ASPIRe to deliver: SFC’s crypto roadmap review and next regulatory milestones

While many jurisdictions continue to debate the boundaries of virtual asset ("VA") regulation, Hong Kong has taken a different path – establishing comprehensive regulatory perimeters and incrementally expanding it through defined licensing regimes and product frameworks.

This approach is guided by the Securities and Futures Commission's ("SFC") principle of "same business, same risks, same rules", under which VA activities are regulated consistently with their traditional financial counterparts, subject to adaptations addressing the specific technological and operational risks of VAs. The result is a regime that closely mirrors traditional financial regulation in structure, while remaining tailored to the realities of VAs.

The momentum behind this approach has accelerated markedly over the past year. Since the publication in February 2025 of "A-S-P-I-Re" for a brighter future: the SFC’s regulatory roadmap for Hong Kong’s virtual asset market (the "ASPIRe Roadmap"), Hong Kong regulators have delivered a substantial body of concrete regulatory measures spanning licensing, custody, market access and product offerings. Structured around five pillars — Access (A), Safeguards (S), Products (P), Infrastructure (I) and Relationships (Re) — the ASPIRe Roadmap has evolved from a policy blueprint into an execution-driven framework that is reshaping how VA activities are conducted in Hong Kong. Against this backdrop, this article highlights the key developments under the ASPIRe Roadmap since its publication 15 months ago.

Pillar A – Access: building the licensing and liquidity rails

When the ASPIRe Roadmap was published in February 2025, the regulatory perimeter captured only securities and futures intermediaries and SFC-licensed Virtual Asset Trading Platforms ("VATPs"), and did not extend to non-VATP service providers. 

Under Pillar A, the SFC has since moved in four directions to broaden market access. The first two involve licensing regimes for VA service providers ("VASPs") and VA custodians, which are the subject of parallel consultations by the Financial Services and the Treasury Bureau ("FSTB") and the SFC in December 2025. Under the VASP umbrella, VA dealing, VA advisory and VA management services will each be subject to a separate licensing regime, forming a three-regime architecture that closely mirrors the Type 1, Type 4 and Type 9 licences for conventional securities under the Securities and Futures Ordinance (Cap. 571). 

For VA custodian businesses, third-party VA custodian service providers currently rely on the Trust or Company Service Provider ("TCSP") licences, which are not designed for the specific risks associated with holding VAs.  The new regime is focused on the safekeeping of client VA private keys in Hong Kong and will hold custodians to standards broadly comparable to traditional financial custodians. 

Together, the proposed VASP and VA custodian regimes enhance the statutory regime on which the broader ASPIRe initiatives can be implemented. A licensed custodian regime provides a sustainable foundation for activities such as staking, stablecoins and tokenisation, while the new VASP licensing frameworks enable stakeholders to offer VA services beyond the VATP perimeter. The FSTB and the SFC expect to introduce a bill implementing these regimes under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) in 2026.

The third aspect of Pillar A is aimed at market connectivity and liquidity, under which the SFC opened two new liquidity channels for licensed VATPs as follows:

• Shared order book – on 3 November 2025, the SFC introduced a framework allowing VATP operators to combine their orders with those of global affiliate VATP operators ("OVATPs") into an aggregate shared liquidity pool, enabling order matching and execution across platforms ("Shared Order Book"). This integration is subject to strict conditions: only fully pre-funded orders may be accepted, settlement must occur on a delivery-versus-payment basis, and the Hong Kong VATP must maintain a local reserve fund held on trust for client compensation. Any launch of a Shared Order Book remains subject to prior SFC approval.
• Affiliated market makers — on 11 February 2026, the SFC relaxes its prohibition on affiliated market makers by easing the VATP Guidelines. Licensed VATPs may now engage group-affiliated market makers, provided that functional independence is maintained and robust conflict-of-interest controls are in place, including Responsible Officer or Manager-in-Charge oversight, effective information barriers and client order priority at the same price level.

The fourth aspect relating to intermediary access occurred in February 2026, when the SFC opened the Shared Order Book to VA brokers, being licensed corporations already provide VA dealing services under omnibus account arrangements, allowing them to route a client's order to the Shared Order Book to obtain the most favourable terms reasonably available for the client. Access is conditional on a structured risk assessment covering potential conflicts of interest of the Shared Order Book operators, settlement mechanics and timeline, failed settlement and default management processes, risk mitigation and client protection and available recourse. Retail participation requires an express client election and clear disclosure of the additional cross-border risks. 

Pillar S – Safeguards: aligning compliance with evolving market risks

Under Pillar S, the SFC sets out compliance expectations under the following three directions: 

• Dynamic approach to custodianship. On 15 August 2025, the SFC issued a circular to licensed VATP operators setting out outcome-based minimum standards for the custody of client VAs. These standards focus on aspects such as senior management accountability, robust cold wallet controls and third-party risk management, while avoiding prescription of specific custody technologies. The circular took immediate effect and serves as a regulatory benchmark for VATPs and the forthcoming standalone VA custodian regime.
• Insurance and compensation frameworks. The 2025 consultation conclusions for the proposed VA dealers and VA custodians regimes, referenced under Pillar A above, contemplate mandatory insurance or equivalent compensation arrangements as part of custody safeguards, together with minimum thresholds of HK$5 million paid-up capital (and up to HK$3 million liquid capital) for VA dealers and HK$10 million paid-up capital (and HK$3 million liquid capital) for VA custodians, and expect licensed entities to maintain excess liquid capital sufficient to cover at least 12 months of operating expenses. In addition, the SFC indicated its intention to retain the flexibility to impose additional financial resources requirements calibrated with reference to the scale of business.
• Safeguarding client VAs in withdrawals. On 11 February 2026, the SFC set out compliance expectations on VA brokers offering VAs withdrawal functionality to clients. While client VAs are held with VATP operators, VA brokers must implement robust controls to mitigate heightened cyber and operational risks, including strong authentication, access controls and continuous monitoring. Brokers are also expected to work closely with VATPs to detect and prevent abnormal or fraudulent withdrawals through measures such as withdrawal limits, wallet whitelisting controls and timely escalation mechanisms.

Pillar P – Products: a calibrated expansion of the regulated products portfolio

The SFC has advanced five distinct product-side workstreams since the launch of the ASPIRe Roadmap. 

• Allowing VATPs to provide staking as a service. On 7 April 2025, the SFC first set out the conditions on which licensed VATPs may offer the service, namely custody, disclosure and restrictions on re-hypothecation.  Subsequently, the SFC extended those expectations to Type 1 intermediaries distributing staking products or services to clients through issuing a Supplemental Joint Circular with the Hong Kong Monetary Authority ("HKMA") in September 2025 to cover governance, slashing risk disclosures and client-asset segregation matters. 
• Broader VA product offering. The SFC’s 3 November 2025 circular widened the range of products and services that VATPs may offer, including relaxing token admission requirements for professional investors ("PIs") and permitting the distribution of products related to digital assets such as VAs, tokenised securities and stablecoins.  Corresponding updates were also made to the framework for SFC authorised funds with VA exposure.
• Direction setting on VA perpetual contracts offering. The SFC published a high-level framework for VA perpetual contracts on 11 February 2026, setting out direction for VA perpetual offerings in the future. Perpetual contracts are platform-traded derivatives that track the price of an underlying asset or index without an expiry date, using periodic funding payments between long and short positions to align with spot prices. They are typically leveraged and margin-traded, with built-in margining and liquidation mechanisms to manage losses and limit platform counterparty exposure. The framework confines perpetual contracts offering to PIs, emphasises robust product design and places particular focus on mitigating risks unique to perpetuals. The SFC signals that binding requirements and any live offering will only follow after further consultation and refinement.
• VA margin financing. From 11 February 2026, Type 1 intermediaries that already conduct securities margin financing may extend financing for VA dealing, but only to existing margin clients and against a limited set of high-liquidity VAs, currently restricted to Bitcoin and Ether. The framework imposes a conservative risk overlay, most notably a minimum 60% haircut on VA collateral, alongside standard credit assessment, concentration and risk-management requirements.
• Secondary trading of tokenised investment products. On 20 April 2026, the SFC took the next step in facilitating tokenisation by permitting public secondary trading of tokenised, SFC-authorised investment products on licensed VATPs. The new framework allows tokenised fund units and similar products to be traded on VATPs, subject to requirements on fair pricing (including NAV-based price deviation alerts), liquidity and market-making arrangements, enhanced disclosure and client risk acknowledgement. The circular bridges primary issuance and secondary liquidity for tokenised products, reinforcing Hong Kong’s trajectory toward a fully regulated lifecycle for tokenised investments that mirrors traditional fund markets while leveraging digital infrastructure.

Pillar I – Infrastructure: modernising oversight, reporting and surveillance 

Pillar I focuses on strengthening the supervisory infrastructure underpinning Hong Kong’s VA regime, with an emphasis on market-wide visibility through enhanced reporting, surveillance and cross-agency coordination. While Pillar I has not yet been advanced through standalone circulars or formal consultations, the SFC has nonetheless commenced its CrypTech initiative in October 2025 to develop technology enabled supervisory tools, including automated regulatory reporting, blockchain analytics and enhanced monitoring of custody and market activities. 

As licensing and product-side frameworks under Pillars A and P become embedded, stakeholders and market participants should expect increased emphasis on data-driven supervision, closer coordination with the HKMA and law-enforcement agencies, and more structured supervisory engagement, as these infrastructure capabilities progress from proof-of-concept towards gradual supervisory deployment.

Pillar Re – Relationships: deepening engagement through transparency and education

Pillar Re addresses the non‑rulemaking side of regulation including, investor education, industry engagement and transparency around supervisory expectations. Developments have been made for both initiatives under this Pillar.

• Investor communication and finfluencers. The SFC has actively used its existing enforcement and supervisory powers to police unlicensed or misleading investment promotion on social media. In the last quarter of 2025, the SFC secured the first custodial sentence against a finfluencer for providing paid investment advice on social media without a licence. In parallel, the SFC commenced a thematic inspection in April 2025 examining how licensed intermediaries engage finfluencers and digital platforms for marketing purposes. 
• Against this backdrop, the ASPIRe Roadmap’s proposal of developing a regulatory framework for finfluencers signals clearer conduct expectations, particularly where finfluencers are engaged as marketing or distribution channels for regulated VA products, or more broadly in a manner that may amount to regulated activities or misleading promotion. Whilst no finfluencer-specific guidelines have been published to date, the SFC has indicated that licensed corporations engaging finfluencers are expected to conduct appropriate due diligence and to monitor finfluencer content to ensure that it does not involve unlicensed regulated activities or improper practices, and that existing obligations under the SFC’s Code of Conduct (including advertising and supervision requirements) are complied with.
• Industry engagement and capability‑building. The Virtual Asset Consultative Panel ("VACP") was established in February 2025 as a standing forum for dialogue with senior management of licensed VATPs. This was followed by the issuance of an Invitation to Tender for a Virtual Asset Accelerator in February 2026. Operated by third-party service provider under the SFC oversight, the VA accelerator, scheduled for launch later this year, will serve as a front-end capability-building and engagement platform to facilitate early risk identification and operational readiness in connection with proposals and applications submitted to the SFC. Unlike a sandbox, which allows regulated activity to be conducted in a limited scale in order to be tested, the accelerator aims to streamline VA-related applications by refining proposals submitted to the SFC’s review and ensuring that regulated activity is fully ready before it begins.

Together, these initiatives signal a shift toward engagement-led supervision and supervised experimentation.

Looking ahead: Implications for VA firms

For overseas VA platforms and service providers, Hong Kong’s shift from framework building to operational delivery marks a critical inflection point. As licensing regimes for VA dealing, advisory, management and custody move towards implementation, and products transition into live secondary markets, firms engaging with Hong Kong clients or infrastructure will need to align their business models, governance and operations with Hong Kong’s increasingly institution-grade standards. Early regulatory engagement, clear scoping of regulated activities and disciplined sequencing of licensing and product decisions will be key to successful market entry or expansion.