The Hong Kong Stablecoin Issuer Licence: A Full Breakdown of the Stablecoins Ordinance (Cap. 656) in 2026

A Hong Kong stablecoin issuer licence is required of any person who, in the course of business, issues a specified stablecoin in Hong Kong, or issues outside Hong Kong a stablecoin referenced wholly or partly to the Hong Kong dollar. Licensing is administered by the Monetary Authority (HKMA). The regime has been in force since 1 August 2025.

The minimum paid-up share capital of an applicant is HKD 25,000,000, or an equivalent amount in another freely convertible currency, or other financial resources approved by the HKMA that equal or exceed that figure. The requirement sits in section 4 of Schedule 2 to the Stablecoins Ordinance and does not apply to applicants that are authorized institutions (banks).

The defining feature of the regime is its long arm over the Hong Kong dollar. Issuing a stablecoin referenced to the HKD requires an HKMA licence wherever the issuance takes place. An issuer incorporated anywhere in the world with no Hong Kong presence is caught by the peg alone. Actively marketing the activity to the Hong Kong public is a separate trigger, again regardless of where the marketing is conducted.

The practical context matters more than the statutory one. By the close of the first round the HKMA had received 36 applications and granted two licences, on 10 April 2026. This is not a strict regime on paper but a strict regime in practice, and entry should be planned against actual rather than stated throughput.

1. The Legal Framework and the Chain of Dates

The regime rests on one Ordinance and three regulator documents, and the regulator documents carry most of the practical requirements.

The Ordinance and its dates

•     The Stablecoins Ordinance (Cap. 656) was passed by the Legislative Council on 21 May 2025.

•     It was gazetted on 30 May 2025.

•     On 6 June 2025 a notice was gazetted appointing 1 August 2025 as the commencement date.

•     From 1 August 2025 the issuance of fiat-referenced stablecoins is a regulated activity in Hong Kong.

The dates of passage, gazettal and commencement differ: 21 May, 30 May and 1 August 2025 respectively. Some commentary describes the regime as "effective since July 2025", which is inaccurate; the commencement date appointed by the notice of 6 June 2025 is 1 August 2025.

HKMA documents

•     Explanatory Note on Licensing of Stablecoin Issuers (29 July 2025) — guidance on the licensing regime, the minimum criteria, application procedures and ongoing obligations, including the list of documents required from an applicant.

•     Guideline on Supervision of Licensed Stablecoin Issuers — the HKMA’s detailed expectations against each of the Schedule 2 minimum criteria.

•     Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers) — AML/CFT requirements for licensed issuers.

How the Ordinance is structured

•     Schedule 1 — the specified affairs, responsibility for which makes a person a "manager" for the purposes of the Ordinance.

•     Schedule 2 — the minimum criteria at sections 3 to 16. The criteria are of a continuing nature and apply after the licence is granted.

•     Schedule 3 — the licence fee.

•     Schedule 4 — the sixteen grounds for revocation.

•     Schedule 6 — the decisions that may be referred to the Stablecoin Review Tribunal.

2. What Counts as a "Stablecoin" and a "Specified Stablecoin"

Section 3 defines a stablecoin as a cryptographically secured digital representation of value that meets five characteristics simultaneously.

1.  It is expressed as a unit of account or store of economic value.

2.  It is used, or intended to be used, as a medium of exchange accepted by the public for payment for goods or services, discharge of a debt, or investment.

3.  It can be transferred, stored or traded electronically.

4.  It operates on a distributed ledger or similar information repository.

5.  It purports to maintain a stable value by reference to a single asset or to a pool or basket of assets.

What is carved out

•     Value issued by a central bank, an entity performing or authorized to perform central bank functions, a government, or an entity authorized by a government to issue currency.

•     A limited purpose digital token (AMLO Cap. 615, s. 53ZR); securities or a futures contract (SFO Cap. 571); a float or SVF deposit (PSSVFO Cap. 584); or a deposit (Banking Ordinance Cap. 155, s. 2(1)).

Section 4(1) defines "specified stablecoin" more broadly than the current regulatory perimeter. Today the perimeter covers only stablecoins referenced wholly to one or more official currencies — fiat-referenced stablecoins. Extending the perimeter to other units of account or stores of economic value is within the HKMA’s power and requires no amendment to the Ordinance.

3. When the Licensing Obligation Arises

Section 5 sets out three independent limbs, each of which constitutes a regulated stablecoin activity.

•     The person issues a specified stablecoin in Hong Kong in the course of business.

•     The person issues a specified stablecoin outside Hong Kong in the course of business, and that stablecoin purports to maintain a stable value by reference — wholly or partly — to Hong Kong dollars.

•     The person carries on an activity specified by the HKMA under section 5(4).

Section 5(2) equates "holding out" with carrying on: a person is regarded as holding out as carrying on a regulated stablecoin activity if the person actively markets to the public, whether in Hong Kong or elsewhere, that it carries on or purports to carry on an activity which, if carried on in Hong Kong, would be a regulated stablecoin activity.

How the HKMA reads "issue in Hong Kong"

•     Where the day-to-day management and operations of the issuer take place.

•     Where the issuer is incorporated.

•     Where minting and burning of the stablecoin take place.

•     Where the reserve assets are managed.

•     Where the bank accounts processing minting and redemption cash flows are maintained.

How the HKMA reads "actively market"

•     The languages used in the marketing and whether the website uses Chinese; whether the message targets people resident in Hong Kong.

•     Whether a Hong Kong domain name is used, or one that may give the impression the issuer is established in Hong Kong; whether a detailed marketing plan exists.

The point of issuance is determined factually: a specified stablecoin is typically regarded as issued, or "minted", when it is first recorded on a distributed ledger and assigned to a digital wallet address.

Two requirements come from the HKMA guidelines rather than the Ordinance and are easily missed in planning. First, the issuer must notify the HKMA before publishing a white paper or making material changes to it, and the document should be in non-technical language comprehensible to the public. Second, the AML/CFT Guideline applies the travel rule to licensed issuers on stablecoin transfers. Both points come from law firm summaries and should be checked against the Supervision Guideline and the AML/CFT Guideline.

Being outside Hong Kong is not, by itself, enough. Section 8 makes it an offence to carry on, or hold out as carrying on, a regulated stablecoin activity without a licence or an exemption under section 13(1)(a). Separately, section 154 prohibits a person who is not an applicant from describing itself as an applicant or behaving in a way reasonably understood as indicating that it is one. The HKMA expressly reminds interested parties to exercise caution in public communications before filing.

The section 13 exemption

The HKMA may exempt a person or class of persons from the section 8 prohibition where satisfied that the risks to holders and to Hong Kong’s monetary or financial system are immaterial. Conditions may be attached — limits on circulation size, or on the class of persons who may be offered the stablecoins — and the exemption may extend to the section 10(1) advertising prohibition.

4. Who May Apply: Two Routes

Section 3 of Schedule 2 admits only two types of applicant: a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622), or an authorized institution incorporated outside Hong Kong as defined in section 2(1) of the Banking Ordinance (Cap. 155).

Any institution incorporated outside Hong Kong that is not an authorized institution must incorporate a Hong Kong subsidiary, and that locally incorporated company is the applicant. Authorized institutions are exempt from the local incorporation requirement because such an institution is already adequately supervised by both the HKMA and its home supervisor under comprehensive requirements meeting Basel standards.

A conflict in the commentary worth resolving. Some summaries render the rule as "licensees must be companies or authorized institutions incorporated outside Hong Kong". That is a distortion: the local incorporation requirement applies to companies, and the exemption from it applies only to authorized institutions. The HKMA’s own Explanatory Note states the alternative unambiguously.

How the two routes differ in substance

Requirement	Locally incorporated company	Overseas authorized institution
Place of incorporation	Hong Kong, under the Companies Ordinance (Cap. 622)	Outside Hong Kong; no local incorporation required
Minimum financial resources (section 4 of Schedule 2)	Applies: at least HKD 25,000,000 paid-up capital or an approved equivalent	Does not apply
HKMA consent for controllers, chief executives and directors	Required before appointment	Not required under the Ordinance
Stablecoin manager	Not a mandatory role	Mandatory appointment under section 66
Restriction on other business (section 12 of Schedule 2)	Applies: other business requires HKMA consent	Does not apply
HKMA power to appoint an advisor or statutory manager	Applies (sections 79 and 80)	Does not apply: Division 4 of Part 2 does not extend to authorized institutions
Certified corporate documents and controller forms	Required in full	Several Annex B items do not apply

The consequence is visible in the first round: both licences went to entities of banking origin. A non-bank applicant has one route only — a Hong Kong company carrying the full requirement set, capital and personnel approvals included.

5. The Schedule 2 Minimum Criteria

A licence may not be granted unless the HKMA is satisfied the minimum criteria would be fulfilled, and they continue to apply after grant: failure is a ground for revocation and disciplinary action.

Schedule 2 section	Subject	Key parameter
Section 3	Corporate status	Hong Kong company or overseas authorized institution
Section 4	Financial resources	HKD 25,000,000 paid-up capital or approved equivalent; does not apply to authorized institutions
Section 5	Reserve assets management	A separate segregated pool per stablecoin type; market value at all times at least equal to the par value in circulation
Section 6	Redemption	Redemption at par; processing within 1 business day unless otherwise approved
Sections 7 and 8	Fit and proper persons, knowledge and experience	Applies to the chief executive, directors, stablecoin manager and controllers; at least one third independent non-executive directors expected
Section 9	Prudential and risk management	Seven areas: risk governance, framework and internal control, credit/liquidity/market, technology, operational, reputation, incident management and exit
Section 10	AML/CFT	Compliance with the AMLO and with measures promulgated by the HKMA
Section 11	Purpose and soundness of issue	A realistic, concrete and viable business plan with a reasonable prospect of sufficient demand
Section 12	Business activities	HKMA consent for any business other than the licensed activity; does not apply to authorized institutions
Section 13	Disclosures	A white paper published on the website before offering to the public
Section 14	Complaint handling	Accessible, independent, fair and timely complaints and redress mechanisms
Section 15	Non-interest bearing	No interest may be paid on the stablecoins issued
Section 16	Recovery planning and orderly wind-down	Continuity planning and a business exit plan

Additional numerical thresholds not supported by the regulator document. Several briefings cite further requirements — HKD 3,000,000 of liquid capital and excess liquid capital covering at least twelve months of operating expenses. Those figures do not appear in the Explanatory Note, which states only the HKD 25,000,000 threshold and a general adequacy requirement. More troubling, some commentary pairs the HKD 3,000,000 figure with a paid-up capital floor of HKD 5,000,000 — which are the SFC Financial Resources Rules parameters for licensed corporations, not the stablecoin regime. That is a sign of cross-contamination between two regimes in the secondary literature: verify against the Guideline on Supervision of Licensed Stablecoin Issuers rather than taking the figures on trust.

6. Reserve Assets: Segregation, Trust and Full Backing

The market value of the specified reserve assets pool backing a type of stablecoin must at all times be at least equal to the par value of the outstanding stablecoins of that type in circulation.

Full backing is a floor rather than a target. The HKMA expects an applicant to take account of the risk profile of the reserve assets and to ensure appropriate over-collateralisation providing a buffer above the full backing level.

Composition and custody

•     Reserve assets must be of high quality and high liquidity with minimal investment risks, held in a separate pool for each stablecoin type, segregated from any other reserve asset pool of the issuer.

•     The pool must be held in the same referenced asset as the stablecoin type it backs. Flexibility on currency mismatch is available case by case and only with the HKMA’s prior written approval.

•     Custody is documented by written contractual agreements with qualified custodians: a licensed bank, or another custodian under an arrangement acceptable to the HKMA.

In assessing a currency mismatch request the HKMA considers whether there is a legitimate reason, whether the licensee can demonstrate the need and rationale, and whether the proposed arrangements — including the composition and proportion of reserve assets and mitigants such as over-collateralisation — are reasonable, so that risk is not transferred to holders.

The trust arrangement and legal opinion

Reserve assets must be segregated from any other pools, adequately protected against claims by the issuer’s other creditors in all circumstances, and kept separate from any other assets of the issuer, including any other funds it holds or receives.

An effective trust arrangement is required to ensure that reserve assets are segregated from the issuer’s assets, held for and on behalf of holders, and available to satisfy valid redemption requests at par. Before implementing such an arrangement the applicant must obtain an independent legal opinion demonstrating its effectiveness and submit that opinion to the HKMA.

Attestation and disclosure

Reserve assets are subject to regular independent attestation and audit by a qualified external auditor acceptable to the HKMA, with public disclosure of the reserve management policy, the risk assessment, the composition and market value of the assets, and the attestation results.

7. Redemption: One Business Day and Insolvency Rights

Valid redemption requests must be honoured without an unreasonable fee and without unduly burdensome conditions, as soon as practicable. Unless otherwise approved by the HKMA, a valid redemption request should be processed within one business day after the day on which it is received.

Redemption is at par in the referenced currency, and where several currencies are referenced, in the same ratio. A draw-down of reserve assets must be matched by a corresponding decrease in the par value of the stablecoins in circulation.

What happens on insolvency

The right to redeem at par includes two rights exercisable on the licensee’s insolvency: the right to direct the disposal of the specified reserve assets pool in order to redeem all outstanding stablecoins of that type on a pro rata basis, and the right to claim against the issuer for any shortfall where the disposal proceeds are insufficient to redeem in full.

8. The Interest Prohibition and What It Does to the Business Model

Section 15 of Schedule 2 prohibits an issuer from paying, or permitting to be paid, any interest in relation to the specified stablecoins it issues. Interest means any profit, income or other return represented to arise, or to be likely to arise, from holding the stablecoin on the basis of the length of the holding period, the par value of the stablecoin, or its market value.

The issuer must also ensure that any income or loss from managing reserve assets, including interest and capital gains or losses, is attributed to the issuer.

The economic consequence. Reserve income belongs to the issuer but cannot reach holders in any form keyed to holding period, par value or market price. Yield-bearing models common elsewhere are therefore unavailable, and competition shifts to settlement infrastructure, distribution and payment integration.

9. People and Governance

Each chief executive, director, stablecoin manager and controller of an applicant must be a fit and proper person with relevant knowledge and experience.

HKMA consent is required before a chief executive, director or stablecoin manager takes up appointment, under sections 54, 59 and 67 respectively. For an applicant that is an authorized institution, HKMA consent is not required under the Ordinance for a person to become a controller, chief executive or director.

The HKMA’s expectations on composition and location

•     At least one third of the board should be independent non-executive directors.

•     Senior management and key personnel are generally expected to be based in Hong Kong.

•     A separate face-to-face meeting between directors or the chairman, the chief executives including the alternate, the stablecoin manager and the HKMA Stablecoin Licensing Team may be held during the process.

•     A licensee must appoint a chief executive and at least one alternate chief executive, and must notify the HKMA of the appointment or cessation of any "manager" — a person principally responsible for one or more of the specified affairs in Schedule 1.

10. Who May Offer: the Five Permitted Offerors

Offering does not itself require an issuer licence, but the class of persons who may do so is closed.

Under section 9(2) a licensee may only engage a permitted offeror to offer the stablecoins whose issuance its licence authorises. Section 9(5) defines five categories: a licensee under the Stablecoins Ordinance; an authorized institution as defined in section 2(1) of the Banking Ordinance; a person licensed under section 8F of the Payment Systems and Stored Value Facilities Ordinance; a virtual asset trading platform licensed by the Securities and Futures Commission; and a corporation licensed by the SFC for Type 1 regulated activity under section 116 of the Securities and Futures Ordinance.

What constitutes an offer

Under section 6, an offer is a communication made in the course of business, in any form and by any means, presenting sufficient information on three matters together — the stablecoin, the terms and the channels — to let the recipient decide whether to acquire it from that person.

Retail access turns on the origin of the stablecoin, not on who offers it. Licensed stablecoins may be offered to the general Hong Kong public. Stablecoins whose issuance falls outside the licensing perimeter — a USD-pegged token such as USDT, provided issuance does not take place in Hong Kong — may be offered only to persons designated by the Financial Secretary, a class currently limited to professional investors under section 1 of Part 1 of Schedule 1 to the Securities and Futures Ordinance.

The practical consequence for distribution. Over-the-counter operators fall into none of the five permitted offeror categories and are therefore effectively excluded from the stablecoin distribution chain unless a narrow exemption applies. The restriction is implemented by a Financial Secretary notice — the Stablecoins Ordinance (Specification of Persons for Purposes of Section 9(2)(b)(iii)) Notice — and the current list of designated persons should be checked against its version in force.

11. Offences and Sanctions

Offence	Maximum sanction	Comment
Carrying on, or holding out as carrying on, a regulated stablecoin activity without a licence (section 8)	Summary: HKD 500,000 fine, 2 years imprisonment and a daily fine of HKD 10,000. On indictment: HKD 5,000,000 fine, 7 years imprisonment and a daily fine of HKD 100,000 for each day the offence continues	The core offence, with a two-tier sanction structure
Offering a specified stablecoin without being a permitted offeror, or offering a stablecoin not issued by a licensee (section 9)	Sanctions equivalent to the section 8 offence at both tiers	Reaches distributors and platforms, not only issuers
Fraud or deception in connection with specified stablecoin transactions (section 11)	Summary: HKD 1,000,000 fine and 3 years. On indictment: HKD 10,000,000 fine and 10 years	The court may additionally bar the convicted person from stablecoin transactions in Hong Kong for up to 5 years
Inducing another to enter into a stablecoin agreement by fraudulent or reckless misrepresentation (section 12)	Criminal liability	Covers false statements, promises without intention to perform, unjustified forecasts and deliberate omission of material facts
Publishing an advertisement in which an unlicensed person holds out as carrying on a regulated stablecoin activity, or a non-permitted offeror holds out as offering a stablecoin (section 10)	A level 5 fine — currently HKD 50,000 — and 6 months imprisonment	Defences exist for intermediaries such as publishers and broadcasters acting in the ordinary course of business, passively disseminating content without creating, modifying or controlling it, and taking all reasonable steps
HKMA pecuniary penalty for contravening the Ordinance, its requirements or licence conditions	The greater of HKD 10,000,000 or three times the profit gained or loss avoided	Applies in addition to criminal liability

This block carries a lower level of verification than the rest of the article. The sanction figures come from Hong Kong and international law firm publications rather than from the Explanatory Note, which does not deal with sanctions. The specific amounts and offence definitions should be checked against the text of the Stablecoins Ordinance on the e-Legislation portal before any decision is taken.

12. The Transitional Period Has Closed

The Ordinance provided a time-limited accommodation for persons who had carried on regulated stablecoin activity in Hong Kong before 1 August 2025 and had a meaningful and substantial presence there.

Per international law firm commentary, such issuers could continue operating during a six-month non-contravention period provided that, within the first three months, they filed an application, received the HKMA’s acknowledgment and undertook that they could comply. Merely establishing a corporate entity or holding "shell" operations in Hong Kong before 1 August 2025 did not qualify.

Pre-existing issuers that demonstrated a reasonable prospect of meeting the full requirements could be granted a provisional licence allowing them to continue operating until 31 January 2026, with the substantive licence decision taken after that date.

Entry via the transitional provisions is no longer available. The six-month period ran from 1 August 2025 and expired on 31 January 2026. Issuers that had not applied by 31 October 2025 entered a closing-down period from 1 November 2025, with one month to close the relevant Hong Kong business absent an HKMA-approved extension. Only the ordinary route remains.

13. The Application Process

Step 1. Preliminary consultation

The HKMA expressly encourages an interested entity to signal its interest to the Licensing Team before filing, so that the team understands the applicant’s background and business model and the applicant understands the procedures and expectations. In the regulator’s words, this helps avoid premature submission.

Step 2. Consultation with the home regulator

Where the parent also conducts digital asset or other regulated financial business at home, the HKMA may contact the home regulator and weigh its views on the parent’s financial soundness, internal control environment and any concern about the group extending into stablecoin issuance.

The Explanatory Note states plainly that the interested party should liaise with its parent to consult the home regulator before submitting an application to the HKMA, in order to avoid delays in processing.

Step 3. The document set

Annex B to the Explanatory Note lists twenty-three mandatory items and six further items provided on request by the Licensing Team.

•     The completed licence application form, plus separate forms for each controller, chief executive, stablecoin manager and director.

•     A business plan covering a three-year horizon and beyond, and business and financial projections for the coming three years.

•     Certified corporate documents: certificate of incorporation, Forms NSC1 and NC1 or NNC1, the business registration certificate, the registers of members, directors, charges and debenture holders, a supporting board resolution and the articles of association.

•     The ownership structure disclosing each controller, audited financial statements for the past three financial years, and the intended trust and custodial arrangements for reserve assets.

•     Policies and procedures for reserve asset management; issuance, redemption and distribution; risk management; corporate governance; and business conduct, together with the draft holder contract, the white paper and the institutional money laundering risk assessment.

On request, the Licensing Team may additionally require independent assessment reports on overall regulatory compliance; an external auditor’s report on paid-up share capital; trust documentation with an independent legal opinion on its effectiveness; an independent legal opinion confirming holder rights; contractual agreements with custodians and other material third parties; and a smart contract audit report.

Step 4. Processing

The HKMA may require by written notice any information or document necessary to determine the application, and may refuse to process further or reject it if the requirement is not met. Processing time is not fixed in advance.

All licence applications are considered by a Stablecoin Advisory Committee comprising senior HKMA officers and chaired by a senior executive, which makes recommendations to the Monetary Authority on licensing matters.

Step 5. Decision

On grant, the HKMA notifies the licence number and effective date and enters the licensee on the public register. On refusal it gives written notice of the decision and the ground; a refusal is a specified decision under Schedule 6 and may be referred to the Stablecoin Review Tribunal.

14. Ongoing Obligations After Grant

Obligation	Timing	Basis
Payment of the licence fee	Within 14 days after the date the licence takes effect, and annually on or before each anniversary of that date	Section 22; the amount is set by Schedule 3 and may be amended by Financial Secretary notice in the Gazette
Display of the licence number	Continuously, on any advertising material and in the consumer-facing interface of any software application supporting the licensed activity	Section 23
Continued fulfilment of the minimum criteria	Continuously	Section 24; failure is a ground for revocation under Schedule 4
Reporting likely inability to meet obligations, insolvency or imminent suspension of payment	Immediately, with all relevant facts and circumstances	Section 25
Notification of change of address	Within 7 days after the day the change takes place	Section 26
Notification of material change of circumstances	As soon as practicable after becoming aware of the change or of its likelihood	Section 27
Notification of appointment and cessation of managers	Within 14 days after the relevant date	Section 63

The licence fee amount is deliberately not stated here. The Explanatory Note refers to Schedule 3 and states expressly that the amount is subject to amendment by notice published in the Gazette by the Financial Secretary. Publishing a figure without checking the current Schedule 3 and the latest notices would present an estimate as a fact.

15. HKMA Powers: From Directions to a Statutory Manager

Supervisory powers under Part 4 include requiring information and documents, examining books and accounts, and commissioning a skilled person’s report. Under section 77, after consulting the Financial Secretary, the HKMA may exercise the powers in sections 78 to 80 where the licensee is or is likely to become unable to meet its obligations, is insolvent, is operating detrimentally to holders or creditors, has contravened the Ordinance or a licence condition, or where a ground for revocation exists.

•     Section 78 — written requirement. An immediate direction on the licensee’s affairs, business or property: restricting expansion, new financial commitments, disposal of reserve assets, or further issuance and redemption. It may go as far as requiring the licensee to cease normal business.

•     Sections 79 and 80 — advisor or statutory manager. An advisor is appointed where management still functions properly and acts in good faith but needs additional expertise; a statutory manager takes over the affairs, business and property where management cannot be relied upon to rectify the problem.

The advisor and statutory manager powers do not apply to authorized institutions: Division 4 of Part 2 of the Ordinance does not extend to them.

Suspension and revocation

•     Section 32 allows temporary suspension for up to 14 days; section 33 allows suspension for up to 6 months, extendable by a further 6. Section 28 permits revocation on any of the sixteen Schedule 4 grounds. A revocation decision may go to the Stablecoin Review Tribunal under section 140, but referral does not stay execution; a stay is sought separately under section 141(2).

16. The First Round: 36 Applications, Two Licences

The HKMA received 36 formal applications by the close of the first application window on 30 September 2025. On 10 April 2026 it granted the first two stablecoin issuer licences — to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. The licences took effect the same day; the HKMA’s public register lists Anchorpoint as FRS01 and HSBC as FRS02.

Anchorpoint Financial Limited is a joint venture of Standard Chartered Bank (Hong Kong) Limited, HKT Limited and Animoca Brands Limited. HSBC and Standard Chartered are two of the three note-issuing banks in Hong Kong.

Sandbox participation did not guarantee a licence. The 2024 HKMA sandbox cohort had three participants: the Standard Chartered, Animoca Brands and HKT consortium, JD Coinlink and RD InnoTech. Only the consortium came through the first round, in the form of Anchorpoint Financial Limited.

A discrepancy in the figures that circulates in coverage. The HKMA’s own figure is 36 formal applications. Some industry material cites materially higher numbers, up to eighty; those do not match the regulator’s count and, on the context, refer to expressions of interest rather than filed applications. Cite the figure from the HKMA press release.

On the day the first licences were granted the HKMA accompanied the announcement with a specific public warning about fraudulent activities and scams purporting to be associated with the licensees or their stablecoin issuance. Verifying the provenance of an instrument before listing or distributing it is a practical duty for platforms and payment providers.

In the HKMA’s own formulation, the licences went to applicants that demonstrated the capability to properly manage risks with credible use cases and development plans, in addition to meeting the licensing requirements. In the initial phase both licensees plan to issue HKD-referenced stablecoins, with launches expected in mid to second half of 2026.

What a two-in-thirty-six outcome means for planning. The first-round approval rate was under 6% and both licences went to bank-backed structures. Without a banking partner and demonstrated institutional-grade reserve and risk management, Hong Kong is a probable refusal after expensive preparation. The HKMA has declined to confirm a formal second application window, referring only to continued engagement with remaining and prospective applicants.

Adjacent 2026 developments

On 27 May 2026 the Securities and Futures Commission issued a circular on virtual asset trading platforms and licensed corporations dealing in stablecoins of HKMA licensees: it removes the twelve-month track record requirement for such stablecoins, eases knowledge assessment for stablecoin-only clients and permits licensed corporations to partner with a licensed issuer. These changes concern distribution rather than issuer licensing and rest on law firm sources.

17. Common Mistakes

Mistake 1. Assuming that no Hong Kong presence means no Hong Kong regime

A peg to the Hong Kong dollar triggers the licensing obligation wherever issuance occurs, and active marketing to the Hong Kong public triggers it wherever the marketing is done. A foreign-registered project aimed at a Hong Kong audience is caught on the marketing alone. The cost: an offence carrying a fine and imprisonment, plus a daily fine for each day it continues.

Mistake 2. Announcing an application before filing it

Section 154 prohibits a person that is not an applicant from describing itself as one, and the HKMA specifically reminds interested parties to be cautious in public communications. The cost: a standalone offence before the process even begins, and reputational damage with the team that will assess the file.

Mistake 3. Building the economics on paying holders a yield

Section 15 of Schedule 2 prohibits any return keyed to holding period, par value or market value, and reserve income is attributed to the issuer. The cost: reworking product economics late, after a three-year business plan and financial projections have been filed.

Mistake 4. Leaving the reserve trust structure until last

Segregation is not enough: an effective trust arrangement is required, supported by an independent legal opinion submitted to the HKMA before implementation, alongside custodian agreements and regular attestation. The cost: this is the longest-lead item in the file, and starting it last pushes the filing back by months.

18. Who the Regime Suits

Good fit

•     Banks and bank-backed structures. An authorized institution is exempt from local incorporation, the financial resources threshold, the restriction on other business and HKMA consent for controllers, chief executives and directors.

•     Projects with a concrete settlement use case, and consortia. Section 11 of Schedule 2 requires a realistic, viable business plan with a reasonable prospect of sufficient demand, and both licensed mandates rest on payment and settlement cases rather than an investment narrative. The shape of the first licence — bank plus telecom plus crypto operator — shows the form the regulator favours.

•     Issuers targeting retail. Only stablecoins of HKMA licensees may be offered to retail investors.

Poor fit

•     Crypto-native issuers without a banking partner, and yield-bearing models. The capital floor, reserve requirements and first-round approval rate make a standalone approach unlikely, and the interest prohibition is unconditional.

•     Projects needing speed, or unwilling to relocate management. Processing time is not fixed, the file includes independent assessment reports and a smart contract audit, a dedicated HKMA committee decides, and senior management is expected to be based in Hong Kong.

19. Step-by-Step Preparation

6.  Determine whether the licensing obligation arises: issuance in Hong Kong, an HKD peg anywhere in the world, or active marketing to the Hong Kong public.

7.  Check whether the digital asset falls outside the stablecoin definition as securities, a futures contract, a deposit, a float or a limited purpose digital token, then choose the route: a locally incorporated Hong Kong company or an overseas authorized institution. For a non-bank foreign group there is one route — a Hong Kong subsidiary.

8.  Open an informal channel with the HKMA Licensing Team before preparing forms, and arrange for the parent to consult its home regulator where the group is regulated in its own jurisdiction.

9.  Put the capital in place: at least HKD 25,000,000 paid-up share capital or an HKMA-approved equivalent, with external auditor confirmation available.

10.     Design the reserve structure — a separate pool per stablecoin type, a qualified custodian agreement, a trust arrangement and an independent legal opinion on its effectiveness — and a redemption mechanism processing within one business day, with disclosure of fees, conditions, procedures and timing.

11.     Compose a board with at least one third independent non-executive directors, place senior management in Hong Kong, and prepare the policy set: reserve management; issuance, redemption and distribution; risk management across seven areas; corporate governance; business conduct; complaint handling; recovery and exit.

12.     Prepare the white paper covering the six mandatory content areas and publish it on the website before offering to the public, and complete the institutional money laundering risk assessment and the smart contract audit.

13.     Settle the distribution channels — only a permitted offeror may offer the stablecoin and the retail channel is open only to licensed stablecoins — then file Annex B items 1 to 23, ready to produce items 24 to 29 on request.

20. Frequently Asked Questions

Is an HKMA licence needed if the company is registered outside Hong Kong?

Yes, in two situations: where the stablecoin is referenced wholly or partly to the Hong Kong dollar, in which case the licence is required wherever issuance takes place; and where the company actively markets to the Hong Kong public that it carries on an activity that would be regulated if carried on in Hong Kong.

What is the minimum capital for a Hong Kong stablecoin issuer licence?

At least HKD 25,000,000 of paid-up share capital, or an equivalent amount in another freely convertible currency, or other financial resources approved by the HKMA that equal or exceed that figure. The requirement does not apply to applicants that are authorized institutions.

Can holders be paid interest or any other return?

No. Section 15 of Schedule 2 prohibits any interest, meaning any profit, income or other return represented to arise from holding the stablecoin on the basis of the holding period, par value or market value. Income and loss from managing reserve assets are attributed to the issuer.

How many licences have been granted?

Two. On 10 April 2026 the HKMA granted licences to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited out of 36 first-round applications. They appear on the HKMA register as FRS01 and FRS02.

21. Key Takeaways

•     The Stablecoins Ordinance (Cap. 656) was passed on 21 May 2025, gazetted on 30 May 2025 and commenced on 1 August 2025.

•     A licence is required for issuance in Hong Kong, for an HKD peg anywhere in the world, and for active marketing to the Hong Kong public. The transitional period for pre-existing issuers expired on 31 January 2026.

•     Only stablecoins referenced wholly to official currencies are in scope, and only a Hong Kong company or an overseas authorized institution may apply.

•     Minimum paid-up capital is HKD 25,000,000 or an approved equivalent; it does not apply to authorized institutions.

•     Reserves: a separate pool per type, market value at all times at least equal to par value in circulation, an effective trust with an independent legal opinion, regular attestation and public disclosure. Redemption at par within one business day; on insolvency, pro rata disposal rights and a claim for any shortfall. Interest to holders is prohibited.

•     Only five categories of permitted offeror may offer stablecoins; the retail channel is open only to stablecoins of HKMA licensees.

•     First round: 36 applications, 2 licences granted on 10 April 2026, registered as FRS01 and FRS02.

22. Summary 

A Hong Kong stablecoin issuer licence is granted by the Monetary Authority under the Stablecoins Ordinance (Cap. 656), passed on 21 May 2025, gazetted on 30 May 2025 and commenced on 1 August 2025. A licence is required where a person, in the course of business, issues a specified stablecoin in Hong Kong, issues anywhere a stablecoin referenced wholly or partly to the Hong Kong dollar, or actively markets such an activity to the Hong Kong public. The perimeter currently covers only stablecoins referenced wholly to official currencies. Only a Hong Kong company under the Companies Ordinance (Cap. 622) or an authorized institution incorporated outside Hong Kong may apply; other foreign institutions must incorporate a Hong Kong subsidiary. The minimum criteria sit in sections 3 to 16 of Schedule 2: paid-up share capital of at least HKD 25,000,000 or an HKMA-approved equivalent, not applicable to authorized institutions; a separate segregated reserve pool per stablecoin type whose market value at all times at least equals the par value in circulation, with an effective trust arrangement, an independent legal opinion, a qualified custodian, regular independent attestation and public disclosure; redemption at par with valid requests processed within one business day and, on insolvency, pro rata disposal rights and a claim for any shortfall; fit and proper chief executive, directors, stablecoin manager and controllers with HKMA consent before appointment and at least one third independent non-executive directors expected; a prohibition on interest keyed to holding period, par value or market value; a white paper published before offering to the public; and recovery and wind-down planning. Section 9(5) lists five permitted offerors: licensees, authorized institutions, section 8F PSSVFO licensees, SFC-licensed virtual asset trading platforms and SFC Type 1 licensed corporations. The Annex B document set comprises 23 mandatory items and 6 on request, including a three-year business plan, three years of audited accounts, trust documentation, the white paper and a smart contract audit; a Stablecoin Advisory Committee considers applications. The six-month transitional period expired on 31 January 2026. In the first round the HKMA received 36 applications by 30 September 2025 and on 10 April 2026 granted two licences — Anchorpoint Financial Limited (FRS01) and The Hongkong and Shanghai Banking Corporation Limited (FRS02).

23. Sources

Tier 1 — regulator and primary documents

•     HKMA — Explanatory Note on Licensing of Stablecoin Issuers, July 2025 (PDF)

•     HKMA — Regulatory Regime for Stablecoin Issuers: register of licensees and guidance

•     HKMA — Eddie Yue, Robust development of the regulated stablecoin ecosystem in Hong Kong, 10 April 2026

•     Bank for International Settlements — FSI Briefs No. 27: Stablecoin-related yields, some regulatory approaches (PDF)

Tier 2 — professional commentary

•     Davis Polk — Hong Kong’s new stablecoin licensing and regulatory regime

•     Davis Polk — Hong Kong’s licensing and regulatory framework for stablecoins is now in effect

•     Slaughter and May — Hong Kong launches stablecoin regime

•     Sidley Austin — Hong Kong Implements New Regulatory Framework for Stablecoins

•     Morgan Lewis — Hong Kong’s Stablecoins Ordinance to Take Effect August 1

•     ONC Lawyers — Core regulatory restrictions and offences under the Stablecoins Ordinance

•     Charltons — HKMA Issues First Stablecoin Issuer Licences

•     Reed Smith — Stablecoin regime in full swing: bite-sized FAQs

•     CMS — Hong Kong Stablecoins Ordinance in operation on 1 August 2025

Related UPPERSETUP analysis

•     Hong Kong + UAE: Dual Structure for International Business 2026

•     Crypto Business in the UAE in 2026: VARA, FSRA, DFSA, VASP Licences and Banking Compliance

•     DIFC 2026: Jurisdiction, Structures, Regulators and Taxes

Assessing entry into the Hong Kong stablecoin regime? UPPERSETUP supports projects in Hong Kong, the UAE and Kazakhstan: testing whether the licensing obligation applies to a given model, choosing between a Hong Kong company and a bank-backed route, building the corporate and documentary perimeter against Annex B, and coordinating with the HKMA Licensing Team. Discuss your project with UPPERSETUP

Disclaimer

This material is provided for informational purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before making any decision, obtain individual professional advice reflecting your specific circumstances, jurisdiction, company status and current regulatory requirements. Information is current as of August 2026.