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Legal Observatory / Finance and Payments

Legal Update China Hong Kong SAR Draft legislation

Hong Kong SAR Announces Virtual Asset Legislation, Tokenisation Pilots, and AI Fraud Framework

Hong Kong SAR announced upcoming virtual asset legislation, financial tokenisation pilots, sandbox expansions, and planned legal consultations to combat online financial fraud.

What Changed

  • Plan to introduce a bill to the Legislative Council before the end of 2026 to regulate advisory, dealing, custody, and management of virtual assets.
  • Launch of Project Ensemble interbank tokenised gold transaction pilot and HKEX tokenisation platform for carbon credits and LME warehouse receipts.
  • Expansion of GenA.I. Sandbox++ across financial sectors and upcoming public consultation to strengthen legal tools against online financial scams and deepfakes.

Financial institutions, virtual asset service providers, technology firms, and investors operating in or targeting Hong Kong SAR face upcoming regulatory and market infrastructure developments following remarks by the Secretary for Financial Services and the Treasury, Mr Christopher Hui, at the FinTech Week x StartmeupHK Festival 2026 on 2 November 2026. The announced initiatives focus on data infrastructure, financial asset tokenisation, and artificial intelligence (AI) risk management.

On infrastructure and data integration, the Hong Kong Monetary Authority's (HKMA) Commercial Data Interchange now connects 28 banks and 17 data sources, which has reduced small and medium-sized enterprise borrowing costs by an average of 36 basis points. In tokenisation, HKMA's Project Ensemble will soon initiate an interbank tokenised gold transaction project featuring a token representing a standard 400-ounce gold bar priced via Hong Kong's HAU reference price, supported by tokenised deposits. Furthermore, the Hong Kong Stock Exchange plans to pilot trading of tokenised carbon credits this year on a blockchain-backed multi-asset tokenisation platform, expanding next year to include warehouse receipts from London Metal Exchange (LME)-approved warehouses in Hong Kong.

To establish a clear regulatory framework, the Government will introduce a bill to the Legislative Council before the end of 2026 to regulate the advisory, dealing, custody, and management of virtual assets. To support innovation alongside regulation, Cyberport opened applications for the Blockchain and Digital Asset Pilot Subsidy Scheme 2.0 on 2 November 2026. Regarding AI, the expanded GenA.I. Sandbox++ now covers the banking, securities, insurance, and mandatory provident fund sectors. Addressing emerging risks such as agentic AI and deepfakes, the Financial Services Development Council is studying agentic AI risks, while the Government will consult the public later this year on enhancing legal frameworks to detect and remove online fraudulent financial content.

Who May Be Affected

Banks, virtual asset intermediaries, financial technology providers, commodity traders, insurance firms, securities firms, and retail/institutional investors in Hong Kong SAR.

Cross-Border Context

Hong Kong SAR reinforces its role as a global fintech hub by integrating international market participants, multi-asset tokenisation (including LME warehouse receipts), and cross-border digital financial solutions.

What to check next

  • Introduction of the virtual asset regulation bill to the Legislative Council of Hong Kong SAR before the end of 2026.
  • Publication of the official public consultation document on legal framework enhancements against online financial scams and deepfake content.
  • Launch details and guidelines for HKEX pilot trading of tokenised carbon credits and LME warehouse receipts.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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