HKMA Project Ensemble: Tokenised Deposits Enter Real-Value Pilot

On 13 November 2025, the Hong Kong Monetary Authority (HKMA) launched Ensemble TX, the pilot phase of Project Ensemble, and with it moved tokenised-deposit settlement out of the laboratory and into real-value transactions. HKMA Project Ensemble had spent more than a year as a sandbox; Ensemble TX now lets participating banks settle interbank tokenised deposit transactions with actual customer money, running throughout 2026. Seven named commercial banks will provide tokenised deposits to customers in Hong Kong, with the interbank leg initially routed through the Hong Kong dollar Real-Time Gross Settlement (RTGS) system.

For a reporting or compliance officer, the pilot is a signal about sequencing. Tokenised deposits are entering live settlement before the wholesale settlement asset is finalised. Interbank legs run on the existing RTGS today, and the HKMA has said the environment will be upgraded later to settle in tokenised Central Bank Money (CeBM) on a 24/7 basis. The gap between a live product and an evolving settlement rail is where the operational, custody and reconciliation questions concentrate.

Ensemble TX does not itself create a standalone supervisory return. The applicable regulatory perimeter depends on the instrument and activity. Authorized institutions remain subject to the Banking Ordinance and applicable HKMA guidance on tokenised products and DLT; SFC requirements apply where SFC-authorised investment products or regulated intermediary activities are involved; and the Stablecoins Ordinance applies to fiat-referenced stablecoins, while section 3 excludes an instrument that constitutes a deposit under section 2(1) of the Banking Ordinance from the statutory definition of a stablecoin.

Related reading: Hong Kong’s Stablecoins Ordinance and HKMA issuer licences

The Project Ensemble timeline at a glance

Ensemble has advanced in stages, and the dates matter for anyone trying to work out when a supervisory expectation attaches. The sequence below is drawn from HKMA press releases and its Project Ensemble materials.

• March 2024: the HKMA announces Project Ensemble, a wholesale central bank digital currency initiative built around tokenised money.
• May 2024: the Project Ensemble Architecture Community is established, bringing banks, technology firms, the SFC and academics together to work on interoperability standards.
• August 2024: the Ensemble Sandbox begins, letting industry participants test end-to-end use cases for settling digital-asset transactions using experimental tokenised deposits.
• 1 August 2025: the Stablecoins Ordinance takes effect, creating a licensing regime for fiat-referenced stablecoin issuers, a separate track from tokenised deposits.
• 13 November 2025: the HKMA launches Ensemble TX, the pilot phase, enabling real-value tokenised deposit and digital-asset transactions.
• Throughout 2026: Ensemble TX operates, with interbank settlement initially via the HKD RTGS system and a planned upgrade to 24/7 tokenised CeBM settlement.

From sandbox experiment to real-value pilot

The Ensemble Sandbox, running since August 2024, was a controlled environment for experimental tokenised deposits. Balances there did not represent live customer claims in the way a settled interbank transfer does. Ensemble TX changes the stakes: the HKMA describes it as the commencement of the pilot phase, upgrading from proof-of-concept to a real-value setting where the tokens tested in the Sandbox are now used in actual transactions.

That distinction is easy to underplay. A sandbox failure is a lesson; a real-value settlement failure is a customer-facing incident with reconciliation, finality and, potentially, complaint-handling consequences. The initial design contains that exposure by keeping the pilot deliberately narrow. Only the banks named in the pilot provide tokenised deposits, the initial use case is bounded, and interbank settlement leans on the mature RTGS rail.

Ensemble TX is a collaborative pilot inside a defined participant group. The HKMA has invited stakeholders with innovative real-value use cases that leverage tokenised deposits to take part in the collaborative effort.

How a tokenised deposit differs from a stablecoin

A tokenised deposit is a claim on the issuing bank, recorded on a distributed ledger instead of only on the bank’s traditional core system. For an instrument that legally remains a bank deposit, the deposit-taking classification is preserved; the precise legal rights and mechanics still depend on the instrument’s terms and structure. That single point drives most of the regulatory treatment, and it is the point most commonly blurred in market commentary.

In Hong Kong, the HKMA has expressly described taking tokenised deposits as deposit-taking activity permissible under the Banking Ordinance, while the Stablecoins Ordinance excludes an instrument that constitutes a deposit under section 2(1) of the Banking Ordinance from the statutory definition of a stablecoin. The Annex A participants are described as commercial banks that will provide tokenised deposits to customers and settle the interbank leg in a real-value setting.

Because the instrument stays inside deposit-taking, it sits outside the Stablecoins Ordinance, which regulates the issuance of fiat-referenced stablecoins by licensed issuers. A bank issuing a tokenised deposit is exercising its banking licence; the stablecoin licence is a different track. Conflating the two is a genuine compliance risk: it would point a bank at the wrong authorisation, the wrong reserve rules and the wrong disclosure obligations. The cleaner mental model treats a tokenised deposit as commercial bank money in a new wrapper, a stablecoin as a privately issued instrument under its own licensing regime, and tokenised CeBM as the central bank money settlement asset the pilot is working toward.

Ensemble TX addresses the interbank-settlement dimension, initially through the HKD RTGS system and with planned support for tokenised central bank money.

The first use case: tokenised deposits meeting tokenised funds

The HKMA has set the initial focus on two linked activities: using tokenised deposits in tokenised money market fund transactions, and managing liquidity and treasury needs in real time. Annex B separately lists the Other Industry Pioneers participating in Ensemble TX, including BlackRock, Franklin Templeton, Hong Kong Exchanges and Clearing and JETCO, without assigning each participant a specific operational role.

Ensemble TX enables participating banks and market players to use tokenised deposits to settle tokenised assets in a real-value setting. Its initial focus includes tokenised money market fund transactions and real-time liquidity and treasury management, while interbank tokenised-deposit settlement is initially facilitated through the HKD RTGS system. For reporting teams, the relevant question is how the on-ledger record and the bank’s books of account stay reconciled at every step.

Tokenisation does not displace the underlying product requirements. Under the SFC’s revised 20 April 2026 circular, an SFC-authorised investment product must continue to meet the applicable product rules and codes, but the product provider must also satisfy tokenisation-specific safeguards covering ownership records, operational soundness, cybersecurity and recovery, smart-contract integrity, disclosure and staff competence. The SFC also requires prior consultation for new tokenised products and for tokenisation of existing authorised products, with prior approval required in specified cases; secondary trading is subject to the separate SFC circular of 20 April 2026. This mirrors the wholesale-settlement direction of travel elsewhere, such as the tokenised commercial bank money and central bank reserves used as settlement assets in the BIS-IIF Project Agorá, in which the Banque de France represents the Eurosystem.

Settlement rails: RTGS now, tokenised central bank money next

Ensemble TX settles the interbank leg of tokenised deposit transactions through the Hong Kong dollar RTGS system in its first stage. The HKMA has been explicit that the environment will be progressively enhanced to support settlement in tokenised CeBM on a 24/7 basis, so continuous settlement in central bank money is a planned upgrade, not a current feature.

That ordering deserves emphasis because it is the opposite of how these projects are often described. There is no live wholesale central bank digital currency settling Ensemble TX transactions today. The pilot deliberately anchors real-value settlement in the existing, proven RTGS while the tokenised central bank money leg is built out. Any statement that Hong Kong is settling tokenised deposits in a live wholesale CBDC would run ahead of the facts.

Keeping interbank settlement in central bank money is the design choice that preserves what central banks call the singleness of money. The Eurosystem has made the same argument in its own programme, using the Pontes and Appia initiatives to link DLT platforms to central bank money settlement. Hong Kong and the euro area are solving a shared problem from different starting points, and comparing the two is a fast way to see which parts of the Ensemble design are structural and which are specific to Hong Kong.

The reconciliation burden is where operational strain is most likely to show first. When a transaction spans DLT records and RTGS settlement, the institution should design reconciliation controls to provide complete and timely agreement between the relevant records. The HKMA’s DLT guidance is risk-based and technology-neutral; it does not prescribe a specific continuous reconciliation frequency for Ensemble TX.

Who is actually in the pilot

Ensemble TX names its participants, and the split between the two annexes is the operative distinction. Annex A lists the tokenised deposit banks, the institutions that will both provide tokenised deposits to customers and settle interbank tokenised deposit transactions: Bank of China (Hong Kong), China Construction Bank (Asia), Fubon Bank (Hong Kong), Fusion Bank, Standard Chartered Bank (Hong Kong), The Bank of East Asia, and The Hongkong and Shanghai Banking Corporation.

Annex B lists the ‘Other Industry Pioneers’. The HKMA annex names those participants but does not assign each a specific operational role. Annex A, by contrast, expressly defines its seven Tokenised Deposit Banks as the commercial banks that will provide tokenised deposits to customers in Hong Kong and settle interbank tokenised deposit transactions via Ensemble TX in a real-value setting.

For an institution outside both lists, the pilot is worth watching even without a near-term plan to tokenise deposits. The standards and settlement patterns this group settles on are likely to shape the HKMA’s later expectations for any wider rollout.

The regulatory perimeter the pilot sits inside

Ensemble TX runs inside Hong Kong’s existing frameworks. The preparation work for banks and digital-asset intermediaries is mostly a mapping exercise against rules that already exist.

For banks, the relevant expectations are the HKMA’s supervisory requirements for authorized institutions offering tokenised products and services, which build on the same prudential and conduct foundations as any other banking activity. Hong Kong’s banking supervision framework continues to apply in full, including the ongoing enhancements to the Banking Ordinance that shape how authorized institutions and their holding companies are regulated. A tokenised deposit that constitutes a deposit under the Banking Ordinance remains deposit-taking activity, but its prudential and reporting treatment must be mapped to the applicable HKMA requirements rather than assumed to be unchanged solely because the underlying claim is a deposit.

For SFC-regulated activities, the current tokenisation framework is not limited to the November 2023 circulars. The SFC’s 2 November 2023 circular on intermediaries engaging in tokenised securities-related activities remains relevant, but its 2 November 2023 circular on tokenisation of SFC-authorised investment products was superseded by a revised circular on 20 April 2026. The SFC also issued a separate circular on 20 April 2026 governing secondary trading of tokenised SFC-authorised investment products. Those current rules include tokenisation-specific safeguards and prior consultation, approval or notification requirements in specified cases. The VATP regime applies where the particular activity falls within that perimeter. Ensemble TX does not itself create a new licence category.

AML and financial-crime controls are the thread running through both. On-ledger settlement changes how transactions are recorded; it leaves transaction monitoring, sanctions screening and suspicious-transaction reporting fully in place. If anything, programmable settlement raises the bar on being able to trace a transaction end to end, because the audit trail now spans a ledger and a core banking system.

What banks and intermediaries should build now

The preparation list for a participating or prospective institution is less about new filings and more about controls that can survive a real-value incident. A few areas carry most of the weight.

Governance and ownership come first. Smart-contract logic that moves customer money needs the same review, testing and sign-off discipline as any other system that touches the general ledger, with clear accountability for who approves a contract before it settles a live transaction. Reconciliation is the second: a documented, testable process that proves the on-ledger position and the core-system position agree, designed from the outset for the continuous settlement the pilot is heading toward.

Custody and key management are the third, and they are where digital-asset intermediaries and banks converge. Control of a cryptographic key does not by itself determine legal ownership. Custody requirements therefore need to be mapped to the product’s ownership model and the applicable Hong Kong rules; comparative guidance elsewhere includes FINMA’s guidance on crypto custody and bankruptcy segregation in Switzerland. The Hong Kong specifics differ, but the control question is the same: can the institution demonstrate segregation, recoverability and clean bankruptcy treatment of tokenised positions.

The planned move to 24/7 tokenised-central-bank-money settlement means institutions should test incident response, business continuity and third-party dependency management for an environment that may not rely on a single overnight control window. In the current phase, Ensemble TX remains a controlled real-value pilot with interbank settlement initially facilitated through the HKD RTGS system.

No new return, but the existing reporting still runs

The Ensemble TX announcement does not specify an Ensemble TX-specific supervisory return or reporting frequency. For Category 1 institutions, however, MA(BS)1E includes memorandum items covering qualifying tokenised claims that meet the HKMA’s cryptoasset LCR treatment criteria in the applicable version of SPM module LM-1. MA(BS)26 similarly includes an item covering qualifying tokenised claims meeting those LM-1 Annex 3 criteria that are reported as available stable funding, with the applicable item designation and institution-scope to be confirmed against the current completion instructions. Reporting teams should therefore map tokenised deposits to their ordinary deposit and liquidity treatment and, where these Category 1 tokenised-claim items apply, to the relevant fields.

Frequently Asked Questions

Is a tokenised deposit in Ensemble TX the same thing as the e-HKD or a wholesale CBDC?

No. A tokenised deposit is commercial bank money, a claim on the issuing bank. Tokenised Central Bank Money is the settlement asset the pilot is working toward for the interbank leg, and it is a separate instrument issued by the HKMA. During the pilot’s first stage the interbank leg settles on the existing HKD RTGS system, so there is no live wholesale CBDC settling these transactions yet.

Does the Stablecoins Ordinance apply to a bank issuing tokenised deposits?

The Stablecoins Ordinance regulates the issuance of fiat-referenced stablecoins and requires those issuers to be licensed. A tokenised deposit issued by a bank under its banking licence is a different instrument and is not the subject of the stablecoin licensing regime. A bank should still confirm the classification of any specific instrument, because the label attached to a token does not determine its legal character.

Can any Hong Kong bank start issuing tokenised deposits because of Ensemble TX?

The pilot is limited to named participants. Only the seven Annex A banks are described as providing tokenised deposits to customers and settling the interbank leg during the pilot. A bank outside the pilot that wanted to offer tokenised deposits should assess its proposal against the Banking Ordinance and the applicable HKMA tokenised-product and DLT supervisory guidance rather than treating Ensemble TX as a general authorisation.

Do the asset managers and technology firms in Annex B need a new licence to take part?

Participation in the pilot does not create a new licence category. An Annex B firm is regulated according to what it actually does. For SFC-authorised investment products, the governing tokenisation framework now includes the revised 20 April 2026 product-tokenisation circular and, where secondary trading is involved, the separate 20 April 2026 secondary-trading circular, alongside the 2 November 2023 circular on intermediaries engaging in tokenised securities-related activities. The applicable prior-consultation, approval and notification requirements must be assessed for the specific activity.

Are tokenised deposits protected under the Deposit Protection Scheme?

Because a tokenised deposit is a deposit claim on the issuing bank, the starting point is the ordinary deposit-protection framework for that bank and that deposit type. Coverage depends on the specific product and depositor, so an institution should confirm the position for each tokenised-deposit product with the HKMA and the Hong Kong Deposit Protection Board before assuming it.

How does 24/7 settlement change reconciliation obligations?

A 24/7 settlement capability would require controls that do not depend solely on a single overnight batch. The HKMA has not prescribed an Ensemble TX reconciliation frequency or mandated intraday or event-driven reconciliation as a defined standard, so institutions should set the control frequency according to their architecture, risk assessment and applicable HKMA requirements.

Does on-ledger settlement change AML and suspicious-transaction reporting?

The AML/CFT obligations are unchanged in substance. Customer due diligence, ongoing monitoring, sanctions screening and suspicious-transaction reporting all still apply. The practical difference is that the transaction record now spans a distributed ledger and traditional systems, so the monitoring and audit trail have to cover both to remain complete.

Related Articles

• Hong Kong’s Stablecoins Ordinance and HKMA Issuer Licences: how the licensing regime for fiat-referenced stablecoin issuers works and why it is separate from tokenised deposits.
• Project Agorá: Tokenised Cross-Border Settlement: the BIS-IIF wholesale project using tokenised central bank reserves and commercial bank deposits as settlement assets.
• ECB Appia and Pontes: Tokenised Settlement Infrastructure: the Eurosystem’s route to settling tokenised assets in central bank money.
• HKMA D-SIB Designation 2025 and Higher Loss Absorbency Buffers: the prudential context for Hong Kong’s largest banks, several of which are in the Ensemble pilot.
• CARF and Crypto-Asset Tax Reporting: the OECD framework that sits alongside prudential and conduct rules for digital assets.

Key Takeaways

• Ensemble TX, the pilot phase of Project Ensemble, launched on 13 November 2025 and runs throughout 2026, moving tokenised-deposit settlement into real-value transactions.
• The interbank leg initially settles through the Hong Kong dollar RTGS system; the HKMA says the pilot environment will be progressively upgraded and enhanced to support 24/7 settlement in tokenised Central Bank Money, but the cited HKMA material does not give a specific go-live date for that capability.
• Only the seven Annex A banks are defined by the HKMA as Tokenised Deposit Banks that provide tokenised deposits to customers and settle interbank tokenised deposit transactions; Annex B separately lists Other Industry Pioneers, including BlackRock and Franklin Templeton, without assigning each firm a specific operational role.
• The initial use case is tokenised deposits settling tokenised money market fund transactions and real-time liquidity and treasury management.
• A tokenised deposit is a claim on the issuing bank and sits outside the Stablecoins Ordinance; classify each instrument before assuming which regime applies.
• Existing frameworks continue to govern the relevant activities: for banks, the Banking Ordinance and applicable HKMA tokenised-product and DLT guidance; for SFC-regulated tokenised investment products and intermediaries, the current SFC tokenisation framework including the revised 20 April 2026 product circular and the 20 April 2026 secondary-trading circular; and, where applicable, the VATP and AML/CFT regimes.
• Ensemble TX does not itself create a standalone supervisory return; for Category 1 institutions, MA(BS)1E and MA(BS)26 include memorandum items that collect qualifying tokenised-claim amounts under the applicable LCR and stable-funding criteria; reporting teams should map tokenised deposits to the ordinary deposit and liquidity treatment and, where these Category 1 items apply, to the relevant fields.
• Build reconciliation, smart-contract governance, custody and key management, and resilience controls now, designed for continuous settlement.

Sources and References

• HKMA, “HKMA announces the new phase of Project Ensemble to support real-value transactions in tokenised deposits and digital assets”, 13 November 2025: https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/11/20251113-3/
• HKMA, Ensemble TX Annex A (Tokenised Deposit Banks) and Annex B (Other Industry Pioneers), 13 November 2025: https://www.hkma.gov.hk/media/eng/doc/key-information/press-release/2025/20251113e3a1.pdf
• HKMA, “HKMA launches Project Ensemble Sandbox to accelerate adoption of tokenisation”, 28 August 2024: https://www.hkma.gov.hk/eng/news-and-media/press-releases/2024/08/20240828-3/
• HKMA, Central Bank Digital Currency (Project Ensemble and wholesale CBDC) overview: https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/fintech/central-bank-digital-currency/
• HKMA, Regulatory Regime for Stablecoin Issuers: https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/
• HKMA, “Implementation of regulatory regime for stablecoin issuers”, 29 July 2025: https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/07/20250729-4/
• HKMA, MA(BS)1E Completion Instructions: https://www.hkma.gov.hk/eng/key-functions/banking/banking-regulatory-and-supervisory-regime/regulatory-supervisory-framework/ma-bs-1e/
• HKMA, MA(BS)26 Return of Stable Funding Position: https://www.hkma.gov.hk/eng/key-functions/banking/banking-regulatory-and-supervisory-regime/regulatory-supervisory-framework/ma-bs-26/
• SFC, Virtual assets and tokenised securities regulatory requirements (Fintech Contact Point): https://www.sfc.hk/en/Welcome-to-the-Fintech-Contact-Point/Virtual-assets/Other-virtual-asset-related-activities/Regulatory-requirements
• SFC, Circular on tokenisation of SFC-authorised investment products (revised), 20 April 2026: https://apps.sfc.hk/edistributionWeb/gateway/EN/circular/doc?refNo=26EC22
• SFC, Circular on secondary trading of tokenised SFC-authorised investment products, 20 April 2026: https://apps.sfc.hk/edistributionWeb/gateway/EN/circular/doc?refNo=26EC23
• Cap. 656 Stablecoins Ordinance, section 3 (meaning of stablecoin): https://www.elegislation.gov.hk/hk/cap656!en/s3

Where Ensemble TX goes from here

The near-term calendar is short and specific. Ensemble TX runs through 2026 on the RTGS rail, the initial use case is tokenised deposits against tokenised money market funds, and the next visible milestone is the upgrade to 24/7 settlement in tokenised central bank money. For a participating bank, the deliverable this year is a reconciliation and controls model that treats on-ledger settlement as production. For an intermediary, it is a clean mapping of tokenised activity to the SFC and HKMA authorisations it already holds.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.