The Hong Kong Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) have completed consultations on legislative proposals for virtual asset service providers and published the outcomes on December 24, 2025. In their announcement, the regulators declared further advancement of related licensing frameworks for dealers and custodians, as well as the launch of a new consultation for advisory and management service providers.
New Cryptocurrency Licensing Frameworks in Hong Kong
In the published consultation outcomes, FSTB and SFC indicated they will promote separate licensing regimes for virtual asset dealers and custodians. These frameworks aim to formalize requirements for those providing trading and custodial services and to align practices with existing regulatory approaches.
Additionally, the regulators have opened a new consultation on regimes for advisory and management service providers, expanding on the principle of "same business, same risks, same rules." For details on dealer-focused rules, see new rules for dealers, which discuss related requirements.
Key Regulatory Changes
The statement notes that the dealer regime will be aligned with Type 1 securities-dealing rules, implying the application of relevant market and operational standards to virtual asset trading activities. Concurrently, the custodial regime emphasizes protecting private keys and client funds, reflecting regulators’ priorities on asset security.
The regulatory approach consistently applies the principle "same business, same risks, same rules" to new categories of providers. In the context of other crypto asset regulatory initiatives in Hong Kong, it is useful to review materials on capital requirements to understand related obligations and their connection to licensing frameworks.
Preparing for New Requirements
Regulators encourage stakeholders to begin pre-application discussions so companies can prepare for upcoming licensing requirements. This consultation phase is designed to facilitate the transition to new rules and enhance market participants’ readiness.
If you follow licensing developments in Hong Kong, it is also helpful to monitor related initiatives, including those on stablecoins and related products; for example, clarifications on stablecoin licensing provide additional context to the overall regulatory landscape.
Why This Matters
For a miner in Russia operating from one to a thousand devices, direct business ties to Hong Kong’s frameworks are usually minimal. However, these changes are significant if you use services from Hong Kong providers (custodial platforms, brokers, or asset managers). Licensing determines which companies can officially offer services and what security standards they must meet.
Moreover, new consultations on advisory and management services suggest that providers of such services may face additional obligations in the future. If you store funds with third parties or consider using managed products from Hong Kong, it is important to monitor whether these providers comply with new requirements and are prepared for pre-application discussions with regulators.
What to Do?
- Check your service providers’ status: verify whether your custodian or broker holds a Hong Kong license or plans to participate in pre-application discussions with the SFC.
- Strengthen key management: maintain backups of private keys and plan access procedures, especially if using third-party custodial solutions.
- Follow official announcements from FSTB and SFC and prepare documentation if you plan to enter the market or offer services requiring licensing.
- If your activities involve providing advisory or asset management services, consider starting preparations for licensing requirements and initiate discussions with regulators early.
Frequently Asked Questions
Which regimes were covered by the consultation outcomes? The outcomes concern proposals for licensing virtual asset dealers and custodians.
When were the consultation results published? The results were published on December 24, 2025.
Which new services are currently under consultation? A new consultation is open for advisory and management service providers.
Where can one seek pre-application consultations? Regulators invite interested parties to start pre-application discussions; practical guidance can be obtained from the SFC.