Hong Kong crypto rules advance for advisers, managers

Hong Kong moved a step closer to licensing virtual-asset advisers and managers on Tuesday after the Financial Services and the Treasury Bureau and the Securities and Futures Commission published consultation conclusions and opened a one-month consultation that will feed into a bill the government aims to introduce in 2026. The move would pull more crypto advisory and portfolio-management activity into the city’s anti-money laundering framework.

The proposal goes beyond trading venues and custodians, two parts of the market Hong Kong has already been regulating more closely. It would make advice on virtual assets and discretionary management of virtual-asset portfolios licensable businesses, widening oversight for firms that market token strategies, manage crypto allocations or stand between investors and crypto products.

Officials said the latest step follows earlier consultations on separate regimes for virtual-asset dealing and custodian service providers. The government received 101 submissions on the dealing proposal and 93 on custody, according to the official statement, and said the further consultation on advisers and managers runs until January 23, 2026.

That sequencing suggests Hong Kong is building a broader rulebook around crypto intermediaries rather than stopping at exchange licensing.

In the statement announcing the next phase, Secretary for Financial Services and the Treasury Christopher Hui said the broader licensing push was meant to strengthen the legal framework for digital assets.

“The proposed establishment of licensing regimes for VA dealing and custodian service providers marks a significant step in enhancing our legal framework for digital assets.”

— Christopher Hui, Hong Kong Secretary for Financial Services and the Treasury

The consultation does not amount to an open invitation for every crypto business. It focuses on which firms need licenses, how much capital they must hold and how regulators should divide oversight between securities rules and anti-money laundering obligations.

What the proposal covers

A Hogan Lovells analysis said the authorities are trying to map two areas that have been less clearly defined in Hong Kong’s crypto regime: virtual-asset advisory services and discretionary management of virtual-asset portfolios. It said the paper outlines minimum paid-up capital of HKD 100,000 for advisers, HKD 5 million for managers with custody and HKD 3 million for managers without custody.

Those thresholds point to a practical distinction in the regime. Managers that sit closer to client assets face heavier capital requirements than advisers that stay further from custody and execution.

For firms offering model portfolios, wealth-management products or private-client crypto allocations, the next question is where regulators draw the line between advice, execution and safekeeping. The answer will matter for traditional financial groups as well as crypto-native firms weighing whether to expand in Hong Kong.

Julia Leung, the SFC’s chief executive officer, said in the official statement that the progress already made should help Hong Kong stay at the forefront of digital-asset market development. Her comment pointed to the package’s two-track goal: keep the city open to regulated crypto business while applying controls that look familiar to asset managers and compliance teams.

The government said it plans to introduce a bill into the Legislative Council in 2026 after the consultation closes. That gives firms a short window to argue over scope, licensing thresholds and the practical definition of advisory activity before the draft law reaches lawmakers.