What is the ASPIRe Roadmap?
ASPIRe (A Single Portal for Integrated Regulatory Engagement) is Hong Kong's comprehensive regulatory framework for virtual assets, designed to create a unified approach across different regulatory bodies (SFC, HKMA, C&ED) and activity types.
Three Pillars of ASPIRe
| Pillar | Regulator | Scope | Status |
|---|---|---|---|
| VASP Licensing | SFC | Virtual Asset Exchanges | ✅ Active (since June 2023) |
| Stablecoin Issuance | HKMA | Fiat-Referenced Stablecoins | 🟡 First licenses March 2026 |
| Dealer & Custodian | SFC + TCSP | OTC Trading, Asset Safekeeping | 🟡 Framework published March 2026 |
Updated Dealer Framework (March 2026)
Who Needs a Dealer License?
The updated framework clarifies licensing requirements based on the type of virtual assets traded:
| Activity | Asset Type | Required License | Regulator |
|---|---|---|---|
| OTC Trading | Security Tokens (e.g., tokenized bonds) | Type 1 (Dealing in Securities) | SFC |
| OTC Trading | Futures/Derivatives on VA | Type 2 (Dealing in Futures) | SFC |
| OTC Trading | Non-Security VA (BTC, ETH) | VASP License* | SFC |
| Advisory Services | Any Virtual Assets | Type 4/9 | SFC |
* OTC dealers exclusively trading non-security VAs may operate under the VASP framework with specific endorsements.
Capital Requirements
| License Type | Minimum Paid-Up Capital | Liquid Capital |
|---|---|---|
| Type 1 (Securities) | HKD 5,000,000 | HKD 3,000,000 |
| Type 1 + Type 9 | HKD 10,000,000 | HKD 5,000,000 |
| VASP (Non-Security VA) | HKD 5,000,000 | Varies by AUM |
Updated Custodian Framework
Dual Licensing Requirement
Virtual asset custodians in Hong Kong must obtain:
- Trust or Company Service Provider (TCSP) License - from Companies Registry
- SFC Type 1 License - if custody involves dealing in securities tokens
Custody Standards
| Requirement | Standard |
|---|---|
| Asset Segregation | Client assets must be fully segregated from custodian's own assets |
| Cold Storage | Minimum 98% of client assets in cold/offline storage |
| Insurance | Minimum HKD 50 million coverage for theft/hacking |
| Key Management | Multi-signature (at least 2-of-3) required for transactions |
| Audit | Annual SOC 2 Type II audit + quarterly proof of reserves |
| Disaster Recovery | Geographic redundancy with RTO < 4 hours |
Custodian Capital Requirements
| Assets Under Custody (AUC) | Minimum Capital | Insurance Requirement |
|---|---|---|
| < HKD 500M | HKD 10,000,000 | HKD 50,000,000 |
| HKD 500M - 2B | HKD 25,000,000 | HKD 100,000,000 |
| > HKD 2B | HKD 50,000,000 | HKD 200,000,000 |
Implementation Timeline
Transition Arrangements
Transition Requirements
- Submit notification of intent to apply by April 30, 2026
- Complete license application by June 30, 2026
- Implement enhanced AML/KYC procedures immediately
- Maintain detailed transaction records for regulatory review
- Provide monthly operational reports to SFC during transition
APAC Comparison: Dealer & Custodian Licensing
| Jurisdiction | Dealer License | Custodian License | Min. Capital |
|---|---|---|---|
| 🇭🇰 Hong Kong | Type 1 / VASP | TCSP + SFC | HKD 5-50M |
| 🇸🇬 Singapore | MAS MPI / CMS | Trust Company | SGD 250K-1M |
| 🇯🇵 Japan | JFSA CAESB | Custodial CAESB | JPY 10M+ |
| 🇦🇺 Australia | AFSL (pending) | AFSL + Trust | AUD 500K+ |
| 🇰🇷 Korea | VASP (FSC) | Included in VASP | KRW 3B |
Compliance Checklist for Operators
🏢 OTC Dealers
- Assess asset classification (security vs non-security)
- Determine applicable license type(s)
- Ensure capital adequacy (HKD 5-10M minimum)
- Implement AML/KYC program per SFC guidelines
- Establish transaction monitoring system
- Appoint Responsible Officers (min. 2)
- Submit notification of intent by April 30, 2026
🔐 Custodians
- Obtain TCSP license from Companies Registry
- Register with SFC under new framework
- Implement cold storage (98% minimum)
- Establish multi-sig key management
- Secure insurance coverage (HKD 50M+)
- Complete SOC 2 Type II audit
- Implement proof of reserves reporting
Impact on Market Participants
Banks & Financial Institutions
Opportunity: Banks like HSBC, Standard Chartered, and local banks (Bank of China HK, HKEX) are well-positioned to offer regulated custody and dealing services, leveraging existing licenses and capital.
Existing OTC Desks
Action Required: Unregulated OTC desks must either obtain appropriate licenses or exit the market by December 2026. Key players like Genesis, Circle Trade, and local desks need to assess their licensing pathway.
Crypto-Native Custodians
Compliance Path: Custodians like Hex Trust, OSL, and Deribit Custody can apply for the new framework. The enhanced requirements (98% cold storage, insurance) align with industry best practices.
Frequently Asked Questions
Q: What is the SFC ASPIRe Roadmap?
ASPIRe (A Single Portal for Integrated Regulatory Engagement) is the SFC's comprehensive roadmap for regulating Hong Kong's virtual asset industry. It covers VASP licensing, OTC dealing, custody services, and tokenized securities, with full implementation targeted by mid-2026.
Q: What licenses are required for crypto OTC dealers in Hong Kong?
Crypto OTC dealers dealing in securities tokens require a Type 1 (Dealing in Securities) license from the SFC. Non-security virtual assets fall under the VASP regime. The updated framework clarifies which activities trigger which license requirements.
Q: What are the custody requirements under the new framework?
Custodians must obtain a TCSP license and meet enhanced requirements including: 98% cold storage, HKD 50M minimum insurance, multi-signature key management, and annual SOC 2 Type II audits.
Q: When will the new Dealer & Custodian framework take effect?
The framework is effective immediately with a transition period until December 2026. Operators must submit applications by June 30, 2026 to continue operating during the transition.
Q: How does ASPIRe relate to HKMA's stablecoin regime?
ASPIRe integrates with HKMA's stablecoin licensing (under the Stablecoin Bill) to create a comprehensive framework. Stablecoin issuers are regulated by HKMA, while exchanges and custodians holding stablecoins fall under SFC's ASPIRe framework.
Q: What are the capital requirements for dealers and custodians?
OTC Dealers: HKD 5-10 million minimum paid-up capital depending on license type. Custodians: HKD 10-50 million based on AUC, plus insurance coverage of HKD 50-200 million.