On 10 April 2026, the HKMA granted Hong Kong’s first two stablecoin issuer licences. One went to HSBC. The other went to Anchorpoint Financial, the joint venture behind Standard Chartered’s Hong Kong bank, HKT and Animoca Brands. By the application deadline the previous September, the regulator had reportedly received 36 submissions. Two got through the first round.
If you read that as a closed door, read it again. Hong Kong did not build this regime to license two issuers. It built a permanent, statutory framework, set a high bar, and started with the names it knew best. The door is open. It is just narrow, and the cost of walking through it is real.
Here’s what the regime actually requires, and what it means if you issue, hold, or build on a stablecoin from Hong Kong.
What the law covers, and who needs a licence
The framework sits in the Stablecoins Ordinance (Cap. 656). LegCo passed it on 21 May 2025 and it came into force on 1 August 2025. The regulator is the Hong Kong Monetary Authority.
The Ordinance regulates one specific activity: issuing a fiat-referenced stablecoin, which the law shortens to FRS. A fiat-referenced stablecoin is one that claims to hold its value against an official currency, the kind of “always worth one dollar” token most of the market runs on. Algorithmic stablecoins and tokens pegged to other assets sit outside this particular regime for now. The HKMA has indicated that the definition of “specified stablecoin” can be extended by gazette notice to capture additional classes of tokens, including other units of account or stores of economic value, without requiring fresh primary legislation. Founders building on non-fiat-pegged tokens should monitor for any such extension.
Two triggers bring you inside the licensing net. The first is obvious: issuing an FRS in Hong Kong. The second catches more people than they expect. If you issue a stablecoin that references the Hong Kong dollar, you need a licence wherever in the world you issue it. A token pegged to the HKD, run from Singapore or the BVI, is still Hong Kong’s business. If you have built anything around a HKD-referenced coin, this is the line to check first. We cover the wider picture of what shifted when the law landed in Hong Kong’s new stablecoin law.
What it takes to get licensed
The HKMA was blunt from the start. In the joint statement it issued with the SFC in August 2025, it warned the market that the bar would be “reasonably high” and that an application was not an endorsement. The 36-to-2 ratio in the first round was the proof.
A few requirements sit at the centre of the regime.
Capital comes first. An applicant needs at least HK$25 million in paid-up share capital, or equivalent financial resources the HKMA accepts. Licensed banks are treated differently here, which is part of why HSBC and a Standard Chartered-backed venture led the field. For a fintech issuer without a banking parent, HK$25 million locked into the cap table before you earn a cent is the first filter, and it is doing its job.
Reserves are where the regime has teeth. Every stablecoin in issue must be fully backed, at par, at all times, by a pool of high-quality, highly liquid assets. The reserve has to be segregated from the issuer’s own money, held with qualified custodians, and matched to the same currency the coin references. The HKMA expects regular independent attestation and audit, and public disclosure of what the reserve actually holds. This is the line between a regulated stablecoin and the failures the market still remembers. The reserve has to be there, in real assets, that someone independent has checked.
Redemption is the holder’s protection. Anyone holding a licensed stablecoin must be able to redeem it at par, without unreasonable fees or conditions, through a mechanism that actually works. “Worth a dollar” only means something if you can get your dollar back.
There are conduct rules layered on top. Only a licensed issuer’s stablecoin can be offered to retail investors in Hong Kong. An unlicensed FRS can only be sold to professional investors, and only through authorised intermediaries. It is an offence to advertise a regulated stablecoin activity without the standing to do so, or to falsely hold yourself out as a licensee or applicant. Licensees have to display their licence number on their consumer-facing material. The HKMA is not subtle about this part, because the whole point of the regime is that a retail user can trust the label.
Timing, and the cost of the high bar
The HKMA does not publish a fixed processing time. It says, plainly, that how long an application takes depends on the application. Translation: a thin submission will sit, and a strong one will still take months of back-and-forth on reserves, custody and governance.
The first round ran on a clear calendar. The regulator invited expressions of interest by August 2025 and applications by 30 September 2025, then took until April 2026 to grant the first two. That is roughly six months of review for the most prepared applicants in the market, several of whom had already spent a year inside the HKMA’s sandbox. If you are starting now, budget accordingly and don’t let a fundraising deck promise a launch date the licensing queue can’t support.
The cost is not only time. Gate, a sizeable exchange, reportedly walked away from its separate Hong Kong trading-platform application citing the expense of meeting local requirements. Stablecoin issuance is heavier still. Between the capital, the custody arrangements, the audit and attestation cycle and the compliance hires, this is a regime built for issuers who intend to operate at scale and can fund the runway to get there.
What this means if you’re building in the space
For most founders, the practical question isn’t “should I become a licensed issuer.” It’s “where do I sit relative to one.”
If you are issuing or planning to issue an FRS from Hong Kong, or anything pegged to the HKD from anywhere, you need a licence or a clear, documented reason you fall outside the regime. Don’t assume the second one. The definitions are wider than they look.
If you build on stablecoins rather than issue them, the wallets, the payment rails, the on-and-off ramps, your exposure runs the other way. You want to be integrating licensed coins, because offering an unlicensed FRS to the wrong user is now an offence, not a grey area. The licence number on the label is about to become a procurement question.
And if you are raising on a stablecoin thesis, investors are going to ask where you stand on Cap. 656 in the first meeting. Have the answer ready. The firms that came through the first round did the regulatory work before they needed it, not after the term sheet.
This is the part TITUS spends most of its time on: working out where a virtual asset business actually sits under the regime, what it has to fix before it applies, and how to structure the entity, the reserves and the fund structuring around it so the application survives contact with the HKMA. Our virtual asset and fintech team has tracked this regime from the consultation papers through to the first grants.
The two licences out the door are the start of the list, not the whole of it. If you want to be on it, the work starts before the application does. Book a consultation and we’ll tell you, straight, whether you’re ready.
This article reflects our understanding of the position under Hong Kong law and applicable regulatory guidance as at June 2026. The regulatory framework for virtual assets continues to develop and is subject to change. Nothing in this article is, or should be taken as, legal advice or a recommendation on any specific matter or product. For advice on your situation, speak to a qualified Hong Kong solicitor.