On 26 May 2026, the Securities and Futures Commission (SFC) and the Financial Services and the Treasury Bureau (FSTB) published consultation conclusions on proposed licensing regimes for virtual asset advisory service providers and virtual asset management service providers in Hong Kong. The consultation attracted 51 submissions from market participants, industry associations, business and professional organisations, and individuals. The FSTB and SFC confirmed their intention to introduce implementing legislation into the Legislative Council in 2026.
The regulatory basis for both regimes is the same business, same risks, same rules principle embedded in Hong Kong's financial regulation. Licensing requirements imposed on VA advisory service providers will align with those applicable to licensed corporations and registered institutions providing VA advisory services under the existing SFC-HKMA Joint Circular on intermediaries' virtual asset-related activities. The SFC holds licensing and supervisory authority over both new categories of regulated person. The VA management service provider regime applies the same principle to discretionary portfolio management of virtual assets.
Virtual asset fund managers, crypto-asset portfolio service providers, and advisory firms soliciting or serving clients in Hong Kong in relation to virtual asset products will require SFC authorisation under the new regimes once the implementing legislation takes effect. Firms currently providing VA advisory or management services without SFC licensing, or under any existing carve-out, must assess whether their activities fall within the expanded regulated perimeter and plan for authorisation applications.
The May 2026 consultation conclusions follow the December 2025 conclusions on VA dealer and custodian regimes, which received broad market support. The four licensing categories (VA dealing, custody, advisory, and management) together constitute the full licensing architecture for virtual asset service providers in Hong Kong, completing the regulatory structure contemplated when the SFC's voluntary virtual asset trading platform licensing regime launched in 2023.
Licentium assists virtual asset businesses with Hong Kong licensing strategy, including SFC licence applications and regulatory perimeter analysis. Contact us to discuss your position under the incoming VA advisory and management regimes. Work we undertake includes SFC VATP licence applications, readiness assessments for the new VA advisory and management regimes, compliance programme design for crypto-asset fund managers, cross-border regulatory structuring for Asia-Pacific operations, and monitoring of Legislative Council progress on VA licensing bills.