The Securities and Futures Commission (SFC) and the Financial Services and the Treasury Bureau (FSTB) of Hong Kong published consultation conclusions on proposed licensing regimes for virtual asset advisory service providers and virtual asset management service providers on 26 May 2026. The consultation received 51 submissions and ran for one month after its launch in December 2025. The conclusions set out the proposed regulatory approach that will advance to legislative drafting and enactment. The proposals form part of the SFC ASPIRe strategic roadmap published on 19 February 2025.
The proposed regime applies the same business, same risks, same rules principle derived from the Securities and Futures Ordinance (Cap. 571). Virtual asset advisory service providers would require SFC authorisation to provide advice on virtual assets, modelled on Type 4 (advising on securities) and Type 6 (advising on corporate finance) regulated activities under Schedule 5 of the SFO. Virtual asset management service providers would be subject to requirements modelled on Type 9 (asset management) regulated activity conditions, including client asset segregation and portfolio valuation obligations. The advisory regime is technology-neutral.
Entities providing virtual asset portfolio management, investment advice referencing virtual assets, or distribution of virtual asset fund products must assess whether they will require authorisation under the new licensing categories once enacted. Firms already licensed under existing virtual asset trading platform operator or virtual asset fund manager conditions should review whether their current SFC authorisation covers advisory or management activities. Discretionary account managers with virtual asset exposure and fund distributors whose products include digital assets face the most direct licensing obligation under the proposed framework.
The consultation conclusions represent the SFC and FSTB's stated policy position, not enacted law. The timetable for introducing implementing legislation to the Legislative Council has not been confirmed. Transitional and grandfathering provisions for firms informally providing VA advisory or management services are not yet final. Firms should treat the conclusions as a near-term regulatory signal and begin internal readiness assessments rather than waiting for the legislation to be gazetted.
Licentium advises virtual asset businesses on Hong Kong licensing strategy across SFC and FSTB regulated activities. We may be able to assist or identify appropriate support through our partner network. Work we undertake includes VASP licensing under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, SFC Type 9 VA fund manager authorisation, VA advisory regime readiness assessments, multi-jurisdictional digital asset licensing, and regulatory affairs support for virtual asset market participants in Hong Kong.