Hong Kong's Stablecoin Licensing Regime: Licences Granted and What Issuers Need to Know

Hong Kong's stablecoin regime is no longer prospective. The Stablecoins Ordinance came into force on 1 August 2025, the HKMA granted the first two issuer licences on 10 April 2026, and the first regulated Hong Kong dollar stablecoin went live on 12 August 2026. Anyone assessing the regime now is assessing something that operates, with a licensing record to read rather than a policy intention to interpret.

That record is short. Thirty-six applications were made in the first batch; two licences have been granted. The HKMA has said publicly that the number will stay very limited. For most businesses the practical question has shifted from "how do we get licensed" to "how do we work with a licensed issuer", and the answer to that changed materially in May 2026.

This guide covers what the Ordinance requires, where licensing actually stands, and what a licence now unlocks downstream for intermediaries.

What the Ordinance catches

A licence from the HKMA is required to do any of three things:

• issue a fiat-referenced stablecoin in Hong Kong;
• issue a stablecoin that references the Hong Kong dollar, anywhere in the world; or
• actively market such a stablecoin to the Hong Kong public.

The second limb has extraterritorial reach and is the one overseas issuers most often miss. An issuer with no Hong Kong presence at all falls within the regime if the token references the Hong Kong dollar. The third limb turns on marketing rather than users, so an issuer that neither operates here nor references the Hong Kong dollar can still be caught by how it promotes itself.

The regime is confined to stablecoins referencing fiat currency. Algorithmic stablecoins, tokens referencing commodities or baskets of assets, and unbacked crypto-assets sit outside it, though they may engage the SFC's regimes instead depending on their features.

Where licensing actually stands

The HKMA set a first-batch application deadline of 30 September 2025 and received 36 applications.

On 10 April 2026 it granted two licences, both effective the same day:

• Anchorpoint Financial Limited, a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands, which had participated in the HKMA's stablecoin issuer sandbox; and
• The Hongkong and Shanghai Banking Corporation Limited.

As at the HKMA's published register, those remain the only two licensed issuers.

On the prospect of more, the HKMA's Chief Executive said in April 2026 that the authority takes "an open yet prudent stance, with no definitive inclination at this stage", that the licensing threshold will remain high, and that if further licences are granted "the overall number will remain very limited". That position was reaffirmed to the Legislative Council in June 2026.

The honest reading for a prospective applicant is that this is not a regime designed to license a broad field. Both successful applicants are, or are backed by, note-issuing or systemically significant banks. A business without that profile should form a realistic view before committing to an application, and should look seriously at the alternative of distributing someone else's licensed stablecoin.

HKDAP

Anchorpoint launched HKDAP on 12 August 2026, the first regulated Hong Kong dollar stablecoin. It runs on Ethereum and was made available initially to corporates and professional investors, distributed through OSL and HashKey. It is worth watching as the working template for how the HKMA expects reserve management, redemption and distribution to operate in practice.

What the HKMA requires

Capital and financial resources

• Paid-up share capital of at least HK$25 million.
• Liquid capital subject to a floor of HK$3 million.
• Reserves sufficient to cover twelve months of operating expenses.

The twelve-month operating expense requirement is the one that catches thinly capitalised applicants. It is not satisfied by the HK$25 million; it sits alongside it and scales with the cost of running the business.

Reserve assets

The stablecoin must be fully backed at all times by high-quality, highly liquid reserve assets with minimal investment risk. Reserves must be properly segregated from the issuer's own assets, held so that they are insulated from the issuer's insolvency, and independently attested. The market value of the reserve pool must at all times be at least equal to the par value of the stablecoins in circulation.

In practice this means short-dated government paper, bank deposits and equivalent instruments, held with custodians the HKMA is satisfied with, and reported on regularly. Yield generation on the reserve is the issuer's commercial model, and the tension between reserve quality and reserve yield is where the HKMA's scrutiny concentrates.

Redemption

Holders must be able to redeem at par. The requirement is specific and tighter than most commentary suggests: redemption requests must be processed within one business day of receipt, unless the HKMA approves otherwise. Redemption cannot be subject to unduly burdensome conditions or fees.

A one business day obligation is an operational commitment before it is a legal one. It requires banking arrangements capable of settling fiat within that window, and a redemption process that does not depend on manual intervention at scale.

Governance, conduct and AML

An issuer must be locally incorporated, have fit and proper controllers, directors and senior management, maintain risk management and internal controls proportionate to its business, disclose the terms of the stablecoin and the composition of the reserve, and submit to audit. Full AML and CFT obligations apply, including customer due diligence and the travel rule where relevant.

What a licence unlocks: the 27 May 2026 circular

This is the development most likely to affect readers who are not issuers, and it is easy to miss.

A joint HKMA and SFC circular of 27 May 2026 gives HKMA-licensed stablecoins materially lighter treatment in the hands of intermediaries. For a "Relevant Stablecoin":

• a licensed corporation may partner directly with the licensed issuer for dealing and custody in segregated accounts, without routing through an SFC-licensed virtual asset trading platform;
• the virtual asset knowledge assessment is disapplied for stablecoin-only services;
• the product is not automatically treated as complex; and
• it is not restricted to professional investors.

Separately, from 3 November 2025, the SFC disapplied the twelve-month track record requirement for HKMA-licensed stablecoins admitted to trading on licensed platforms.

Taken together, these change the commercial calculus. Distributing a licensed stablecoin is now a materially lighter regulatory undertaking than distributing other virtual assets, and considerably lighter than issuing one. For a payments business, a brokerage or a fintech, the sensible first question is no longer whether to seek an issuer licence but whether a distribution or partnership arrangement with a licensed issuer achieves the same commercial objective.

Offences

Issuing a fiat-referenced stablecoin, issuing a Hong Kong dollar-referenced stablecoin, or actively marketing one to the Hong Kong public without a licence is an offence. So is offering an unlicensed stablecoin to retail investors, and advertising an unlicensed issue. The Ordinance also creates offences relating to false or misleading representations about a stablecoin or its backing.

The practical exposure for most businesses is the marketing limb rather than the issuance limb. A website, an app store listing or a promotional campaign accessible in Hong Kong can constitute active marketing, and that assessment turns on how the offering is presented rather than on where the servers sit.

How Hong Kong compares

Hong Kong's regime sits alongside the EU's MiCA framework and Singapore's stablecoin regime, and the broad architecture is similar in each: full backing, segregation, redemption at par, and prudential requirements on the issuer.

The differences that matter commercially are the reserve composition rules, the redemption service standard, and how each regulator treats retail access. There is no mutual recognition. An issuer distributing across Hong Kong, the EU and Singapore needs authorisation in each, and should not assume that satisfying one regulator shortens the process with another. Where an issuer has limited resources, the sensible approach is to prioritise the jurisdictions that represent genuine distribution rather than pursuing parallel applications.

If you are considering issuance

• Test the three limbs against your actual model. Particularly the Hong Kong dollar limb, which reaches issuers with no Hong Kong presence, and the marketing limb, which reaches issuers with no Hong Kong users.
• Model the capital honestly. HK$25 million paid-up, plus the liquid capital floor, plus twelve months of operating expenses. The third number is usually the one that moves.
• Design the reserve and the redemption path together. A one business day redemption obligation constrains what the reserve can be invested in.
• Form a realistic view on prospects. Two licences from thirty-six applications, and a regulator saying the number will remain very limited.
• Price the alternative. Distribution of, or partnership with, a licensed issuer is now a substantially lighter route to a similar commercial position.
• Check your CARF position separately. Hong Kong's crypto-asset tax reporting obligations begin on 1 January 2027 and apply to a wider group than the licensing regimes. See our guide to CARF in Hong Kong.

For the wider licensing picture, including where the stablecoin regime sits alongside the SFC's virtual asset regimes and the four new regimes arriving under the AMLO, see our guide to Hong Kong crypto licence requirements.

How we can help

Alan Wong LLP advises stablecoin issuers and their counterparties on the Hong Kong regime: licensing strategy and application preparation, reserve and redemption structuring, governance and compliance frameworks, and the distribution and partnership arrangements that have become the more realistic route for most businesses since the May 2026 circular. We also advise on how the regime interacts with the SFC's virtual asset regimes and with the incoming dealing and custody licensing requirements. To discuss your position, please get in touch.

This article is general information current as at August 2026. Hong Kong's stablecoin and virtual asset regulation is moving quickly and the position may have changed since publication. It is not legal advice and should not be relied on as such.