Stablecoins Ordinance (Hong Kong)

The Stablecoins Ordinance (Cap. 656) is a Hong Kong law that makes the issuing of fiat-referenced stablecoins a licensed activity supervised by the Hong Kong Monetary Authority (HKMA). It was passed by the Legislative Council on 21 May 2025 and came into operation on 1 August 2025.¹² It applies to issuers in Hong Kong and also to anyone who issues a coin outside Hong Kong that purports to be stable against the Hong Kong dollar. It limits who may offer such coins to the public, sets minimum capital, reserve and redemption rules, and bars licensees from paying interest on their coins.³ The HKMA granted the first two licences on 10 April 2026, to Anchorpoint Financial and HSBC.⁴ As of October 2026 both issuers had begun phased rollouts of Hong Kong dollar coins.⁵⁶

BackgroundReport an error

The HKMA published a discussion paper on crypto-assets and stablecoins in January 2022 and a summary of the feedback in January 2023, which proposed bringing certain stablecoin activities within the regulatory perimeter.⁷ In December 2023 the Financial Services and the Treasury Bureau (FSTB) and the HKMA issued a consultation paper proposing a licensing regime for issuers of fiat-referenced stablecoins. The paper proposed that only licensed issuers and specified licensed entities could offer such coins, that only coins licensed by the Monetary Authority could be offered to retail investors, and that unlicensed issuance could not be advertised. The consultation ran until 29 February 2024.⁸⁷

On 12 March 2024 the HKMA launched a stablecoin issuer sandbox, to tell interested firms what supervisors expected and to collect feedback on the proposals.⁹ On 18 July 2024 it named the first participants: JINGDONG Coinlink Technology Hong Kong, RD InnoTech, and a group made up of Standard Chartered Bank (Hong Kong), Animoca Brands and Hong Kong Telecommunications (HKT). The HKMA said participants would not handle public funds at the initial stage.¹⁰

The consultation conclusions followed on 17 July 2024. The FSTB and the HKMA reported 108 submissions, and said a vast majority of respondents agreed a regime should be introduced.¹¹

Legislative historyReport an error

The Stablecoins Bill was submitted to the Legislative Council for first reading on 18 December 2024.¹² The Legislative Council passed it on 21 May 2025, and the Government said the Ordinance was expected to take effect that year to give the industry time to understand the licensing requirements.² The Ordinance was gazetted on 30 May 2025. On 6 June 2025 the Government gazetted a notice appointing 1 August 2025 as the commencement date, as section 1(2) of the Ordinance left the date to the Secretary for Financial Services and the Treasury.¹

ProvisionsReport an error

What a stablecoin is

The Ordinance defines a stablecoin as a cryptographically secured digital representation of value that is used or intended to be used as a medium of exchange accepted by the public (for payment, discharging a debt or investment), operates on a distributed ledger, and purports to keep a stable value against a single asset or a basket of assets. It excludes, among other things, tokens issued by central banks or governments, securities and futures contracts, stored value facility deposits, and bank deposits.³

A "specified stablecoin" is one that purports to keep a stable value wholly against official currencies, or against units of account or stores of value that the Monetary Authority specifies by gazetted notice, or a combination of these. The Monetary Authority can also specify further classes of digital representation of value.³ The HKMA describes the resulting regime as covering the issuance of fiat-referenced stablecoins.⁷

Who needs a licence

A person carries on a regulated stablecoin activity if they issue a specified stablecoin in Hong Kong in the course of business. The same applies to a person who issues a specified stablecoin outside Hong Kong that purports to keep a stable value, wholly or partly, against the Hong Kong dollar. The Monetary Authority may, after consulting the Financial Secretary, specify further activities by gazetted notice.³ Section 5 of the Ordinance also treats a person as holding out as carrying on a regulated activity if they actively market it to the public, in Hong Kong or elsewhere.³

Applicants must be a company or an authorised institution incorporated outside Hong Kong. The Monetary Authority may grant a licence only if satisfied that the minimum criteria in Schedule 2 would be met, and may attach conditions.³

Who may offer stablecoins

Section 9 makes it an offence to offer a specified stablecoin, or hold oneself out as offering one, unless an exemption applies. The main exemption covers a "permitted offeror" where the issue of the coin is authorised by a licence. Permitted offerors are licensees, virtual asset service licensees, stored value facility licensees, corporations licensed for Type 1 (dealing in securities) regulated activity, and authorised institutions.³ A second exemption allows permitted offerors to offer coins that are not licensed to a class of persons specified by the Financial Secretary. On 6 June 2025 the Financial Secretary specified professional investors for this purpose.³¹ The Government stated that only coins issued by a licensed issuer may be offered to retail investors.²

Advertising is also restricted. Publishing an advertisement in which an unlicensed person holds themselves out as carrying on a regulated activity is an offence, as is advertising the offering of a coin that does not fall under the exemptions above.³ The Government said that, to prevent fraud, only advertisements for licensed issuance are allowed at all times, including during the transitional period.²

Minimum criteria for licensees

Schedule 2 of the Ordinance sets the minimum criteria that licensees must meet.³

• Capital. A licensee that is not an authorised institution must have adequate financial resources and liquid assets, and paid-up share capital of at least HK$25 million or other approved financial resources of an equivalent amount.
• Reserves. For each type of coin, the licensee must hold a segregated pool of reserve assets whose market value is at all times at least equal to the par value of coins in circulation. The pool must generally be held in the same reference asset as the coin, must be protected against the licensee's other creditors, and must consist of high quality, highly liquid assets with minimal investment risk. Reserves must be subject to regular independent attestation and audit.
• Redemption. Holders must have a right to redeem. Unless the Monetary Authority consents otherwise, a valid request must be honoured as soon as practicable at par value in the reference asset, less any reasonable fee, and redemption conditions must not be unduly burdensome. If the licensee becomes insolvent, holders have a right to direct disposal of the reserve pool to redeem coins pro rata, and a claim against the licensee for any shortfall.
• Disclosure. Licensees must disclose their reserve management policy, risk assessments, and the composition, market value and audit or attestation results of reserves, and must set out redemption rights, fees and processing times. They must publish a white paper for each type of coin and give holders access to complaint handling and redress.
• Interest. A licensee must not pay, or permit anyone to pay, interest on its coins, defined as any return represented to arise from holding the coin by reference to the holding period, par value or market value.
• Other. Licensees must apply anti-money laundering and counter-terrorist financing controls, meet fit-and-proper requirements for their chief executive, directors and controllers, maintain risk management and recovery and orderly wind-down plans, and obtain the Monetary Authority's consent before carrying on other business activities.

Penalties

Carrying on a regulated stablecoin activity without a licence, or offering a specified stablecoin outside the exemptions, is punishable on summary conviction by a fine of HK$500,000 and two years' imprisonment, with a further daily fine for a continuing offence. On conviction on indictment the penalty is a fine of HK$5 million and seven years' imprisonment.³ Fraud or deception in a transaction involving a specified stablecoin carries up to HK$10 million and ten years' imprisonment on indictment, and the court may bar the offender from dealing in stablecoins in Hong Kong for up to five years.³ Unlawful advertising carries a fine at level 5 and six months' imprisonment.³

Transitional arrangements

Schedule 7 allowed firms already carrying on a regulated activity in Hong Kong before 1 August 2025 to continue for the first three months. If such a firm applied within those three months, the Monetary Authority acknowledged the application and the firm gave a declaration and an undertaking to comply as if licensed, it could continue for the first six months. The Monetary Authority could grant a provisional licence within that period if it was satisfied the firm had a reasonable prospect of showing it could meet the requirements, or give a rejection notice that the firm could object to.³ The HKMA published an explanatory note on the transitional provisions for pre-existing issuers on 29 July 2025.¹³ The HKMA stated that, on that date, no licence had been issued.¹³

HKMA guidelines

On 29 July 2025 the HKMA published finalised guidelines on the supervision of licensed stablecoin issuers and on anti-money laundering and counter-financing of terrorism for licensed stablecoin issuers, together with consultation conclusions on each and an explanatory note on licensing. The guidelines were published in the Gazette on 1 August 2025.¹³ The HKMA says they set out its regulatory expectations for licensed issuers.⁷ The HKMA asked interested applicants to contact it by 31 August 2025 and said those wishing to be considered early should apply by 30 September 2025.¹³

ImplementationReport an error

Licensing

The HKMA said it received applications from 36 entities in the first batch, by the 30 September 2025 deadline. It granted licences on 10 April 2026 to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, saying it had focused on applicants' risk management capability and on whether they could propose distinct use cases with viable business plans.¹⁴ The licences took effect that day.⁴ Anchorpoint is a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands.¹⁵ The register of licensed issuers lists them as licences FRS01 and FRS02; the version this article read was last revised on 23 April 2026.¹⁶

The HKMA said in April 2026 that it would continue to engage the remaining applicants and that its stance on further licences was "open yet prudent", with no definitive inclination at that stage.¹⁴ This article found no report of a further licence granted by 31 October 2026.

Earlier, in July 2025, Eddie Yue, the HKMA's chief executive, said the market needed to "further rein in the euphoria" and that few licences would be granted initially, so most applicants would be disappointed.¹⁷ In August 2025 he said the HKMA had been in preliminary communication with dozens of parties, and that only a handful of licences would be granted initially.¹⁸

Launches

Anchorpoint began a phased rollout of HKDAP, a Hong Kong dollar stablecoin, on 12 August 2026. The Block reported that access was through beta access for institutional distributors and professional investors, and that HashKey Exchange completed the first minting and redemption.⁵ This article did not find a retail launch date for HKDAP.

HSBC said when it received its licence that it planned to launch a Hong Kong dollar stablecoin in the second half of 2026, through its PayMe and HSBC HK mobile banking apps, for peer-to-peer and merchant payments, with tokenised investment subscriptions through the app.¹⁹ On 28 April 2026 the HKMA warned of tokens named "HKDAP" and "HSBC" circulating in the market with no connection to the licensees, and HSBC denied any involvement.²⁰ On 30 September 2026 HSBC named its coin RedCoin.²¹ Decrypt reported that RedCoin (RCHKD) was activated inside PayMe on Friday 23 October 2026, with more than 3.3 million PayMe users able to activate wallets in the following days. The report said it ran on HSBC's own private ledger, was not a bank deposit and was not covered by the Deposit Protection Scheme. HSBC's reserve tracker showed at the time about US$10.2 million in circulation against US$10.4 million of cash reserves, and HSBC expected the first independent reserve attestation after the fourth quarter of 2026.⁶ The Paypers dated its report 27 October 2026 and said access was phased.²² As of October 2026, an analyst note on investinglive.com said the coin could only be used inside HSBC's own apps.²³

Mainland China and offshore yuan coinsReport an error

Mainland authorities have reportedly shaped who applies. In October 2025 the Financial Times reported, citing unnamed sources, that the People's Bank of China and the Cyberspace Administration of China had told Ant Group and JD.com not to go ahead with plans to issue yuan-pegged stablecoins in Hong Kong. The Block's summary reported that five sources said officials objected to private companies issuing any form of currency, and that one said such coins could challenge the digital yuan. The Block reported that neither firm nor the regulators had publicly confirmed the instruction in the pieces it summarised.²⁴²⁵ Decrypt reported that Ant Group and JD.com had not responded to its request for comment, and that the regulators' guidance was reported only through the FT.²⁵ The Block, citing the FT, also reported that the HKMA had said in September 2025 that 77 firms, including Ant and JD.com, had expressed interest in a licence.²⁴ JD's Hong Kong unit, JINGDONG Coinlink, had been a sandbox participant in 2024.¹⁰

On 3 October 2025, after reports that a Hong Kong firm, AnchorX, had issued the first offshore yuan stablecoin, the HKMA stated that no licences had been granted to any stablecoin issuer and urged the public to be cautious about such projects.²⁶ The Ordinance covers any specified stablecoin issued in Hong Kong in the course of business, which would include one referencing the yuan.³ As of 31 October 2026 this article found no HKMA licence for a yuan-referenced coin, as the register this article read listed only the two April 2026 licensees.¹⁶

Criticism and warningsReport an error

Speculation

On 14 August 2025 the HKMA and the Securities and Futures Commission (SFC) issued a joint statement on abrupt share price movements linked to the stablecoin concept after announcements, news reports and social media posts about plans to apply for licences. They urged the public not to make investment decisions on market hype, reminded market participants not to make misleading statements, and said the SFC would act against manipulation. Yue said the HKMA had a "rigorous and prudent approach" and that approval thresholds were high.¹⁸ In July 2025, Yue had warned of a risk of bubbles, observing that some listed companies' shares jumped after merely announcing stablecoin plans.²⁷

The HKMA warned the public against scams from the start. When the sandbox participants were named in July 2024 it advised vigilance against scams purporting to be related to the sandbox, and in April 2026 it warned that fake tokens were using the licensees' names.¹⁰²⁰

Narrow licensing and limited use

The HKMA has said it would grant only a handful of licences at first.¹⁸ An analyst note on RedCoin's launch said the coin risked being a closed system that adds little to existing PayMe balances.²³

TimelineReport an error

See alsoReport an error

• Stablecoin, the general article and list of stablecoins
• GENIUS Act, the United States federal stablecoin law
• MiCA, the European Union's crypto-asset regulation
• Payment Services Act (Japan)

ReferencesReport an error