Licensing Virtual Asset Service Providers in Hong Kong 2026: Dealers, Custodians, Advisers, and Managers

Hong Kong is preparing four new licensing regimes for virtual asset service providers — dealers, custodians, advisers, and asset managers — supplementing the already-established regime for trading platforms (VATP), through amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

The Securities and Futures Commission (SFC) published its ASPIRe regulatory roadmap on 19 February 2025; consultations on the dealer and custodian regimes launched 27 June 2025, and on advisers and managers on 24 December 2025.

⚠ As of July 2026, none of the four new regimes has come into force — all remain at the bill stage, with a bill planned for introduction to the Legislative Council (LegCo) sometime in 2026; no exact introduction date has been announced in any source verified, including the most recent materials from June 2026.

These new regimes are fundamentally distinct from the already-established Virtual Asset Trading Platform (VATP) licensing regime, which has issued licences since 2023 and does not cover OTC dealing, private key custody, advisory services, or asset management as separate regulated activities.

1. ASPIRe: the SFC’s Regulatory Roadmap

ASPIRe is a policy document published by the SFC setting out the regulator’s approach to virtual assets across five pillars.

ASPIRe was published by the Securities and Futures Commission on 19 February 2025; the new dealer and custodian licensing regimes implement the “Access” pillar (access to Hong Kong’s virtual asset market) under this roadmap.

2. The Full Consultation and Conclusions Timeline

Date	Event
19 February 2025	The SFC published its five-pillar ASPIRe regulatory roadmap
27 June 2025	The FSTB and SFC jointly published two consultation papers on licensing VA dealers and custodians
24 December 2025	Consultation conclusions on the dealer and custodian regimes published (over 190 responses received); a further consultation on two new regimes — advisers and managers — launched simultaneously
23 January 2026 (corrected on repeat verification via the SFC document itself; one secondary source cited 26 January)	The comment period for the further consultation on advisers and managers closed — 51 submissions received, per the SFC’s own document
26 May 2026	Consultation conclusions on the adviser and manager regimes published — no significant modifications from the original consultation paper
Sometime in 2026 (no date announced)	A bill is planned to be introduced to the Legislative Council (LegCo) to implement all four regimes through AMLO amendments

ℹ Over 190 responses were received for the dealer and custodian consultation — an indicator of broad market interest in the new regimes.

3. The Legal Basis: Amendments to an Existing Law, Not a New Act

The new regimes are implemented not through a standalone, dedicated virtual asset law, but through amendments to the already-existing Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

⚠ It is important not to confuse the AMLO (the legal basis for dealers, custodians, advisers, and managers) with the legal basis of the VATP regime — both mechanisms ultimately rest on the same ordinance (Cap. 615), but regulate different activities through different sections of it.

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4. The Virtual Asset Dealer Regime

The virtual asset dealer regime regulates over-the-counter (OTC) dealing — buying and selling virtual assets outside trading platforms.

Per the consultation conclusions, the virtual asset dealer regime will be closely aligned with the requirements for Type 1 (dealing in securities) regulated activity under the Securities and Futures Ordinance, with similar exemptions under consideration.

ℹ Virtual asset dealers will be required to custody client virtual assets with custodians licensed under the new regime, rather than holding them directly themselves.

5. The Virtual Asset Custodian Regime

The virtual asset custodian regime focuses on managing risks related to safekeeping private keys of client virtual assets within Hong Kong.

The new custodian regime is oriented toward the standards applied to traditional financial custodians and creates a two-tier market structure, separating trading (VATP) and custody (the new custodian regime) as distinct regulated activities.

6. The Adviser and Asset Management Regimes

A further consultation, launched at the same time as the dealer and custodian conclusions, covers two additional new regulated activities — advising on and managing virtual assets.

The consultation on the adviser and manager regimes concluded 26 May 2026; the conclusions contain no significant modifications from the original consultation paper.

✅ The intended regulatory principle is “same business, same risks, same rules”: standards for virtual asset advisers and managers are comparable to already-existing requirements for advisory and management services in traditional securities.

7. Regulatory Background: A Change of Responsible Authority

⚠ Originally, in early 2024, the FSTB proposed licensing OTC virtual asset dealing through the Commissioner of Customs and Excise (CCE). Responsibility was subsequently transferred to the SFC (and the HKMA for banks and stored value facilities) to avoid regulatory fragmentation across different authorities.

8. How This Differs From the Existing VATP Regime

Parameter	VATP (current regime)	New regimes: dealers/custodians/advisers/managers
Legal basis	Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Schedule 3B	The same AMLO (Cap. 615), but new regulated activities introduced by separate amendments
Status as of July 2026	In force, licences issued since 2023	A bill has not yet been introduced to LegCo; expected sometime in 2026
What it regulates	Operators of virtual asset trading platforms (exchanges)	OTC dealing, private key custody, advisory services, asset management
Comparable framework	A standalone regime specific to exchanges	Dealers — aligned with Type 1 (dealing in securities) under the SFO; custodians — aligned with traditional financial custodian standards

⚠ A VATP licence does not automatically cover dealer, custodian, adviser, or manager activity — these are separate regulated activities requiring separate licensing under the new regimes once they take effect.

9. The Territorial Reach of the Licensing Requirement

Per the consultation materials, a person without the appropriate licence may not actively market virtual asset dealing, custody, advisory, or management services to the Hong Kong public from anywhere in the world — the licensing requirement has an extraterritorial dimension with respect to marketing.

10. Step-by-Step Preparation for the New Regimes

1.     Determine whether planned or existing activity falls under one of the four new categories: dealing, custody, advisory, or asset management.

2.     Assess whether a VATP licence is already required for the specific activity, or whether it falls under the new regimes not yet in force.

3.     Initiate pre-application discussions with the SFC — the regulator expressly encourages this before the regimes formally take effect.

4.     Track the bill’s introduction to the Legislative Council during 2026 and any subsequent transition periods for existing market participants.

5.     When structuring dealing activity, arrange contractual custody relationships with a licensed custodian for client assets in advance.

11. Common Mistakes

•       Assuming a VATP licence covers both OTC dealing and asset custody. These are separate regulated activities with distinct licensing regimes — a trading platform operator’s licence does not substitute for a dealer or custodian licence.

•       Believing the new regimes are already in force as of July 2026. As of this article’s preparation date, all four regimes remain at the bill stage, not yet introduced to the Legislative Council.

•       Underestimating the extraterritorial reach of the licensing requirement. Actively marketing relevant services to the Hong Kong public from abroad without a licence falls under the same requirement as domestic activity.

•       Delaying contact with the SFC until the regimes formally take effect. The regulator expressly encourages pre-application discussions now, so market participants can obtain more information and prepare in advance.

12. Who This Information Fits

•       Companies already providing, or planning to provide, OTC dealing, custody, advisory, or asset management services for virtual assets in Hong Kong. It is essential for them to track the specific requirements of the new regimes before they come into force.

13. Who This Does Not Fit

•       Operators already licensed under the VATP regime with no plans to expand into dealing, custody, advisory, or management separately from the trading platform. For them, the existing VATP licence remains sufficient for exchange operations.

14. When Professional Verification Is Essential

Self-assessment is worth supplementing with specialist advice when: determining the applicable regime for a specific business model; initiating pre-application discussions with the SFC; and assessing transition provisions for existing market participants once the bill is introduced.

FAQ

What is the ASPIRe roadmap?

The SFC’s regulatory roadmap for virtual assets, published 19 February 2025, setting out the regulator’s approach across five pillars.

Have the new dealer and custodian licensing regimes come into force?

No, as of July 2026 all four new regimes remain at the bill stage, with a bill planned for introduction to the Legislative Council sometime in 2026.

Does a VATP licence cover virtual asset dealing?

No, these are separate regulated activities with their own licensing regimes.

What existing framework do virtual asset dealer requirements mirror?

The requirements for Type 1 (dealing in securities) regulated activity under the Securities and Futures Ordinance.

Who was originally meant to license OTC virtual asset dealing in Hong Kong?

The Commissioner of Customs and Excise (CCE), per the FSTB’s original early-2024 proposal; responsibility was later transferred to the SFC.

Key Takeaways

•       The ASPIRe roadmap was published by the SFC on 19 February 2025.

•       The dealer and custodian consultations concluded 24 December 2025; the adviser and manager consultation concluded 26 May 2026.

•       All four new regimes are implemented through AMLO (Cap. 615) amendments, not a new law.

•       As of July 2026, none of the regimes has come into force — a bill is expected sometime in 2026.

•       The licensing requirement has an extraterritorial dimension for active marketing to the Hong Kong public.

•       The new regimes are fundamentally distinct from the already-established VATP regime, which covers only trading platforms.

Summary

Hong Kong is preparing four new licensing regimes for virtual asset service providers — dealers, custodians, advisers, and managers — implemented through amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), rather than a new standalone law. The Securities and Futures Commission published its ASPIRe regulatory roadmap on 19 February 2025; consultations on the dealer and custodian regimes launched 27 June 2025 and concluded 24 December 2025 (over 190 responses received); the consultation on adviser and manager regimes concluded 26 May 2026 with no significant modifications. As of July 2026, none of the four regimes has come into force — a bill is planned for introduction to the Legislative Council sometime in 2026, with no exact date announced. The virtual asset dealer regime will align with Type 1 (dealing in securities) requirements under the Securities and Futures Ordinance; the custodian regime is oriented toward traditional financial custodian standards. Licensing of OTC dealing was originally proposed in 2024 through the Commissioner of Customs and Excise, but responsibility was later transferred to the SFC to avoid regulatory fragmentation. The new regimes are fundamentally distinct from the already-established VATP regime for virtual asset trading platforms, in force since 2023.

Sources

• Securities and Futures Commission Hong Kong — official press release on concluding the dealer and custodian consultations and launching the further consultation, 24 December 2025 (sfc.hk)

• Financial Services and the Treasury Bureau — Consultation Conclusions: Legislative Proposal to Regulate Virtual Asset Custodian Services, official document (fstb.gov.hk)

• SFC — Consultation Conclusions on the adviser and manager regimes (refNo=25CP12), confirming the 23 January 2026 deadline and 51 submissions received (sfc.hk)

• Davis Polk — Hong Kong Concludes Consultation on Virtual Asset Advisory and Asset Management Regimes, June 2026 (davispolk.com)

• Gibson Dunn — Hong Kong Concludes Consultations on Regulation of Virtual Asset Dealing and Custodian Services, January 2026 (gibsondunn.com)

• Deacons — Hong Kong’s Virtual Asset Licensing Regime: Key Updates, January 2026 (deacons.com)

Disclaimer

This article is for informational purposes only and does not constitute legal or consulting advice. The licensing regimes described are at the bill stage and have not yet come into force — final requirements may change during Legislative Council review. Verify the current status directly on the official sfc.hk portal and consult a qualified legal adviser in Hong Kong before making decisions. Information is accurate as of July 2026.