Licensing Handbook for Virtual Asset Trading Platform Operators is Hong Kong Securities and Futures Commission guidance for virtual asset trading platform operators, or VATPs. The current SFC listing identifies the handbook as a 15 July 2025 guideline, while the document cover describes the July 2025 version. It operates within Hong Kong’s broader VATP framework under the Securities and Futures Ordinance (Cap. 571) and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
The handbook is best read as a licensing-process guide rather than a standalone statute. It explains how centralized VATP operators and relevant individuals approach licensing, approval criteria, responsible officer requirements, post-licence filings, ongoing notifications and related applications. The SFC’s VATP page describes it as a practical guide for licence applications and post-licence matters.
What the Hong Kong VATP Licensing Handbook Covers
The handbook sits alongside the Guidelines for Virtual Asset Trading Platform Operators, AML/CFT guidance, SFC circulars and the underlying ordinances. The companion VATP Guidelines contain the substantive regulatory standards for platform conduct, financial soundness, operations, client dealing, custody, cybersecurity, conflicts, record keeping, auditors, and notification obligations.
- It explains when a corporation or individual may need SFC licensing for a regulated activity and/or virtual asset service.
- It summarises application procedures for platform operators, responsible officers, licensed representatives and associated entities.
- It describes recurring post-licence notifications, annual returns, fees, changes in particulars and continuous professional training expectations.
Licensing Scope and Dual Licence Arrangement
Hong Kong’s VATP regime distinguishes between activities involving security tokens and non-security tokens, but the SFC’s public materials note that classification may change over time. The SFC therefore states that it would be appropriate for VATPs to apply under both the SFO and AMLO regimes to avoid contravening the licensing regimes and to support business continuity.
Under the handbook, a person generally needs to be licensed for Type 1 dealing in securities and Type 7 automated trading services under the SFO, and/or for providing a virtual asset service under the AMLO, where the relevant Hong Kong business or active marketing tests are met. The handbook also states that a licence issued under the SFO and/or AMLO only allows the holder to carry on the relevant activities in Hong Kong; other jurisdictions’ laws remain separate considerations.
Key Requirements for Platform Operators
Applicants, responsible officers and licensed representatives
For platform operators, the SFC’s licensing assessment includes fit and proper considerations such as financial status, qualifications, competence, honesty, reputation, reliability and financial integrity. The handbook states that an applicant must be incorporated in Hong Kong or registered as an overseas company in Hong Kong, and must show appropriate business structure, internal controls and qualified personnel. It also describes responsible officer expectations, including a minimum of two responsible officers, at least one ordinarily resident in Hong Kong, and responsible officer approval for executive directors.
Ongoing notifications and training
Post-licence obligations are central to the handbook. Common change events include cessation of business, changes involving representatives or responsible officers, business address changes, changes in directors, share capital, shareholding structure, contact information, business plan and service types. The handbook states that notifications must be made through WINGS-LIC. It also summarises continuous professional training expectations for licensed individuals and additional compliance training for responsible officers.
Status and Timeline
The SFC’s implementation circular stated that the new licensing regime for centralized VATPs under the AMLO came into effect on 1 June 2023 and referred to the dual licence arrangement under the SFO and AMLO. The SFC’s consultation conclusions said the revised proposed regulatory requirements would become effective on the same date. The current handbook version is mapped here to the SFC’s 15 July 2025 listing.
Editorial Context
This profile treats the handbook as agency guidance for Hong Kong’s active VATP licensing framework. It should be reviewed with current SFC circulars, the VATP Guidelines, AML/CFT materials and the official SFO and AMLO texts. Nothing in this profile is legal, tax, investment or trading advice.