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Centralised exchanges operating in Hong Kong or marketing to its investors hold this dual SFC licence, filed as one application because a token’s classification as a security can change.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission to decision.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
We assemble your team: two responsible officers and core function heads.
The licence, the requirements, the cost and the timing for your business.
You will need two responsible officers, senior licensed staff, under each licence, one living in Hong Kong and one an executive director, plus heads of each core function.
One programme, from scoping to launch. Speak to an expert about this licence.
Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.
An operator of a centralised platform on which clients trade virtual assets, operating in Hong Kong or actively marketing its services to Hong Kong investors, needs the SFC licence. Applicants are Hong Kong-incorporated companies or non-Hong Kong companies registered with the Companies Registry; sole proprietors and partnerships are not accepted. The licence is in practice dual: a licensed corporation for Type 1 (dealing in securities) and Type 7 (automated trading services) under the Securities and Futures Ordinance, and a licensed virtual asset service provider under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, with responsible officers and licensed representatives approved under each.
| Regime | Instrument | Covers | Approvals |
|---|---|---|---|
| Securities and Futures Ordinance | Licensed corporation, Types 1 and 7 | Trading in security tokens | Responsible officers and licensed representatives per regulated activity |
| Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) | Licensed virtual asset service provider | Trading in non-security tokens | Responsible officers and licensed representatives for the VA service |
One consolidated application is filed through the SFC’s WINGS portal for both regimes: Forms VA1 and VA3 (at least two responsible officers), VA6, the supplements, Questionnaire VA1 and a board resolution.
| Requirement | Amount |
|---|---|
| Paid-up share capital | HK$5,000,000 at all times |
| Liquid capital | Higher of HK$3,000,000 and the statutory basic amount |
| Liquid assets in Hong Kong | Twelve months of projected operating expenses, excluding virtual assets |
| Client assets | Held on trust by the associated entity, separate from the platform’s own |
If the capital requirement can no longer be met, the operator notifies the SFC immediately and ceases the business under the standard licence conditions.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | No statutory period; the Licensing Handbook states no fixed processing time | Licensing Handbook for Virtual Asset Trading Platform Operators, paragraph 6.5.1 |
| Regulator’s published figure | Licences granted since the regime opened on 1 June 2023 cluster 12 to 27 months later; applications filed in February 2024 remained pending at 17 October 2026, over 32 months | SFC lists of virtual asset trading platforms (licensed, applicants, removed) |
| Application preparation | 10 to 12 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | 12 to 18 months after submission | Our own figure, from the regulator’s published data and our applications |
Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Application fee, Types 1 and 7 | HK$4,740 | Per regulated activity |
| Application fee, AML ordinance VA service | HK$4,740 | For the virtual asset service licence |
| Responsible officer approval | HK$2,950 | Each |
| Licensed representative | HK$1,790 | Each |
| Annual fees | Per the SFC fees rules | Payable to the SFC once licensed |
| External assessor | Set by the assessor | Phase 1 and Phase 2 reports |
| Professional fees | Fixed | Quoted after scoping |
The Hong Kong virtual asset framework has widened since the platform regime opened.
The licence covers platform operations in Hong Kong and active marketing to Hong Kong investors, under the active marketing tests in section 115 of the Securities and Futures Ordinance and section 53ZRB of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. A platform serving the European Union holds a MiCA authorisation and one serving the United Kingdom the FCA cryptoasset authorisation; we obtain each.
The Licensing Handbook sets out what leads the SFC to return an application and what lengthens processing.
A virtual asset firm needs accounts for client fiat funds, separated from its own, and operating accounts in the markets it serves. Banks review the financial crime framework first: customer due diligence, transaction monitoring, travel rule arrangements and the wallet screening tools. We open the accounts alongside the application, with the financial crime framework the banks review. See banking and payment processing.
There is no statutory period and the SFC states no fixed processing time. Licences have been granted 12 to 27 months after the regime opened in June 2023, and applications filed in February 2024 remained pending in October 2026; we plan for twelve to eighteen months after submission.
HK$5,000,000 paid-up share capital at all times, liquid capital of at least HK$3,000,000 and liquid assets in Hong Kong equal to twelve months of projected operating expenses, excluding virtual assets.
A token’s classification as a security or a non-security can change. The SFC recommends a dual licence under the Securities and Futures Ordinance and the AML ordinance, filed as one application.
A wholly owned associated entity incorporated in Hong Kong with a trust or company service provider licence, holding client assets on trust and conducting no other business.
At least one of the two responsible officers ordinarily resident, at least one an executive director, with managers-in-charge of core functions and premises in Hong Kong for the business and its records.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.
This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.
The licence, your team, banking and technology, delivered as one programme.