On 26 May 2026, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) jointly published their consultation conclusions on legislative proposals to create licensing regimes for virtual asset (VA) advisory and VA management service providers. The conclusions followed a one-month public consultation that closed in late January 2026 and received 51 submissions. The FSTB and SFC are now finalising the legislative proposals, targeting introduction of a bill into the Legislative Council within 2026.
The proposed regimes adopt the 'same activity, same risks, same regulation' principle. VA advisory service providers will be licensed under a regime aligned with Type 4 (advising on securities) regulated activity under the Securities and Futures Ordinance (Cap. 571). VA management service providers will be licensed under a regime aligned with Type 9 (asset management) regulated activity under Cap. 571. Both regimes will be enacted through amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
VA advisory and VA management service providers operating in Hong Kong, or marketing services to Hong Kong-based clients, will need to obtain a new licence under Cap. 615 once the bill passes. Fund managers, portfolio managers, and investment advisors currently holding Type 4 or Type 9 SFC licences must assess whether their existing licences cover VA activities or whether supplemental licensing is required under the new regimes. Firms providing incidental VA advisory services within broader financial planning mandates should also review their activity scope against the proposed licence perimeter.
Respondents sought clarification on exemptions for incidental VA advisory activities and on transitional arrangements for firms already conducting VA advisory or management activities before the new regimes take effect. These questions remain open pending the final bill text. The scope of extraterritorial application, particularly for foreign-registered VA managers with Hong Kong client books, was also raised during the consultation as requiring further regulatory guidance.
Licentium advises financial institutions, fund managers, and virtual asset businesses on licensing strategy and compliance across major Asia-Pacific regulatory regimes, including those administered by the SFC and the FSTB. We work with a partner network of Hong Kong-qualified solicitors and compliance specialists for local licensing matters. To discuss how these consultation conclusions affect your operations or licensing structure, contact us. Work we undertake includes virtual asset licensing advice, Type 4 and Type 9 SFC licence applications, AMLO compliance structuring, VA fund authorization support, and regulatory mapping across APAC jurisdictions.