CBSR · evidence library
Hong Kong SAR stablecoin regulation evidence | CBSR historical snapshot
Explore 14 Hong Kong SAR stablecoin regulatory records with source locators, issuer pathways, reserve and yield rules, legal-force and review status in the 20 August 2026 CBSR snapshot.
Read this jurisdiction in context
Hong Kong's dossier separates the Stablecoins Ordinance licensing perimeter, HKD-referencing offshore issuance, offering restrictions, reserve safeguards and the non-interest-bearing condition. Licence-cohort observations are operational facts and do not replace the legal test for a different issuer or product.
Coverage and unresolved review work
Four regulatory questions and their evidence
Issuer pathway
hk-frs-issuer_pathway-001
Snapshot record wording · not a statutory quotation
A licence is required for (1) FRS issuers in Hong Kong, (2) issuers outside HK of stablecoins referencing the HK dollar, and (3) entities actively marketing FRS to the HK public. Eligible applicants are companies incorporated in HK under the Companies Ordinance, or authorised institutions (banks / restricted-licence / deposit-taking companies under the Banking Ordinance). Shell entities or mere pre-1-Aug-2025 establishment do not qualify for transitional treatment. The first-licence cohort (10 Apr 2026) was HSBC and Anchorpoint Financial Limited (a Standard Chartered (HK)–HKT–Animoca JV intending HKDAP on a B2B2C model); no PRC-connected entities were licensed.Reserve and backing
hk-frs-reserve_backing-001
Snapshot record wording · not a statutory quotation
100% backing at all times; the market value of reserve assets must equal or exceed the par value of circulating stablecoins, with HKMA expecting overcollateralisation. Acceptable assets: cash, bank deposits (term <= 3 months), government and central-bank securities (residual maturity <= 1 year), and tokenised forms of the foregoing. Reserves must be strictly segregated from the issuer's other assets and protected against creditor claims via statutory trust.Permitted activity and yield
hk-frs-permitted_activity_yield-001
Snapshot record wording · not a statutory quotation
The Stablecoins Ordinance Schedule 2 Section 15 (Non-interest bearing) provides that the licensee must not pay any interest on issued stablecoins. Direct payments from issuer to holder are reached by the prohibition.Monetary sovereignty
hk-frs-monetary_sovereignty-001
Snapshot record wording · not a statutory quotation
Hong Kong does not impose a quantitative non-domestic-currency usage cap of the MiCA Article 23 type, but it draws a sovereignty-adjacent line through distribution: foreign-based issuers of non-HKD-linked FRS may offer to professional investors only, while HKD-referencing stablecoins (including those issued offshore) are pulled fully inside the licensing perimeter. The effect is to privilege the domestic-currency instrument for retail use without a numeric ceiling.Complete record inventory
| Record / dimension | Recorded source locator | Binding status | Freshness | Source check date |
|---|---|---|---|---|
| AML and KYC | AMLO + Ordinance AML obligations on licensees | in_force_enacted | unknown | Not evidenced |
| Bank and non-bank routing | Licensing of issuers (bank and non-bank); not bank-only | in_force_enacted | unknown | Not evidenced |
| Capital requirements | HK$25m paid-up capital (statutory) | in_force_enacted | stale | 2026-06-27 |
| Cross-border data | PDPO (Cap. 486) data obligations; HKMA outsourcing/data guidance | in_force_enacted | unknown | Not evidenced |
| Disclosure and reporting | Disclosure, reserve attestation and supervisory reporting | in_force_enacted | unknown | Not evidenced |
| Distribution | permitted-offeror closed loop; HK$5m / 7-year offence | in_force_enacted | stale | 2026-06-27 |
| Implementation status | Timeline Jan 2022 -> Q3 2026; first cohort 10 Apr 2026 | in_force_enacted | unknown | Not evidenced |
| Issuer pathway | licensable regulated activities; s.8(1) licensing offence | in_force_enacted | stale | 2026-06-27 |
| Monetary sovereignty | offshore HKD-referencing issuance is licensable; non-HKD FRS offering limited | in_force_enacted | stale | 2026-06-27 |
| Permitted activity and yield | Sch. 2 s.15 (no interest on issued stablecoins) | in_force_enacted | stale | 2026-06-27 |
| Redemption | par redemption within 1 business day | in_force_enacted | stale | 2026-06-27 |
| Regulatory authority | HKMA as the licensing/supervisory authority | in_force_enacted | stale | 2026-06-27 |
| Reserve and backing | 100% backing; same-currency reserve with HKD/USD exception; segregation/trust | in_force_enacted | stale | 2026-06-27 |
| Securities classification | HKMA stablecoin perimeter vs. the SFO securities/futures definitions | in_force_enacted | unknown | Not evidenced |