Detailed overview
Hong Kong at a glance
Hong Kong regulates crypto through a dual-regulator model: the SFC licenses virtual asset trading platforms (VATPs) under the AMLO and SFO (mandatory since 1 June 2023), and the HKMA licenses fiat-referenced stablecoin issuers under the Stablecoins Ordinance (Cap. 656; effective 1 August 2025; HKD 25m capital, full reserves). New SFC VA dealing and custody regimes were proposed in 2025, with the ASPIRe and LEAP/Policy Statement 2.0 roadmaps driving a tokenisation push. Payments and e-money run through the HKMA's Stored Value Facility (SVF) licence under the PSSVFO, plus Money Service Operator (MSO) registration with Customs & Excise, and banking under the Banking Ordinance. Gambling is among the world's most restrictive: under the Gambling Ordinance (Cap. 148) and Betting Duty Ordinance (Cap. 108), only the Hong Kong Jockey Club is authorised (horse racing, football, Mark Six), online betting is HKJC-only, and a 2025 basketball-betting law was suspended in April 2026 pending a prediction-markets review.
Crypto regime — dual-regulator, hub-building, mid-build-out:
- VATP licensing (SFC; from 1 June 2023; AMLO + SFO) — mandatory for centralised VA trading platforms serving or actively marketing to Hong Kong; client assets must be held by a wholly-owned subsidiary (no third-party custody); investor protection, governance and disclosure rules; professional-investor threshold HKD 8m and limited retail access
- November 2025 SFC circulars — VATPs may integrate order books with global affiliate platforms (shared liquidity) and expand products (distribution of VA products, tokenised securities and stablecoins, and wider custody); the 12-month track-record requirement was lifted for professional-investor assets and HKMA-licensed stablecoins
- Stablecoins Ordinance (Cap. 656; LegCo 21 May 2025; effective 1 August 2025) — HKMA licensing of fiat-referenced stablecoin issuers; HKD 25m paid-up capital, full segregated reserve backing, par redemption; only licensed FRS may be offered to the public and only HKMA-licensed FRS to retail; first licences expected from early 2026; penalties up to HKD 5m and seven years' imprisonment
- VA dealing and custody (proposed; FSTB/SFC consultation 27 June 2025) — new AMLO-based licences to close gaps under the "same activity, same risks, same regulation" principle; no deeming arrangement; indicative requirements include around HKD 5m paid-up and HKD 3m liquid capital, retail-access restrictions, and (for custodians) permission to offer staking
- Policy roadmaps — the SFC's ASPIRe roadmap (February 2025) and the Policy Statement 2.0 / LEAP framework (June 2025) target real-world-asset tokenisation (tokenised bonds review in Q1 2026) and ecosystem growth; an NFT review is flagged for around 2027
- AML/CFT — AMLO obligations (customer due diligence, the Travel Rule, suspicious-transaction reports) supervised by the SFC for VATPs and the HKMA for stablecoins and banks
- Tax — no capital-gains tax; profits tax (16.5% for corporations; two-tier 8.25% on the first HKD 2m) applies to trading businesses
Payments and e-money regime (HKMA-led):
- PSSVFO (Cap. 584) — the HKMA licenses Stored Value Facilities (multi-purpose e-wallets and prepaid cards such as Octopus, Alipay HK, WeChat Pay HK and Tap & Go) and oversees designated Retail Payment Systems, including the Faster Payment System (FPS)
- SVF licence — minimum HKD 25m paid-up capital (or equivalent), float protection and AML/CFT; single-purpose facilities exempt; banks deemed licensed; SVF licensees need no separate MSO licence
- MSO licence (AMLO; Customs & Excise) — required to operate a money-changing or remittance business, with AML/CFT customer-due-diligence and record-keeping obligations administered by the Money Service Supervision Bureau
- Banking — HKMA three-tier authorization under the Banking Ordinance (licensed banks, restricted-licence banks, deposit-taking companies), with substantial capital, governance and prudential requirements
- Infrastructure — FPS real-time rail; e-CNY pilots; cross-boundary remittance and Payment Connect with the Mainland
- Currency: the Hong Kong dollar (HKD), pegged to the US dollar under the Linked Exchange Rate System (band 7.75–7.85)
Gambling regime — among the world's most restrictive:
- Gambling Ordinance (Cap. 148) — all gambling is unlawful unless authorised; bookmaking and betting with an unauthorised bookmaker are offences; enforced by the Hong Kong Police Force
- Betting Duty Ordinance (Cap. 108) — authorises and taxes HKJC betting; policy is set by the Home and Youth Affairs Bureau, with the Betting and Lotteries Commission advising
- Hong Kong Jockey Club (HKJC) — the sole authorised operator (horse racing, football betting, Mark Six lottery); a not-for-profit that is among Hong Kong's largest taxpayers and charities (HK$28.8bn in betting duties and profits tax in 2024/25)
- Online betting — offered only by the HKJC; private and offshore online gambling is prohibited; bets on local Hong Kong teams and games are banned; minimum age 18; credit betting prohibited
- Betting duty — horse racing 72.5%–75% of net stake receipts (progressive), football betting 50%, lotteries 25% of proceeds
- Basketball betting — the Betting Duty (Amendment) Bill 2025 (passed September 2025) legalised basketball betting with a 50% duty and the HKJC as expected sole operator, but the HYAB suspended implementation in April 2026 to study prediction-market risks
- Harm-minimisation — the Ping Wo Fund finances prevention and treatment; strict responsible-gambling controls apply
Last verified: May 2026. Reference rate: USD 1 = HKD 7.80 (HKD 1 ≈ USD 0.128). The Hong Kong dollar is pegged to the US dollar under the Linked Exchange Rate System, with the HKMA keeping it within a 7.75–7.85 band.
Hong Kong is a dual-regulator digital-asset hub: the SFC licenses VATPs (and is building VA dealing and custody regimes) while the HKMA licenses fiat-referenced stablecoin issuers (from August 2025) and runs the SVF payments regime — all against a USD-pegged currency. Gambling, by contrast, is locked to a single not-for-profit operator (the HKJC), with online betting HKJC-only and basketball betting legalised but suspended in 2026.
Is there a crypto licence in Hong Kong?
Yes — several, across two regulators. The SFC licenses virtual asset trading platforms (mandatory since 1 June 2023) and security/tokenised-securities activity; the HKMA licenses fiat-referenced stablecoin issuers under the Stablecoins Ordinance (from 1 August 2025); and new SFC regimes for VA dealing and custody were proposed in 2025. Hong Kong is actively building a regulated hub, but the bar is high.
The legal foundation:
- AMLO + SFO — VATP licensing by the SFC (from 1 June 2023); security and tokenised-securities activities under the SFO
- Stablecoins Ordinance (Cap. 656) — HKMA licensing of fiat-referenced stablecoin issuers (from 1 August 2025; HKD 25m capital, full reserves, par redemption)
- Proposed VA dealing / custody regimes — FSTB/SFC 2025 consultation; not yet in force; no deeming arrangement
- Policy roadmaps — ASPIRe (February 2025) and LEAP / Policy Statement 2.0 (June 2025); real-world-asset tokenisation focus
- AML/CFT — AMLO obligations supervised by the SFC (VATPs) and HKMA (stablecoins and banks)
Structure:
- A Hong Kong-incorporated (or registered) company with real local presence, responsible/executive officers passing fit-and-proper tests, and (for VATPs) an external assessor's report
- VATP client assets held by a wholly-owned subsidiary (no third-party custody); professional-investor threshold HKD 8m; limited, condition-heavy retail access
- Stablecoin issuers: HKD 25m capital, segregated high-quality liquid reserves, issuance-focused operations; only HKMA-licensed fiat-referenced stablecoins may reach retail
Operational reality:
- Hong Kong is "regulated yet innovation-friendly" — the 2025 reforms (shared global liquidity, expanded products, stablecoin framework) deliberately widen the regulated market, but onboarding, custody and assessor requirements are demanding
- The dual-regulator model means overlapping SFC/HKMA obligations; map each token and activity to the right regime early, and budget for both supervisors where products span trading and stablecoin issuance
- Licences do not passport into the EU (a MiCA CASP authorisation is separate); independent Hong Kong legal, regulatory and tax counsel and early SFC/HKMA engagement are essential
Payments & E-money (HKMA — Stored Value Facilities; Customs & Excise — MSO)
Best for e-wallet, prepaid, remittance and money-changing operators prepared to obtain an HKMA SVF licence or an MSO registration and meet Hong Kong's capital, float-protection and AML standards.
What it is: The HKMA licenses multi-purpose Stored Value Facilities under the PSSVFO and oversees retail payment systems; the Customs & Excise Department registers Money Service Operators for money-changing and remittance; deposit-taking requires HKMA bank authorisation under the Banking Ordinance.
Who it suits: E-wallet and prepaid-card issuers, remittance and money-changing businesses, merchant-payment providers, and banks and fintechs targeting Hong Kong and Greater Bay Area flows.
Covers: Multi-purpose stored value (e-money), retail payments and FPS participation (SVF); money-changing and remittance (MSO); deposit-taking and full banking (authorized institutions).
Operational requirement: A Hong Kong entity; an SVF licence (HKD 25m paid-up capital, float protection, AML/CFT) or MSO registration; fit-and-proper management; AML/CFT under the AMLO; HKMA conduct and technology-risk expectations; access to FPS and other rails.
Headline figures
- Primary instruments: Payment Systems and Stored Value Facilities Ordinance (Cap. 584); Anti-Money Laundering and Counter-Terrorist Financing Ordinance; Banking Ordinance
- Regulators: HKMA (SVF, retail payment systems, banking); Customs & Excise Department (MSO)
- Entry capital: SVF — HKD 25m paid-up (or equivalent) plus float safeguarding; MSO — no fixed minimum capital, registration-based
- Infrastructure: FPS real-time rail; e-CNY pilots; cross-boundary remittance and Payment Connect with the Mainland
- Reform pipeline: stablecoin-payments integration with the digital-asset framework; continued retail-payment modernisation
- Currency: HKD, USD-pegged under the Linked Exchange Rate System (band 7.75–7.85); no exchange controls
Is there a gambling licence in Hong Kong?
Effectively no — there is only one operator. Under the Gambling Ordinance and Betting Duty Ordinance, the government authorises the Hong Kong Jockey Club alone to offer horse-race betting, football betting and the Mark Six lottery (including online); all other gambling, and offshore/private online betting, is prohibited. A 2025 law legalising basketball betting (again HKJC-only) was suspended in April 2026.
The legal foundation:
- Gambling Ordinance (Cap. 148) — prohibition by default; bookmaking and betting with unauthorised bookmakers are offences
- Betting Duty Ordinance (Cap. 108) — authorises and taxes HKJC betting; Home and Youth Affairs Bureau sets policy, with the Betting and Lotteries Commission advising
- HKJC — sole authorised operator (horse racing, football, Mark Six); not-for-profit
- Enforcement — Hong Kong Police Force pursues unlawful and offshore gambling; bans apply to local-team bets and credit betting
Structure:
- Betting and lotteries — HKJC only; online betting HKJC-only; no commercial licences for other operators
- Basketball betting — legalised in 2025 (HKJC expected sole operator; 50% duty) but suspended in April 2026 pending a prediction-markets review
- Mahjong / tin kau parlours — a narrow, separately licensed land-based category
- Minimum age 18; strong responsible-gambling and AML controls; the Ping Wo Fund finances prevention and treatment
Gambling — Authorised Betting & Lotteries (HKJC; Betting Duty Ordinance)
Best for the Hong Kong Jockey Club and its partners; not for private, commercial or offshore operators of any kind.
What it is: Government authorisation (granted by the Secretary for Home and Youth Affairs) for the HKJC to conduct horse-race betting, football betting and the Mark Six lottery, taxed under the Betting Duty Ordinance.
Who it suits: The HKJC and its technology, integrity and content partners; not standalone or offshore B2C operators, which cannot be licensed.
Covers: Horse-race betting, football betting and the Mark Six lottery (including online), all by the HKJC; potentially basketball betting if the suspended 2025 regime is revived.
Operational requirement: Operation by the HKJC under government authorisation and licence conditions; high betting-duty payment; strict AML/CFT and responsible-gambling controls; bans on local-team bets, credit betting and underage participation; regular reporting and auditing.
Headline figures
- Primary instruments: Gambling Ordinance (Cap. 148); Betting Duty Ordinance (Cap. 108); Betting Duty (Amendment) Bill 2025 (basketball — suspended)
- Regulators: Home and Youth Affairs Bureau (policy and authorisation); Betting and Lotteries Commission (advisory); Hong Kong Police Force (enforcement)
- Market access: closed — HKJC only; no commercial or online licences for other operators
- Tax / duty: horse racing 72.5%–75% of net stake receipts (progressive); football 50%; lotteries 25% of proceeds; basketball 50% (suspended)
- Player protection: minimum age 18; no credit betting; no bets on local teams; Ping Wo Fund finances prevention and treatment
Costs and timelines at a glance
- Crypto: SFC VATP licence (AMLO + SFO; mandatory from 1 June 2023; subsidiary custody; HKD 8m professional-investor threshold); SFO for security and tokenised securities; HKMA stablecoin (FRS) licence (Cap. 656; from 1 August 2025; HKD 25m capital, full reserves); proposed VA dealing and custody regimes (2025; ~HKD 5m paid-up + HKD 3m liquid); ASPIRe and LEAP roadmaps; no capital-gains tax (profits tax 16.5%)
- Payments primary instruments: Payment Systems and Stored Value Facilities Ordinance (Cap. 584); Anti-Money Laundering and Counter-Terrorist Financing Ordinance; Banking Ordinance
- Payments regulators: HKMA (SVF, retail payment systems, banking); Customs & Excise (MSO)
- Entry capital: SVF — HKD 25m paid-up plus float protection; MSO — registration-based; bank authorisation — substantial and case-by-case
- Reform pipeline: first stablecoin licences (early 2026); VA dealing and custody regimes; real-world-asset / tokenised-bond review (Q1 2026); NFT review (~2027)
- Gambling: Gambling Ordinance + Betting Duty Ordinance; HKJC monopoly (horse racing 72.5%–75%, football 50%, lottery 25%); online HKJC-only; basketball betting legalised in 2025 but suspended in April 2026; minimum age 18
- Currency: HKD, USD-pegged under the Linked Exchange Rate System (7.75–7.85); no exchange controls
- FX: USD 1 = HKD 7.80 (HKD 1 ≈ USD 0.128)
Who Hong Kong suits and who it does not
Suitable for
- Virtual asset trading platforms and tokenised-securities operators able to meet the SFC's VATP and SFO requirements (Hong Kong company, responsible officers, subsidiary custody, external assessor) and willing to use the 2025 shared-liquidity and expanded-product reforms
- Fiat-referenced stablecoin issuers able to meet the HKMA framework — HKD 25m capital, full segregated reserves, par redemption — and target a regulated, retail-eligible market
- Institutional digital-asset, custody and real-world-asset tokenisation businesses attracted by the LEAP and ASPIRe hub strategy and a USD-pegged base
- E-wallet, prepaid, remittance and money-changing operators able to obtain an SVF licence (HKD 25m) or MSO registration and integrate with FPS
- Groups that value a USD-pegged currency, no capital-gains tax, deep banking and a Greater Bay Area gateway, with a clear two-regulator framework
Not suitable for
- Firms wanting a light-touch or purely offshore crypto base — Hong Kong's VATP, stablecoin and (proposed) dealing and custody regimes are demanding, with no deeming arrangement for the new regimes
- Crypto businesses needing EU passporting — Hong Kong licences do not passport (a MiCA CASP authorisation is separate)
- Payment or e-money firms unable to meet the HKD 25m SVF capital and float-protection requirements, or expecting an EU-style passport
- Any private, commercial or offshore gambling operator — betting is a closed HKJC monopoly, online gambling is HKJC-only, and offshore or private betting is a criminal offence
- Operators counting on near-term betting-market liberalisation — even legalised basketball betting was suspended in April 2026, underscoring Hong Kong's not-to-encourage-gambling policy