Crypto Law Profile

Explanatory Note on Licensing of Stablecoin Issuers

HKMA guidance explaining how Hong Kong’s Stablecoins Ordinance licensing regime applies to stablecoin issuers, including scope, minimum criteria, application procedures, ongoing obligations and supervisory powers.

Hong Kong Effective Agency guidance Aug 1, 2025

At a glance

Jurisdiction Hong Kong SAR guidance under the Stablecoins Ordinance (Cap. 656).
Regulator The Monetary Authority, operating through the HKMA, administers licensing.
Status Guidance published July 2025; regime in force since Aug. 1, 2025.
Scope Targets fiat-referenced specified stablecoin issuance and HKD-linked issuance.

Overview

The Explanatory Note on Licensing of Stablecoin Issuers is Hong Kong Monetary Authority guidance for the licensing regime created under the Stablecoins Ordinance (Cap. 656). Published with the HKMA’s July 2025 implementation package, the Note explains how the Monetary Authority interprets licensing scope, minimum criteria, application procedures, ongoing duties and supervisory powers for persons that intend to conduct regulated stablecoin activities in Hong Kong.

As of June 17, 2026, the guidance remains part of Hong Kong’s active stablecoin issuer framework. The underlying regime came into operation on August 1, 2025, and the HKMA has since begun granting licences and maintaining a public register of licensed stablecoin issuers.

Hong Kong stablecoin licensing scope

The Note focuses on specified stablecoins, currently covering fiat-referenced stablecoins that purport to maintain a stable value by reference wholly to one or more official currencies. A regulated stablecoin activity includes issuing a specified stablecoin in Hong Kong in the course of business, issuing one outside Hong Kong that purports to maintain a stable value by reference wholly or partly to Hong Kong dollars, or another activity specified by the Monetary Authority.

The HKMA indicates that determinations such as whether a stablecoin is issued in Hong Kong, or whether an activity is actively marketed to the Hong Kong public, are fact-specific. Relevant factors may include management and operations, incorporation, minting and burning arrangements, reserve-asset management, cash-flow bank accounts, language used in marketing, Hong Kong targeting and domain names.

Key provisions for stablecoin issuer applicants

  • Corporate status: applicants must generally be Hong Kong-incorporated companies, while authorized institutions incorporated outside Hong Kong are treated separately under the Note.
  • Financial resources: non-authorized institution applicants must meet adequate financial-resources expectations, including a HKD25 million paid-up share capital benchmark or approved equivalent resources.
  • Reserve assets: each type of specified stablecoin requires a segregated reserve asset pool. The reserve pool must at least equal the par value of outstanding tokens, with the HKMA expecting an appropriate buffer where needed.
  • Redemption: holders must have a right to redeem at par value. Unless otherwise approved, valid redemption requests should be processed within one business day after receipt.
  • Governance and controls: applicants must address fit-and-proper standards, risk governance, technology risk, operational resilience, AML/CFT controls, disclosure, complaint handling, recovery planning and orderly wind-down.

Application process and supervisory posture

The Note encourages prospective applicants to speak with the HKMA licensing team before submitting an application. Applicants are expected to provide the required forms and supporting documents, and the HKMA may request additional materials, including independent assessment reports. Licensing applications are considered by a Stablecoin Advisory Committee, which makes recommendations on licensing matters under the Ordinance.

If a licence is granted, the HKMA notice specifies the licence number and the date on which the licence takes effect. Licensees must then meet ongoing requirements, including paying licence fees, displaying licence numbers on relevant advertising material and consumer-facing software interfaces, and continuing to fulfil the minimum criteria. The Note also summarises HKMA powers over licensees, including powers that may become available where a licensee is insolvent, unable to meet obligations, contravenes the Ordinance or licence conditions, or carries on business in a manner detrimental to holders or creditors.

Status and related Hong Kong stablecoin materials

The licensing Note should be read with Cap. 656, the HKMA’s supervisory guideline for licensed stablecoin issuers and the AML/CFT guideline for licensed stablecoin issuers. It is guidance rather than a standalone statute, and the Note itself states that it is not a substitute for appropriate legal or other professional advice.

For CryptoSlate taxonomy purposes, this profile is best treated as Hong Kong agency guidance under an in-force stablecoin licensing regime, with primary topics in stablecoins, licensing, payments, AML/CFT and consumer protection.

Key provisions

Licensing perimeter

Explains regulated stablecoin activity, including Hong Kong issuance, HKD-referenced offshore issuance and active marketing to the Hong Kong public.

Licensing Aug 1, 2025 Source

Applicant status and financial resources

Describes eligible applicant status and financial-resource expectations, including the HKD25 million paid-up share capital benchmark for relevant applicants.

Licensing Aug 1, 2025 Source

Reserve backing and safekeeping

Requires segregated reserve pools for each stablecoin type and at least par-value backing of outstanding specified stablecoins.

Stablecoins Aug 1, 2025 Source

Redemption at par

States that holders must have a right to redeem at par and that valid requests should generally be processed within one business day after receipt.

Consumer protection Aug 1, 2025 Source

Risk, AML/CFT and governance controls

Covers fit-and-proper expectations, risk governance, technology and operational controls, AML/CFT systems, disclosures and complaint handling.

AML/CFT Aug 1, 2025 Source

Application review and public communications

Encourages early HKMA discussion, describes application review and warns parties not to imply applicant or licensee status improperly.

Disclosure Aug 1, 2025 Source

Timeline

  1. Stablecoins Bill passed

    Legislative Council passed the bill establishing Hong Kong’s fiat-referenced stablecoin issuer licensing regime.

    Passed Source
  2. Commencement date appointed

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

    Enacted Source
  3. Licensing Note published

    HKMA published the Explanatory Note with other implementation materials for the stablecoin issuer regime.

    Enacted Source
  4. Stablecoin regime in force

    The Stablecoins Ordinance came into operation and made fiat-referenced stablecoin issuance a licensed activity.

    In force Source
  5. First licences granted

    HKMA granted licences to Anchorpoint Financial Limited and HSBC, with licences effective the same day.

    Effective Source

Who it affects

Actors

Financial Services and the Treasury Bureau, Hong Kong Monetary Authority, Monetary Authority

Asset classes

Fiat-referenced stablecoins, Specified stablecoins, Stablecoins

Official sources

Editorial note

Profile covers the HKMA Explanatory Note, not the full Stablecoins Ordinance. The Note is guidance and should be read with Cap. 656, the Supervisory Guideline and the AML/CFT Guideline.