Hong Kong’s Legislative Proposal to Regulate Virtual Asset Advisory Service Providers and Virtual Asset Management Service Providers is a pending regulatory proposal for the Hong Kong Special Administrative Region. As of June 17, 2026, it has not been enacted. The Financial Services and the Treasury Bureau and the Securities and Futures Commission published consultation conclusions in May 2026 and said they would finalise legislative proposals under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, with a view to introducing a bill into the Legislative Council in 2026.
The proposal would create two standalone licensing or registration regimes: one for virtual asset advisory services and one for virtual asset management services. It forms part of Hong Kong’s wider effort to extend the virtual asset regulatory perimeter beyond licensed virtual asset trading platforms, alongside proposed regimes for virtual asset dealing and custody.
Proposed Hong Kong virtual asset advisory regime
The proposed advisory regime would cover a person carrying on a business in Hong Kong of advising on whether, which, when, or on what terms virtual assets should be acquired or disposed of. It would also cover issuing analyses or reports that help recipients make those acquisition or disposal decisions.
The FSTB and SFC describe the regime as technology neutral. The consultation conclusions state that the substance of the activity matters more than labels such as education, research, commentary, or trading signals. Copy trading, mirror trading, specific alerts, or AI-generated virtual asset recommendations could fall within scope where they amount to advice. Generic factual information, or tools that objectively filter factual information for self-directed research, are treated differently in the official discussion.
Proposed Hong Kong virtual asset management regime
The proposed management regime would cover a person carrying on a business in Hong Kong of managing a portfolio of virtual assets for another person. The FSTB and SFC said the regime is intended to align with Type 9 asset management concepts under the Securities and Futures Ordinance, including discretionary management of funds and discretionary accounts. The proposal would not include a de minimis threshold for virtual asset exposure.
The consultation conclusions distinguish direct management of virtual assets from management of securities or investment products that reference virtual assets. A manager of a portfolio that includes both virtual assets and investment products referencing virtual assets may need both an AMLO virtual asset management licence or registration and an SFO Type 9 licence or registration, depending on the final statutory wording.
Key regulatory design choices
- Regulatory model: the advisory regime is intended to broadly align with Type 4 advising on securities, while the management regime is intended to broadly align with Type 9 asset management.
- Financial resources: proposed baseline requirements include HK$100,000 minimum liquid capital for firms not holding client assets, and HK$5 million paid-up share capital plus HK$3 million minimum liquid capital in other cases.
- Existing intermediaries: the new regimes would operate as standalone AMLO regimes and would replace the current practice of imposing virtual asset terms and conditions on SFO intermediaries once the regimes are in force.
- Transition: the FSTB and SFC do not plan a deeming arrangement for existing providers. The regimes are expected to take full effect from the commencement date of the relevant statutory provisions.
- Marketing reach: the proposal would prohibit active marketing of covered virtual asset services to the Hong Kong public unless the person is licensed or registered for the relevant virtual asset service.
Status and next steps
The one-month further consultation closed on Jan. 23, 2026, and the May 2026 conclusions reported 51 submissions. The FSTB and SFC said they would finalise the legislative proposals and target introduction of the relevant bill into the Legislative Council within 2026. The SFC also expects to engage pre-applicants, consult on detailed regulatory requirements, and issue those requirements as appropriate.
Because no bill has yet been enacted, effective dates, commencement provisions, offences, appeal mechanics, and final licensing conditions remain subject to the future bill and subsidiary regulatory materials.