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Swiss Chinese Law Association — Geneva

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Legal Observatory / Finance and Payments

Legal Update China Hong Kong SAR Regulatory guidance

Hong Kong SAR Outlines Digital Asset Regulatory Advances and Upcoming Legislative Amendments

The Hong Kong SAR Government detailed progress under Policy Statement 2.0 and announced an upcoming bill to expand virtual asset regulations to dealing, advisory, management, and custody services.

What Changed

  • Planned introduction of a bill by end-2026 to amend Cap. 615, expanding oversight to virtual asset dealing, advisory, management, and custody.
  • SFC authorization of 17 retail products with tokenised classes reaching HK$10.3 billion in assets under management as of September 2026.
  • Issuance of two stablecoin licences in April 2026 under the Stablecoins Ordinance (Cap. 656) and relaunch of Cyberport's Pilot Subsidy Scheme on November 2, 2026.

On November 4, 2026, the Acting Secretary for Financial Services and the Treasury of Hong Kong SAR, Mr Joseph Chan, provided a Legislative Council reply updating the public on the implementation of Policy Statement 2.0 on the Development of Digital Assets in Hong Kong (issued in June 2025). The update impacts virtual asset trading platforms, financial institutions issuing or managing tokenised products, stablecoin issuers, and Web3.0 talent seeking to establish a presence in Hong Kong SAR.

To advance legal and regulatory streamlining under the principle of "same activity, same risks, same regulation," the Hong Kong SAR Government and the Securities and Futures Commission (SFC) plan to introduce a bill into the Legislative Council by the end of 2026. The bill will amend the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) to expand existing regulatory oversight for virtual asset trading platforms to cover virtual asset dealing, advisory, management, and custody services. Additionally, the Financial Services and the Treasury Bureau (FSTB) and the Hong Kong Monetary Authority (HKMA) are advancing a legislative review regarding distributed ledger technology (DLT) applications in fixed income markets.

Market development highlights show that by the end of September 2026, the SFC had authorized 17 retail investment products with tokenised classes, accounting for approximately HK$10.3 billion in assets under management. On October 26, 2026, two SFC-authorized tokenised money market funds commenced 24/7 secondary market trading on licensed virtual asset trading platforms. Following the entry into force of the Stablecoins Ordinance (Cap. 656) in August 2025, the HKMA granted two stablecoin issuer licences in April 2026 for cross-border, local payment, and asset trading use cases.

To support talent acquisition and commercialization, the Government re-opened applications for Cyberport's Blockchain and Digital Asset Pilot Subsidy Scheme on November 2, 2026, after an initial round facilitated HK$230 million in asset tokenisation across funded projects. International virtual asset platforms are encouraged to seek SFC licensing subject to statutory requirements.

Who May Be Affected

Virtual asset trading platforms, financial institutions, fund managers, stablecoin issuers, and Web3.0 fintech professionals in or expanding to Hong Kong SAR.

Cross-Border Context

Establishes regulatory compliance pathways for international virtual asset platforms, tokenised product issuers, and Web3.0 talent targeting the Hong Kong SAR market.

What to check next

  • Track the official introduction of the Cap. 615 amendment bill into the Legislative Council by late 2026.
  • Monitor further licensing announcements and guidelines from the HKMA and SFC regarding stablecoin issuers and DLT applications in fixed income markets.

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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