The Guidelines for Virtual Asset Trading Platform Operators are Hong Kong Securities and Futures Commission guidance for centralized virtual asset trading platforms operating in Hong Kong or actively marketing to Hong Kong investors. As of 17 June 2026, the SFC lists the Guidelines as an operative code-and-guidelines instrument dated 1 June 2023, and they sit within the broader licensing framework under the Securities and Futures Ordinance and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance.
The Guidelines are designed for platform operators licensed under the SFO and/or AMLO when they carry on relevant virtual asset trading platform activities. They should be read with the SFC’s licensing materials, virtual-asset AML/CFT guideline, FAQs, circulars, and later supervisory materials. This profile summarizes the instrument as a legal-reference entry and is not compliance advice.
Scope of the Hong Kong VATP Guidelines
The SFC states that centralized virtual asset trading platforms carrying on business in Hong Kong, or actively marketing services to Hong Kong investors, are required to be licensed and regulated by the SFC. The VATP page distinguishes the SFO regime for platforms dealing in security tokens from the AMLO regime for platforms dealing in non-security tokens, while noting that a token’s classification may change over time.
The Guidelines themselves state that they apply to all Platform Operators, whether licensed under the SFO and/or AMLO, when they carry on relevant activities. For dually licensed operators, the SFC expects compliance with the SFO, AMLO, SFC codes, guidelines, circulars and FAQs, with the more stringent requirement prevailing where requirements are inconsistent.
Key provisions for virtual asset trading platform operators
Licensing conduct and financial soundness
The Guidelines set conduct principles covering honesty and fairness, due skill and diligence, disclosure, client-asset safeguarding, proper records and senior-management responsibility. Platform operators are also expected to maintain liquid assets in Hong Kong equivalent to at least 12 months of operating expenses and paid-up share capital of not less than HK$5 million.
Token admission, retail access and client onboarding
A platform operator must establish a token admission and review committee, perform due diligence on virtual assets before admitting them to trading, and conduct ongoing monitoring. For retail trading, the Guidelines require additional safeguards, including high liquidity and, at minimum, inclusion in two acceptable indices issued by at least two different index providers unless the SFC considers a case-specific proposal. The client-facing provisions also address investor knowledge, know-your-client checks, risk tolerance, client agreements, risk disclosures and suitability obligations.
Custody, market integrity and cybersecurity
The custody provisions require client virtual assets to be safeguarded through an associated entity, segregated from the assets of the platform operator and associated entity, and generally held 98% in cold storage. The Guidelines also set expectations for private-key controls, wallet whitelisting, compensation arrangements, market surveillance, prohibitions on specified manipulative practices, restrictions on proprietary trading, cybersecurity governance, two-factor authentication and recordkeeping.
Status and transitional timeline
The SFC issued the implementation circular and transitional circular on 31 May 2023. The new AMLO licensing regime came into effect on 1 June 2023. Pre-existing non-security-token VATPs could rely on a non-contravention arrangement until 31 May 2024 if they met the stated conditions, and fully completed applications submitted by 29 February 2024 could qualify for a deeming arrangement from 1 June 2024 pending determination.
On 28 May 2024, the SFC reminded the public that the non-contravention period would end on 1 June 2024 and that all VATPs operating in Hong Kong must be licensed or deemed-to-be-licensed applicants. The SFC also stated that deemed applicants are not formally licensed and remain subject to the SFC’s supervisory, disciplinary and other applicable powers. Later SFC circulars and licensing-process updates should be checked alongside the Guidelines for the most current supervisory expectations.