Crypto Law Profile

Hong Kong Guideline on Supervision of Licensed Stablecoin Issuers

HKMA guidance for licensed stablecoin issuers under Hong Kong’s Stablecoins Ordinance, covering reserves, redemption, financial resources, risk management, governance and disclosures.

Hong Kong Effective Agency guidance Aug 1, 2025

At a glance

Status In force as HKMA agency guidance since 1 Aug. 2025.
Regulator Issued by the Hong Kong Monetary Authority under Stablecoins Ordinance s. 171(4).
Scope Applies to licensed issuers of specified, fiat-referenced stablecoins in Hong Kong.
Core Focus Reserves, redemption, risk management, governance, disclosures and conduct.

Overview

The Guideline on Supervision of Licensed Stablecoin Issuers is Hong Kong Monetary Authority guidance for entities licensed under the Stablecoins Ordinance (Cap. 656) to issue fiat-referenced stablecoins in Hong Kong. As of 17 June 2026, it is in force. HKMA published the final guideline on 29 July 2025 as part of implementation materials, and the regime took effect on 1 August 2025.

The guideline is not a standalone statute. It explains HKMA supervisory expectations for the ongoing minimum criteria in Schedule 2 to the Stablecoins Ordinance and should be read with the ordinance, the HKMA licensing explanatory note, and the separate AML/CFT guideline for licensed stablecoin issuers. HKMA states that “must” refers to statutory requirements while “should” indicates regulatory expectations.

What the Hong Kong stablecoin supervision guideline covers

The guideline organizes HKMA expectations around reserve assets, issuance and redemption mechanics, distribution, business activities, financial resources, risk management, governance, disclosures, personal data protection, and complaints handling. It is aimed at licensed issuers rather than token holders, exchanges, or unlicensed issuers.

  • Reserve asset management and full backing of each specified stablecoin type.
  • Issuance, redemption and distribution procedures, including third-party distributors.
  • Financial resources, liquidity and orderly-exit capability.
  • Risk governance, technology controls, cybersecurity and private-key management.
  • White papers, public disclosures, accounting records and complaint handling.

Reserve backing, eligible assets and redemption

For reserve assets, the guideline states that each pool backing a specified stablecoin should at all times have market value at least equal to the par value of the outstanding stablecoins of that type. HKMA also expects over-collateralisation, reconciliation, prudent valuation, and board-approved reserve policies.

Eligible reserve assets include cash, bank deposits with terms of no longer than three months, qualifying marketable debt securities, certain overnight reverse repurchase receivables, dedicated investment funds, and other assets acceptable to HKMA. Except with HKMA approval, reserve assets should match the reference currency, or currency basket ratio, of the stablecoins they back.

The guideline also addresses segregation and safekeeping. Reserve assets must be separated from the issuer’s own assets and other reserve pools, protected from claims by other creditors, and held under trust arrangements or other structures acceptable to HKMA. Licensees remain primarily responsible even when custodians or investment managers are appointed.

Redemption is central to the guidance. Licensed issuers must provide holders with a right to redeem specified stablecoins at par value. Unless HKMA approves otherwise, valid redemption requests should be processed within one business day after receipt, with fees and conditions assessed for reasonableness and burden.

Risk governance, technology and conduct expectations

The financial resources section states that a licensee must maintain paid-up share capital of at least HK$25 million, or equivalent approved financial resources, unless it is an authorized institution subject to Banking Ordinance requirements. HKMA may impose higher resource requirements and expects liquid net assets funded by equity to support obligations and an orderly exit.

Risk management expectations include a board-approved framework, three lines of defence, independent risk, compliance and internal audit functions, and controls for credit, liquidity, market, operational, technology and third-party risks. The guideline calls for regular stress testing, including at least quarterly stress tests of reserve portfolios under severe but plausible scenarios.

Technology controls are detailed because issuance and redemption rely on distributed-ledger infrastructure. HKMA expects documented token standards, smart-contract architecture, lifecycle controls for minting and burning, authorization controls for high-risk operations, secure private-key arrangements, incident management, capacity planning, cybersecurity testing and continuity planning.

Business conduct provisions cover information systems, record keeping, public white papers, reserve and redemption disclosures, audited financial statements and complaints. White papers should describe the issuer, stablecoin, reserve arrangements, issuance and redemption mechanisms, technology, and risks. Complaint procedures should be public, with acknowledgement generally within seven calendar days and a full or interim response within 30 calendar days.

Status and related Hong Kong stablecoin materials

HKMA’s stablecoin regime page states that, following implementation of the Stablecoins Ordinance on 1 August 2025, issuance of fiat-referenced stablecoins is a regulated activity in Hong Kong and a licence is required. On 10 April 2026, HKMA announced stablecoin issuer licences for Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. This profile treats the guideline as in force agency guidance within Hong Kong’s broader stablecoin licensing framework.

Key provisions

Full reserve backing

Licensees must maintain reserve pools with market value at least equal to outstanding par value, with reconciliation and appropriate buffers.

Stablecoins Aug 1, 2025 Source

Eligible reserve assets

Reserve assets should be high quality, liquid and low risk, such as cash, short-term deposits, qualifying debt securities and HKMA-approved assets.

Custody Aug 1, 2025 Source

Segregation and safekeeping

Reserve assets must be segregated from issuer assets and protected from other creditor claims, with trust arrangements or HKMA-acceptable structures.

Custody Aug 1, 2025 Source

Par redemption rights

Specified stablecoin holders must have par redemption rights; valid requests should generally be processed within one business day after receipt.

Consumer protection Aug 1, 2025 Source

Financial resources

Non-bank licensees must maintain at least HK$25 million paid-up share capital or equivalent approved financial resources, plus liquid net assets.

Licensing & Registration Aug 1, 2025 Source

Risk and technology controls

Licensees should maintain board-approved risk frameworks, three lines of defence, stress tests, token controls, cybersecurity and private-key safeguards.

Privacy & Cybersecurity Aug 1, 2025 Source

Disclosures and complaints

Licensees should publish white papers, reserve and redemption disclosures, audited statements and accessible complaint handling procedures.

Disclosure & Marketing Aug 1, 2025 Source

Timeline

  1. Stablecoins Bill passed

    Hong Kong Legislative Council passed the Stablecoins Bill establishing the issuer licensing regime.

    Passed Source
  2. Commencement date appointed

    Government notice appointed 1 Aug. 2025 as commencement date for the Stablecoins Ordinance.

    Enacted Source
  3. Final guideline published

    HKMA published consultation conclusions and the final supervision guideline for licensed stablecoin issuers.

    Enacted Source
  4. Guideline in force

    Stablecoin issuer regime took effect; HKMA stated the guidelines would be published in the Gazette on this date.

    In force Source
  5. First issuer licences granted

    HKMA granted stablecoin issuer licences to Anchorpoint Financial and HSBC under the ordinance.

    In force Source

Who it affects

Actors

Hong Kong Monetary Authority

Asset classes

Fiat-referenced stablecoins, Stablecoins

Official sources

Editorial note

This profile summarizes HKMA supervisory guidance and should be read with the Stablecoins Ordinance (Cap. 656), the HKMA licensing explanatory note and the AML/CFT guideline. It is not legal advice.