKey establish early compliance advantage

As the earliest compliance platform in Hong Kong, OSL Digital Securities and HashKey Exchange rely on their profound blockchain underlying technology and senior Chinese executive team background, Become one of the first licensed pioneers in the early stages of the regulatory framework.

Traditional brokerage VA upgrade

Victory Securities achieved retail and tens of billions of transaction volume breakthroughs

Victory Securities, a long-established Hong Kong securities company, will 1 License for virtual asset upgrade (VA Uplift), Became the first securities firm approved to carry out retail virtual asset transactions, And recorded a virtual asset trading volume of over 10 billion Hong Kong dollars in a compliant manner.

Stablecoin Sandbox Enters the Game

JD Coin Chain and Yuancoin Innovation Enter HKMA Sandbox

Hong Kong Monetary Authority launches stablecoin sandbox, JD Coin Chain, a subsidiary of JD Technology, Yuanbi Innovation, which is a shareholder of Zhongan Online, and institutions such as Standard Chartered Bank are among the first batch to enter the box, Test according to law 1:1 A fiat stablecoin issuance mechanism linked to the Hong Kong dollar.

8. Practical Legal Questions and Answers (FAQ): Analysis of licensing conditions and core compliance pain points

9. Relevant regulations, Regulatory information and further reading