Hong Kong’s Joint circular on intermediaries’ virtual asset-related activities is an SFC/HKMA agency-guidance profile for licensed corporations and registered institutions that distribute virtual asset-related products or provide virtual asset dealing, advisory or asset-management services. The Securities and Futures Commission and Hong Kong Monetary Authority issued the current Joint Circular on 22 December 2023, superseding the 20 October 2023 and 28 January 2022 joint circulars.
The circular remains listed by the SFC as a regulatory requirement for virtual asset fund managers, intermediaries dealing in or advising on virtual assets, and intermediaries distributing virtual asset-related products. This profile reflects the 22 December 2023 Joint Circular, the 30 September 2025 supplemental joint circular and the SFC’s 27 May 2026 clarification for Relevant Stablecoin activities.
Scope of the Hong Kong VA intermediaries circular
The Joint Circular applies to intermediaries that carry on virtual asset-related activities, including the distribution of investment products with exposure to virtual assets, virtual asset dealing services, advisory services and portfolio-management activities. The circular defines “VA-related products” broadly to include products with a principal strategy to invest in virtual assets, products deriving value principally from virtual assets, and products tracking or replicating virtual asset returns.
Key provisions for VA-related products and services
The circular treats many VA-related products as likely complex products and layers investor-protection measures on top of Hong Kong’s existing complex-product regime. In most cases, intermediaries must observe selling restrictions, conduct a virtual asset knowledge assessment for clients other than institutional and qualified corporate professional investors, and consider whether clients have sufficient net worth to bear potential losses.
- Distribution: Intermediaries distributing VA-related products must address product suitability where applicable, conduct product due diligence, provide warning statements and observe applicable Hong Kong and cross-border selling restrictions.
- Dealing: The circular expects VA dealing services to be provided through arrangements with SFC-licensed virtual asset trading platforms, either by introducing clients to such platforms or through omnibus-account arrangements.
- Custody rails: Client deposits and withdrawals of virtual assets must use specified segregated-account arrangements with partnered SFC-licensed platforms or qualifying authorized financial institutions.
- Asset management: Type 9 asset managers meeting the VA de minimis threshold are subject to additional VA portfolio-management terms and conditions.
- Advisory services: Intermediaries providing VA advisory services are expected to observe suitability obligations and, for retail recommendations, focus on high-liquidity virtual assets available for retail trading on SFC-licensed platforms.
Supplemental updates and implementation
The 30 September 2025 supplemental joint circular states that it supplements the 22 December 2023 Joint Circular and updates licensing or registration conditions and terms and conditions for intermediaries. It introduced refinements and relaxations following market developments and industry feedback.
The 2025 supplement allows intermediaries to provide staking services to clients for whom they deal in virtual assets, subject to segregated-account arrangements and risk-disclosure requirements. It also clarifies that certain subscriptions and redemptions of investment products using virtual assets are not treated as VA dealing services, and that some net-worth and futures risk-disclosure requirements do not apply to institutional professional investors and qualified corporate professional investors.
Status of the Joint Circular
As of 17 June 2026, this profile treats the Joint Circular as in force agency guidance in Hong Kong, as supplemented in 2025 and further clarified for Relevant Stablecoin activities by the SFC’s 27 May 2026 circular. The 2026 circular expressly states that it clarifies the application of the Joint Circular to activities in Relevant Stablecoins and notes corresponding updates to the appendices to the Joint Circular.
This reference profile is for informational purposes only and does not provide legal, tax, investment or trading advice.