Hong Kong's government and Securities and Futures Commission plan to introduce legislation by the end of 2026 to bring virtual-asset dealing, advisory, management and custody services into the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. The measure would extend the existing licensing architecture for virtual-asset trading platforms rather than replace it.[1][2]
The timetable is a policy commitment, not an enacted rule. Firms should therefore distinguish between activities already regulated under the current VATP regime and the four service categories targeted by the forthcoming amendment bill. The bill's final definitions, transitional treatment, capital requirements and licensing deadlines still need to be read when legislation is introduced.[1][2]
Services targeted by the forthcoming bill
| Service | Regulatory direction announced |
|---|---|
| Virtual-asset dealing | To be brought within expanded statutory regimeSource 1Source 2 |
| Virtual-asset advisory | To be licensed/regulatedSource 1Source 2 |
| Virtual-asset management | To be licensed/regulatedSource 1Source 2 |
| Virtual-asset custody | To be licensed/regulatedSource 1Source 2 |
| Existing VA trading platforms | Current regime remains the base architectureSource 1Source 2 |
The market is expanding before the perimeter is finished
The government's 4 November answer also shows why the extension matters. At the end of September, the SFC had authorised 13 tokenised money-market funds, one tokenised gold investment product, two gold ETFs with tokenised classes and one covered-call ETF with a tokenised class. The tokenised classes of those 17 retail investment products had about HK$10.3 billion of assets under management.[1]
Two authorised tokenised money-market funds began round-the-clock secondary-market trading on licensed virtual-asset platforms on 26 October, according to the same statement. Hong Kong also says two stablecoin-issuer licences were granted in April. Together, those developments make custody, dealing and advisory boundaries more operationally significant: tokenised investment products, stablecoins and licensed trading venues increasingly sit in the same client journey.[1]
Selected ecosystem markers disclosed by government
| Marker | Status |
|---|---|
| Tokenised money-market funds | 13 authorised by end-Sep 2026Source 1 |
| Other tokenised retail products | 1 gold product, 2 gold ETFs with tokenised classes, 1 covered-call ETF tokenised classSource 1 |
| AUM of 17 tokenised retail classes | About HK$10.3bnSource 1 |
| 24/7 secondary trading | Two tokenised MMFs on licensed VA platforms from 26 OctSource 1 |
| Stablecoin issuers | Two licences granted in April 2026Source 1 |
| Expanded VA-services bill | Targeted for introduction by end-2026Source 1 |
For international brokers and crypto firms, the immediate task is perimeter mapping, not licence application under a law that does not yet exist. Firms should separate each service they perform—execution, advice, discretionary management, custody, platform operation—and identify which Hong Kong entity performs it. The decisive next document is the amendment bill itself, because that will determine scope, exemptions, transition and implementation dates.[1][2]
Sources & further reading
- LCQ1: Policy on the development of digital assets Hong Kong Government · 4 Nov 2026 · Accessed 8 Nov 2026
- Remarks by SFST at FinTech Week x StartmeupHK Festival 2026 Hong Kong Government · 2 Nov 2026 · Accessed 8 Nov 2026