Hong Kong Stablecoins Ordinance: HKMA Grants the First Issuer Licences

On 10 April 2026 the Hong Kong Monetary Authority granted the territory’s first two stablecoin issuer licences, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. Both licences took effect that day under the Hong Kong Stablecoins Ordinance, the statute that has regulated fiat-referenced stablecoins since it came into operation on 1 August 2025.

The announcement moves the regime from paper to practice. The licensing perimeter covers a person that, in the course of business, issues a specified stablecoin in Hong Kong or issues outside Hong Kong a specified stablecoin that purports to maintain a stable value wholly or partly by reference to the Hong Kong dollar. Licensed issuers are then subject to reserve, redemption, disclosure, governance and supervisory requirements. For a bank or fintech that treated the Ordinance as a future problem, the two licences are the signal that the supervisor is now authorising, supervising and expecting returns.

For global banks with Hong Kong operations the choice has narrowed to three practical routes: apply for a licence, partner with a licensed issuer, or stay out of Hong Kong dollar stablecoin issuance entirely. HSBC took the first route. The rest of the market now has two live reference points for what an authorised issuer looks like.

Related reading: Stablecoin reporting obligations under MiCAR, the EMT rules and PSD3.

The dates that anchor the regime

The Hong Kong stablecoin framework has a short, dense timeline. Reporting and legal teams building a compliance position should anchor their planning to these fixed points early.

• 21 May 2025: the Legislative Council passed the Stablecoins Ordinance.
• 1 August 2025: the Ordinance (Cap. 656) came into operation and the licensing regime went live.
• End of September 2025: the HKMA had received a reported 36 formal licence applications.
• 10 April 2026: the HKMA granted the first two issuer licences, effective the same day, to Anchorpoint Financial Limited and HSBC.
• 2026 launch plans: the HKMA said both licensees intended to complete preparations and launch business in the coming months. Anchorpoint targeted phased HKDAP issuance from the second quarter of 2026, while HSBC stated that it planned to launch its Hong Kong dollar stablecoin in the second half of 2026.

The gap between 1 August 2025 and 10 April 2026 matters. It shows that authorisation under this regime is not a registration formality. Applicants spent months in assessment before a single licence was granted, and the HKMA has been open that the first batch was deliberately small.

How the Hong Kong Stablecoins Ordinance defines who needs a licence

The Ordinance regulates a specific object: the fiat-referenced stablecoin, often shortened to FRS. That is a cryptographically protected digital token that purports to hold a stable value by reference to one or more official currencies. A licence from the Monetary Authority is required where a person issues a specified stablecoin in Hong Kong in the course of business or issues outside Hong Kong in the course of business a specified stablecoin that purports to maintain a stable value wholly or partly by reference to the Hong Kong dollar.

The second limb is the one that catches offshore structures. A firm incorporated elsewhere that mints an HKD-referenced token for a global user base is inside the Hong Kong perimeter even if it never touches a Hong Kong customer directly. The regime also reaches conduct short of issuance. A person may be treated as holding itself out as carrying on a regulated stablecoin activity, or as offering a specified stablecoin, where it actively markets to the public that it carries on or purports to carry on an activity that would constitute the relevant regulated activity or offering if carried on in Hong Kong. Sections 8 to 10 then determine whether the activity, offer or advertisement is prohibited or permitted.

A common misreading is to treat the Ordinance as a general crypto law. It is narrower than that. Tokens that are not specified stablecoins fall outside this issuer-licensing perimeter. However, the statutory definition does not exclude a fiat-referenced token merely because it uses an algorithmic stabilisation mechanism. A token that otherwise satisfies the stablecoin definition and purports to maintain a stable value wholly by reference to one or more official currencies may still be a specified stablecoin. Scope precision is the first thing a token issuer should settle, because it decides whether the HKMA is the supervisor at all.

The first two licensees, and what they signal

The first two names tell you what the HKMA wanted to see. HSBC, one of Hong Kong’s note-issuing banks, was licensed directly. Anchorpoint Financial Limited is a subsidiary of Standard Chartered Bank (Hong Kong) Limited and a joint venture the bank established with HKT and Animoca Brands in February 2025, building a regulated Hong Kong dollar stablecoin branded HKDAP. Both are bank-anchored propositions with deep balance sheets and existing supervisory relationships.

The HKMA received 36 applications during the initial application period and granted two licences after its review. In June 2026, the Government said remaining applications would be assessed against consistent and stringent standards, including practical and feasible use cases, a robust and sustainable operating model with appropriate risk-management capability and experience, and compliance with Hong Kong and other relevant laws. The small first cohort is consistent with a selective approach, but the number of licences alone does not establish which criterion determined each decision.

One operational trap surfaced within weeks. On 28 April 2026 Anchorpoint issued a public notice that, despite holding its licence since 10 April, it had not yet officially issued any regulated stablecoin under the HKDAP name, and warned that tokens claiming to be HKDAP were not genuine. A licence is not evidence that a stablecoin product has launched. The HKMA register verifies the identity and status of licensed issuers; it does not by itself establish that a particular token has been issued. Product-launch status should be checked against the HKMA’s notices and the licensed issuer’s official announcements.

Reserve backing and redemption sit at the core of the obligation

The economic promise of a regulated stablecoin is that one token can always be turned back into one unit of the referenced currency. The Ordinance turns that promise into supervised requirements. A licensee has to hold reserve assets whose market value is at all times at least equal to the par value of the stablecoins it has in circulation. Those assets must be high quality and highly liquid and must be segregated from the issuer’s other assets and reserve pools. Except with the Monetary Authority’s prior written approval, each reserve pool must be held in the same reference asset as the stablecoin it backs.

Redemption is the other side of the same coin. Holders are entitled to redeem at par value in the referenced asset, subject only to reasonable fees, and the HKMA expects requests to be met promptly. The Ordinance requires a licensee, except with the Monetary Authority’s prior written consent, to honour a valid redemption request as soon as practicable at par in the relevant reference asset. The precise operational processing period must be confirmed against the current HKMA supervisory guideline and any applicable licence condition. A licensee must not attach a condition restricting redemption that is unduly burdensome in the circumstances, and it cannot treat the reserve as a general funding pool.

The frequent mistake here is to read the backing rule as an approximation, as if the reserve only needs to sit close to par on average or at a month-end date. The rule is stricter: market value has to be at least equal to par at all times, which is why the real work lands in continuous reconciliation between tokens in circulation and reserve value, well beyond the white paper that describes it.

What a licensed issuer actually has to file

For a reporting desk, the licence is the start of an ongoing supervisory relationship, not the end of the project. The Ordinance requires the reserve’s market value to be at least equal to the par value of outstanding stablecoins at all times. It also requires controls for regular independent attestation and audit and adequate and timely public disclosure of the reserve-management policy, reserve risks, composition, market value and attestation and audit results. The exact HKMA submission frequency must be taken from the current supervisory guideline and applicable licence conditions.

For each type of specified stablecoin it issues, a licensee must publish a white paper providing comprehensive and transparent information about that type of stablecoin. Separately, it must disclose applicable redemption rights, provide holders with information about its complaint-handling and redress mechanisms, and maintain policies for identifying, managing and disclosing conflicts of interest. The precise contents and updating requirements for the white paper should be confirmed against the current HKMA supervisory guideline.

Our guide to stablecoin reporting obligations across MiCAR and the EU e-money token rules shows how similar the underlying data set is across regimes: circulation figures, reserve composition, redemption activity and attestation results. A group operating in both Hong Kong and the European Union will be assembling many of the same numbers for two supervisors on two calendars, which is an argument for a single reserve-reporting data model instead of two parallel builds.

Capital, governance and the fit-and-proper test

The Ordinance also sets structural entry conditions. A non-bank licensee has to hold a minimum of HK$25 million in paid-up share capital, or an equivalent amount of financial resources acceptable to the HKMA, and maintain financial resources on an ongoing basis for the life of the licence. The capital floor is a screen against thinly funded issuers, and it is one reason the early market has tilted towards bank-backed applicants.

Governance requirements go to people as well as money. The chief executive, alternate chief executive and stablecoin manager require the Monetary Authority’s consent and must be ordinarily resident in Hong Kong. Directors also generally require the Monetary Authority’s consent, while controllers are subject to the statutory consent and objection regime. The chief executive, directors, stablecoin manager and controllers must be fit and proper; other managers are subject to fit-and-proper controls, and officers responsible for day-to-day stablecoin operations must have appropriate knowledge and experience. Anyone seeking to become a controller by acquiring a threshold stake needs the HKMA’s consent before doing so. For a global group, that means the Hong Kong issuing entity cannot be run as a remote booking vehicle; it needs real local substance and named, approved accountable individuals.

These minimum criteria must continue to be met while the licence remains in force. Changes involving consented senior roles or controllers can trigger consent or notification requirements. A licensee must immediately report if it is likely to become unable to meet its obligations, is insolvent or is about to suspend payment; not every change in financial position is automatically reportable on that basis.

Who may offer a stablecoin to the Hong Kong public

Issuance is only one regulated activity. The Ordinance also controls who may offer stablecoins to the public in Hong Kong, and this is where distributors, exchanges and marketing teams get caught even when they are not issuers. Only a permitted offeror may offer a specified stablecoin. The five statutory categories are a licensed stablecoin issuer, a licensed virtual asset trading platform, a stored value facility licensee, an SFC-licensed corporation authorised for Type 1 regulated activity and an authorised institution. A permitted offeror may offer a stablecoin whose issuance is authorised by an HKMA licence to retail or professional investors. A stablecoin whose issuance is not authorised by such a licence may be offered only by a permitted offeror, only where its issuance is not prohibited by section 8, and only to professional investors or another class specified under section 9.

Advertising and holding-out activities are also regulated. A person may be treated as holding itself out as carrying on a regulated stablecoin activity where it actively markets to the Hong Kong public, whether from Hong Kong or elsewhere, that it carries on or purports to carry on an activity that would be regulated if conducted in Hong Kong. Separate restrictions apply to advertisements for unlicensed regulated activities and non-permitted offers. The Ordinance should therefore be tested against the actual communication, audience and activity rather than relying on a general reverse-solicitation label.

The Hong Kong perimeter is stricter on retail distribution than many first assume, a deliberate contrast with regimes that regulate the issuer and leave distribution largely to general conduct rules.

How the regime compares with MiCAR and the UK approach

Global banks rarely assess Hong Kong in isolation. The Stablecoins Ordinance lands in a field where the European Union’s Markets in Crypto-Assets Regulation already runs a full authorisation and reserve regime for e-money tokens and asset-referenced tokens, and where the United Kingdom is standing up its own rules for issuers. The shared architecture is familiar: regulate the issuer, impose reserve or safeguarding requirements, provide holder redemption rights, and require ongoing disclosure and reporting. The calibration differs: MiCAR e-money tokens are redeemable at par, whereas asset-referenced tokens are redeemed for funds equivalent to the market value of the referenced assets or by delivery of those assets.

The differences sit in the detail that reporting teams actually operate. Our summary of the EBA statement on asset-referenced and e-money tokens sets out the MiCAR own-funds and reserve tests, and our explainer on the Bank of England systemic stablecoin rules covers how a systemic UK issuer is treated. The classification question, in particular, does not map one to one: MiCAR splits single-currency e-money tokens from asset-referenced tokens, whereas the Hong Kong regime works from a single fiat-referenced stablecoin concept. A token that is a straightforward e-money token in the EU still has to be re-tested against the Hong Kong definition and never assumed equivalent, a point our MiCAR token classification guide develops for the European side.

What this means for global banks with Hong Kong operations

The immediate consequence is that a Hong Kong dollar stablecoin is now a regulated product with a named supervisor and a queue of applicants. A group deciding whether to enter should treat the licence as a multi-quarter programme covering capital, local substance, reserve custody, an auditable reserve-reporting pipeline and anti-money-laundering controls, since stablecoin issuers are treated as financial institutions under Hong Kong’s Anti-Money Laundering and Counter-Terrorist Financing Ordinance and carry customer due diligence and monitoring duties accordingly. The FATF work on stablecoins and unhosted wallets is a useful reference for how those AML expectations are framed internationally.

For groups that will not issue, the exposure runs through distribution and correspondent relationships. A bank or intermediary that lists, distributes or provides services connected with a stablecoin should verify the issuer’s licensing status and assess its own obligations under the offering, conduct and AML/CFT regimes applicable to that bank or intermediary. A stablecoin issuer’s classification as a financial institution under the AMLO does not by itself place every service provider or counterparty within the same regulatory perimeter. Tax and information-reporting teams should also note that stablecoin activity can feed the emerging crypto-asset reporting frameworks; our overview of CARF crypto-asset tax reporting covers where those obligations are heading.

Frequently Asked Questions

Does the Hong Kong Stablecoins Ordinance cover every kind of crypto token?

No. It regulates specified stablecoins, including stablecoins that purport to maintain a stable value wholly by reference to one or more official currencies. The statutory definition does not depend on the token using reserves. Tokens that are not specified stablecoins fall outside this licensing regime. An algorithmic mechanism does not by itself remove a token from scope: a token that otherwise satisfies the stablecoin definition and purports to maintain a stable value wholly by reference to one or more official currencies may still be a specified stablecoin.

Do the licences granted on 10 April 2026 mean HKDAP and an HSBC stablecoin are already available?

Not automatically. A licence authorises the issuer; it does not mean a product is live. Anchorpoint stated on 28 April 2026 that it had not yet officially issued HKDAP and warned about tokens falsely claiming to be HKDAP. The HKMA register is the reference point for verifying licensed issuers. Whether a particular stablecoin has actually been launched should be checked against the HKMA’s notices and the issuer’s official announcements.

Can a stablecoin issuer incorporated outside Hong Kong avoid the regime?

An offshore structure does not avoid the regime where it issues outside Hong Kong, in the course of business, a specified stablecoin that purports to maintain a stable value wholly or partly by reference to the Hong Kong dollar. Issuance in Hong Kong, offering and holding-out activities must also be tested separately.

What does full reserve backing require in practice?

The market value of the reserve has to be at least equal to the par value of the stablecoins in circulation at all times, using high quality and highly liquid assets held in segregation. The obligation is continuous and holds at all times; an average or a period-end snapshot does not satisfy it, which is why daily reconciliation of circulation against reserve value is central to compliance.

Who is allowed to sell a stablecoin to retail customers in Hong Kong?

The five permitted-offeror categories are licensed stablecoin issuers, licensed virtual asset trading platforms, stored value facility licensees, SFC Type 1 licensed corporations and authorised institutions. These persons may offer an HKMA-regulated stablecoin to retail or professional investors. A stablecoin whose issuance is not authorised by an HKMA licence may be offered only by a permitted offeror, only where section 8 does not prohibit its issuance, and only to professional investors or another class specified under section 9.

How does the Hong Kong regime line up with MiCAR for a group operating in both?

The core architecture is similar, covering issuer regulation, reserve or safeguarding requirements, holder redemption rights and ongoing reporting, but the calibration differs. MiCAR e-money tokens are redeemable at par; asset-referenced tokens are redeemed for funds equivalent to the market value of the referenced assets or by delivery of those assets. The classification and calibration differ, so a token treated as an e-money token in the EU still has to be re-assessed against Hong Kong’s fiat-referenced stablecoin definition and cannot be assumed equivalent.

What ongoing reporting does a licensed issuer face?

A licensee must maintain full reserve backing at all times, arrange regular independent attestation and audit, and make adequate and timely public reserve disclosures. The current HKMA supervisory guideline and applicable licence conditions determine the detailed preparation, submission and publication cadence.

Related Articles

• Stablecoin Reporting Obligations under MiCAR, EMT and PSD3: how EU stablecoin issuers report reserves, circulation and redemptions across the crypto and payments frameworks.
• Bank of England Systemic Stablecoin Rules for UK Issuers: the UK approach to systemic stablecoin issuers and the reporting that comes with it.
• EBA Statement on ARTs and EMTs: the own-funds, reserve and redemption tests for EU asset-referenced and e-money tokens.
• MiCAR Token Classification and Reporting Obligations: how to classify a token under MiCAR before mapping its reporting duties.
• FATF on Stablecoins and Unhosted Wallets: the international AML and CFT expectations that shape stablecoin supervision.

Key Takeaways

• The HKMA granted Hong Kong’s first two stablecoin issuer licences on 10 April 2026, to Anchorpoint Financial Limited and HSBC, effective that day under the Stablecoins Ordinance (Cap. 656, in force since 1 August 2025).
• A licence is required where a person, in the course of business, issues a specified stablecoin in Hong Kong or issues outside Hong Kong a specified stablecoin that purports to maintain a stable value wholly or partly by reference to the Hong Kong dollar.
• Reserve assets have to be at least equal to par value at all times, high quality, highly liquid and segregated, with redemption at par and prompt processing.
• Licensees require an auditable reserve-reporting process capable of demonstrating full backing at all times, supporting regular independent attestation and audit, meeting public-disclosure duties and producing any returns required by the current HKMA supervisory guideline or licence conditions.
• Non-bank issuers need at least HK$25 million in paid-up share capital or equivalent financial resources acceptable to the HKMA. The chief executive, alternate chief executive and stablecoin manager must be ordinarily resident in Hong Kong and require the Monetary Authority’s consent; directors generally require consent, while controllers are subject to the statutory consent and objection regime.
• Only the five statutory categories of permitted offeror may offer specified stablecoins: licensed stablecoin issuers, licensed virtual asset trading platforms, stored value facility licensees, SFC Type 1 licensed corporations and authorised institutions. HKMA-regulated stablecoins may be offered to retail or professional investors; other stablecoins may be offered only by permitted offerors and only to professional investors where the section 9 conditions are met.
• A licence authorises an issuer but does not mean a product is live. Counterparties should use the HKMA register to verify the issuer and check HKMA notices and the issuer’s official announcements to confirm whether a particular stablecoin has launched.

Sources and References

• Hong Kong Monetary Authority, press release “Granting of stablecoin issuer licences”, 10 April 2026: hkma.gov.hk
• Hong Kong Monetary Authority, Regulatory Regime for Stablecoin Issuers (including the Register of Licensed Stablecoin Issuers): hkma.gov.hk
• Hong Kong Monetary Authority, Explanatory Note on Licensing of Stablecoin Issuers (PDF): hkma.gov.hk
• Stablecoins Ordinance (Cap. 656), Hong Kong e-Legislation: elegislation.gov.hk
• Anchorpoint Financial Limited, press release “Anchorpoint alerts the public of tokens purported to be HKDAP”, 28 April 2026: av.sc.com
• Morgan Lewis, “Hong Kong’s Stablecoins Ordinance to Take Effect August 1: An Overview of the Regulatory Framework”, June 2025: morganlewis.com
• Central Banking, “HKMA awards Hong Kong’s first stablecoin licences”, April 2026: centralbanking.com

Where Hong Kong’s stablecoin regime goes from here

Two licences do not make a market, but they set the template. The HKMA has shown it will authorise slowly, favour reserve quality and bank-grade risk management, and expect a continuing reporting relationship once tokens are outstanding. The next questions are how quickly HKDAP and an HSBC stablecoin reach circulation, whether the second cohort of applicants is any wider than the first, and how the HKMA’s supervisory returns settle into a fixed cadence once tokens are actually in issue. For issuers and for the banks that will bank, list and distribute them, the practical work now is building the reserve reconciliation, attestation and disclosure machinery that the licence assumes is already running.

Last updated: July 2026

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.