On 26 May 2026, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) published consultation conclusions on the legislative proposal to regulate virtual asset advisory and virtual asset management service providers in Hong Kong. The consultation attracted 51 responses and received broad market support for the proposed regimes. The FSTB and SFC will now finalise the legislative proposals under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and aim to introduce a bill into the Legislative Council in 2026.
The proposed virtual asset advisory regime is aligned with Type 4 regulated activity (advising on securities) under the Securities and Futures Ordinance (Cap. 571), adapted for virtual assets. The proposed virtual asset management regime is aligned with Type 9 regulated activity (asset management) under Cap. 571, adapted for virtual assets. Both regimes will be established under Cap. 615 and will cover licensing criteria, fit-and-proper requirements, conduct obligations, and anti-money laundering and counter-terrorist financing measures specific to virtual asset advisory and management activities. The consultation conclusions confirmed the overall design of both regimes as proposed.
Portfolio managers and investment advisers who provide virtual asset-specific services to clients in Hong Kong will require a licence under the new AMLO regime before commencing or continuing those activities once the bill is enacted. Licensed corporations already conducting Type 4 or Type 9 activities under Cap. 571 must assess whether their virtual asset-related services require a separate AMLO licence or whether transitional arrangements will apply. Offshore managers and advisers who market virtual asset strategies to Hong Kong investors face the same licensing threshold, regardless of whether they maintain a local presence.
The May 2026 consultation conclusions on advisory and management follow earlier consultation conclusions on virtual asset dealing and virtual asset custody regimes, issued in 2025. The FSTB and SFC concurrently launched a further public consultation on two additional virtual asset service provider categories not covered by the four concluded regimes. The legislative bill incorporating all concluded regimes has not yet been introduced, and the exact sequencing of enactment and transitional provisions will be confirmed when the bill is published. Once legislated, the four-regime coverage of the virtual asset market will give Hong Kong one of the more detailed VASP licensing structures in Asia.
Licentium advises on virtual asset regulatory licensing in Hong Kong and other jurisdictions and can draw on a partner network for Hong Kong-specific legal counsel. Fund managers, investment advisers, and fintech operators assessing their licensing obligations under the proposed AMLO virtual asset regimes are welcome to contact us. Work we undertake includes virtual asset licensing applications, regulatory gap analysis for portfolio managers with virtual asset mandates, AMLO compliance programmes, and cross-border regulatory strategy for virtual asset fund structures.