The Hong Kong Securities and Futures Commission published two circulars on 20 April 2026. Circular reference 26EC23 governs secondary trading of tokenised SFC-authorised investment products. A companion circular updates the SFC's earlier guidance on tokenisation. The new regime applies to existing SFC-authorised investment products that meet the conditions set out in the circulars.
Secondary trading is permitted only on SFC-licensed virtual asset trading platforms operating under the Type 1 and Type 7 regulated activity regime and the SFC's VATP Guidelines. The SFC permits 24-by-7 on-platform auto-matching. Settlement may use regulated fiat-referenced stablecoins issued under the Stablecoins Ordinance, which took effect 1 August 2025, or tokenised deposits. The first eligible product class is SFC-authorised money market funds. Investor protection conditions apply to token ownership records, fair pricing, and operational resilience. The Code on Unit Trusts and Mutual Funds and the Securities and Futures Ordinance Part IV authorisation regime continue to apply to the underlying products.
Authorised asset managers, custodians, and transfer agents can offer round-the-clock subscription and redemption through licensed VATPs. Licensed VATPs gain a new on-platform business line for SFC-authorised products beyond virtual assets. Stablecoin issuers licensed under the Stablecoins Ordinance gain a regulated settlement use case. Banks and licensed trust companies that operate tokenised deposit infrastructure can now support investment product settlement. As of March 2026 thirteen tokenised products were authorised for public offering with assets under management of HK$10.7 billion.
Distribution of tokenised SFC-authorised products through traditional intermediaries remains permitted. Cross-border distribution into other jurisdictions still requires local product registration or applicable exemptions. The SFC retains discretion to limit the product scope and may expand it beyond money market funds.
Licentium advises fund managers, VATPs, custodians, stablecoin issuers, and banks on Hong Kong tokenisation, secondary trading authorisations, and regulated stablecoin settlement, and coordinates Hong Kong counsel and international counterparts. Contact us if you intend to authorise a tokenised product or list one on a Hong Kong VATP. Work we undertake includes SFC authorisation filings, VATP licensing, Stablecoins Ordinance compliance, tokenised fund prospectus drafting, and custody arrangement reviews.
Source: Securities and Futures Commission of Hong Kong, Circular on Secondary Trading of Tokenised SFC-authorised Investment Products, ref. 26EC23, 20 April 2026, https://apps.sfc.hk/edistributionWeb/gateway/EN/circular/doc?refNo=26EC23, confirmed 15 May 2026.
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