Crypto Law Profile

Stablecoins Ordinance Professional Investor Notice (Hong Kong)

Hong Kong subsidiary legislation specifying professional investors as the class of persons for section 9(2)(b)(iii) of the Stablecoins Ordinance.

Hong Kong Effective Act Aug 1, 2025

At a glance

Status In force in Hong Kong from 1 August 2025.
Specified class Professional investors are specified for section 9(2)(b)(iii).
Instrument Cap. 656A; Legal Notice No. 126 of 2025.
Authority Made by the Financial Secretary under section 9(3).

Overview

The Stablecoins Ordinance (Specification of Persons for Section 9(2)(b)(iii)) Notice is Hong Kong subsidiary legislation under the Stablecoins Ordinance (Cap. 656). The Notice is identified as Cap. 656A and L.N. 126 of 2025. It came into operation on 1 August 2025 and, as of 16 June 2026, should be treated as in force unless an editor identifies a later amendment, repeal or replacement in Hong Kong e-Legislation.

The instrument is narrow but important. It specifies professional investors as the class of persons for the purposes of section 9(2)(b)(iii) of the Stablecoins Ordinance. In practical editorial terms, the Notice sits inside Hong Kong’s wider stablecoin offering restrictions. It does not create the licensing regime on its own, but it helps define one of the circumstances in which the section 9(1) offering prohibition does not apply.

Key Provisions of Cap. 656A

Professional investors are the specified class

The Schedule to Cap. 656A states that “professional investor” has the meaning given by section 1 of Part 1 of Schedule 1 to the Securities and Futures Ordinance (Cap. 571). Part 2 of the Schedule then specifies “Professional investor” as the relevant class of persons. This is the operative content of the Notice.

Connection to section 9 of the Stablecoins Ordinance

The explanatory note to L.N. 126 of 2025 states that section 9(1) of the Stablecoins Ordinance prohibits a person from offering, or holding out as offering, a specified stablecoin. Section 9(2) sets out circumstances in which that prohibition does not apply. One condition under section 9(2)(b) is that the stablecoin is offered to a person, or class of persons, specified for section 9(2)(b)(iii) under section 9(3). Cap. 656A supplies that specified class.

Authority and commencement

The Financial Secretary made the Notice under section 9(3) of the Stablecoins Ordinance. The Legal Notice was signed by Financial Secretary Paul Chan Mo-po on 3 June 2025, published in the Gazette on 6 June 2025, tabled before the Legislative Council for negative vetting on 11 June 2025, and commenced on 1 August 2025.

Jurisdictional Impact in Hong Kong

Hong Kong’s government described the main Stablecoins Ordinance as a framework to supervise stablecoin-related activities and introduce a licensing regime for regulated stablecoin activities in Hong Kong. The Hong Kong Monetary Authority states that, after implementation on 1 August 2025, the business of issuing fiat-referenced stablecoins became a regulated activity in Hong Kong and a licence is required.

Cap. 656A should therefore be read as a supporting notice within that broader regime. It is relevant to offers of specified stablecoins issued by a person that has not been granted a licence under section 15 of the Stablecoins Ordinance, where the conditions in section 9(2)(b) are otherwise met. The government press release described the Notice as allowing such offers to professional investors.

Status and Timeline

  • 21 May 2025: The Stablecoins Ordinance was enacted by the Legislative Council.
  • 30 May 2025: The main Ordinance was published in the Gazette.
  • 3 June 2025: The Financial Secretary made the Specification Notice.
  • 6 June 2025: The Notice was published in the Gazette.
  • 11 June 2025: The Notice was scheduled for tabling before the Legislative Council for negative vetting.
  • 1 August 2025: Cap. 656A came into operation alongside the main Stablecoins Ordinance.

Editorial Reading

For CryptoSlate readers, the Notice is best understood as a professional-investor specification rather than a full stablecoin rulebook. Its central function is to identify who may receive certain specified stablecoin offers under the section 9(2)(b) pathway. The licensing, supervision, AML/CFT and issuer requirements remain anchored in the main Stablecoins Ordinance and HKMA materials.

Key provisions

Commencement

The Notice came into operation on 1 August 2025.

Stablecoins Aug 1, 2025 Source

Professional investor class

The Schedule specifies professional investors, using the Securities and Futures Ordinance definition.

Investor scope Aug 1, 2025 Source

Section 9 offering pathway

The specified class supports one condition in section 9(2)(b), where section 9(1) does not apply if statutory conditions are met.

Offering scope Aug 1, 2025 Source

Financial Secretary authority

The Notice was made by the Financial Secretary under section 9(3) of the Stablecoins Ordinance.

Authority Jun 3, 2025 Source

Timeline

  1. Notice made

    Financial Secretary Paul Chan Mo-po made the Specification Notice.

    Enacted Source
  2. Gazette publication

    The Specification Notice was published in the Gazette.

    Enacted Source
  3. LegCo negative vetting

    The LegCo brief listed this date for tabling before LegCo for negative vetting.

    Enacted Source
  4. Notice in force

    Cap. 656A came into operation alongside the Stablecoins Ordinance.

    In force Source

Who it affects

Actors

Financial Secretary, Financial Services and the Treasury Bureau, Hong Kong Monetary Authority, Legislative Council of Hong Kong

Asset classes

Fiat-referenced stablecoins, Stablecoins

Official sources

Editorial note

Subsidiary legislation under the Stablecoins Ordinance (Cap. 656). The law-type taxonomy is mapped to Act because the controlled vocabulary does not include a standalone notice or subsidiary-legislation term.