🇭🇰 Hong Kong VASP License Requirements 2026
Complete guide to Virtual Asset Trading Platform (VATP) licensing under SFC regulations
📊 License Status (Feb 2026): 10 VATPs fully licensed, 11 applications pending/deemed licensed. The SFC approved Victory Fintech (VDX) in February 2026 — the first new approval since June 2025.
📋 Quick Overview
| Aspect | Details |
|---|
| Regulator | Securities and Futures Commission (SFC) |
| Governing Law | Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) |
| License Type | Virtual Asset Trading Platform (VATP) License |
| Application Fee | HKD 780,000 |
| Annual Fee | HKD 295,000 |
| Minimum Capital | HKD 5 million (paid-up) + HKD 3 million (liquid) |
| Processing Time | 12-18 months typical |
📝 License Requirements
1. Corporate Structure
- Incorporated in Hong Kong
- Principal place of business in Hong Kong
- At least 2 Responsible Officers (ROs) approved by SFC
- At least 1 Executive Director resident in Hong Kong
2. Capital Requirements
| Requirement | Amount |
|---|
| Minimum Paid-up Share Capital | HKD 5,000,000 |
| Minimum Liquid Capital | HKD 3,000,000 or variable based on operations |
| Insurance Coverage | Required for client assets (amount varies) |
3. Operational Requirements
✅ Compliance Checklist
- Client Asset Segregation: 98% cold wallet, 2% hot wallet maximum
- AML/CFT: Full compliance with FATF Travel Rule
- KYC: Robust customer due diligence and ongoing monitoring
- Custody: Licensed custodian or internal custody with SFC approval
- Cybersecurity: ISO 27001 or equivalent standards
- Token Admission: Due diligence process for listing new tokens
- Investor Protection: Professional investors only (unless retail approved)
- Market Surveillance: Systems to detect manipulation
4. Responsible Officers (ROs)
- Minimum 2 ROs approved by SFC
- Relevant experience in financial services (typically 5+ years)
- Pass SFC fit and proper assessment
- At least 1 RO with virtual asset experience
- Executive Director must also be RO
📊 Licensed Platforms (Feb 2026)
| Platform | License Date | Status |
|---|
| OSL Digital Securities | Dec 2020 | ✅ Licensed |
| HashKey Exchange | Nov 2023 | ✅ Licensed |
| HKVAX | Jun 2024 | ✅ Licensed |
| HKbitEX | Jun 2024 | ✅ Licensed |
| Accumulus | Jun 2024 | ✅ Licensed |
| DFX Labs | Jun 2024 | ✅ Licensed |
| Hong Kong Digital Asset Exchange (HKD.com) | Jun 2024 | ✅ Licensed |
| Thousand Whales Technology | Jun 2024 | ✅ Licensed |
| PantherTrade | Jun 2024 | ✅ Licensed |
| Victory Fintech (VDX) | Feb 2026 | ✅ Licensed |
| Others | - | ⏳ Pending/Deemed Licensed |
⚠️ Note: "Deemed licensed" platforms are operating under transitional arrangements. They must obtain full licenses or cease operations by the regulatory deadline.
❓ Frequently Asked Questions
How much does a Hong Kong VASP license cost?
Direct fees:
- Application fee: HKD 780,000
- Annual renewal: HKD 295,000
Total setup costs: HKD 5-20 million typically, including legal, compliance, technology infrastructure, and operational setup.
How long does the licensing process take?
Typical timeline: 12-18 months from application submission, including:
- Document preparation: 2-3 months
- SFC initial review: 3-6 months
- Q&A and clarifications: 3-6 months
- On-site inspection and testing: 2-3 months
- Final approval: 1-2 months
Can retail investors use licensed platforms?
Yes, but with restrictions. SFC-licensed platforms can serve retail investors if they:
- Obtain specific retail authorization from SFC
- Implement additional investor protection measures
- List only tokens that pass retail admission criteria
- Conduct suitability assessments
What tokens can be listed?
VATPs must conduct due diligence on each token. Generally:
- Allowed: BTC, ETH, and major tokens meeting SFC criteria
- Restricted: Security tokens (require additional Type 1 license)
- Prohibited: Privacy coins, unregistered securities
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Last Updated: February 26, 2026
Sources: SFC, AMLO, Legislative Council
Disclaimer: This is for educational purposes only. Consult qualified professionals for licensing advice.
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