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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

Records
14
Binding status
in_force_enacted: 14/14
Evidence tier
firm_summary: 5/14; resolution_text: 8/14; unverified: 1/14
Review freshness
stale: 8/14; unknown: 6/14
Source availability
official: 10/14; unavailable: 4/14

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.
Instrument / locator
Stablecoins Ordinance (Cap. 656), licensing provisions
licensable regulated activities; s.8(1) licensing offence
Primary-source link
Open the source recorded by CBSR
Binding / legal status
in_force_enacted
operative
Claim / evidence tier
tier1_legal
resolution_text
Source disposition / check
official
checked
Last source check / next due
2026-06-27 / 2026-07-27
Freshness / review stage
stale
primary_reviewed_second_pending
Independent second reviewer
Not recorded
Effective from / until, as recorded
2025-08-01 / Not evidenced
Uncertainty
low
Exact committed record
hk-frs-issuer_pathway-001.yaml

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.
Instrument / locator
Stablecoins Ordinance (Cap. 656), reserve / backing requirements
100% backing; same-currency reserve with HKD/USD exception; segregation/trust
Primary-source link
Open the source recorded by CBSR
Binding / legal status
in_force_enacted
operative
Claim / evidence tier
tier1_legal
resolution_text
Source disposition / check
official
checked
Last source check / next due
2026-06-27 / 2026-07-27
Freshness / review stage
stale
primary_reviewed_second_pending
Independent second reviewer
Not recorded
Effective from / until, as recorded
2025-08-01 / Not evidenced
Uncertainty
low
Exact committed record
hk-frs-reserve_backing-001.yaml

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.
Instrument / locator
Stablecoins Ordinance (Cap. 656), Schedule 2, s.15 (Non-interest bearing)
Sch. 2 s.15 (no interest on issued stablecoins)
Primary-source link
Open the source recorded by CBSR
Binding / legal status
in_force_enacted
operative
Claim / evidence tier
tier1_legal
resolution_text
Source disposition / check
official
checked
Last source check / next due
2026-06-27 / 2026-07-27
Freshness / review stage
stale
primary_reviewed_second_pending
Independent second reviewer
Not recorded
Effective from / until, as recorded
2025-08-01 / Not evidenced
Uncertainty
low
Exact committed record
hk-frs-permitted_activity_yield-001.yaml

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.
Instrument / locator
Stablecoins Ordinance (Cap. 656) — HKD-referencing perimeter + non-HKD FRS professional-investor restriction
offshore HKD-referencing issuance is licensable; non-HKD FRS offering limited
Primary-source link
Open the source recorded by CBSR
Binding / legal status
in_force_enacted
operative
Claim / evidence tier
tier1_legal
resolution_text
Source disposition / check
official
checked
Last source check / next due
2026-06-27 / 2026-07-27
Freshness / review stage
stale
primary_reviewed_second_pending
Independent second reviewer
Not recorded
Effective from / until, as recorded
2025-08-01 / Not evidenced
Uncertainty
low
Exact committed record
hk-frs-monetary_sovereignty-001.yaml

Complete record inventory

Record / dimensionRecorded source locatorBinding statusFreshnessSource check date
AML and KYCAMLO + Ordinance AML obligations on licenseesin_force_enactedunknownNot evidenced
Bank and non-bank routingLicensing of issuers (bank and non-bank); not bank-onlyin_force_enactedunknownNot evidenced
Capital requirementsHK$25m paid-up capital (statutory)in_force_enactedstale2026-06-27
Cross-border dataPDPO (Cap. 486) data obligations; HKMA outsourcing/data guidancein_force_enactedunknownNot evidenced
Disclosure and reportingDisclosure, reserve attestation and supervisory reportingin_force_enactedunknownNot evidenced
Distributionpermitted-offeror closed loop; HK$5m / 7-year offencein_force_enactedstale2026-06-27
Implementation statusTimeline Jan 2022 -> Q3 2026; first cohort 10 Apr 2026in_force_enactedunknownNot evidenced
Issuer pathwaylicensable regulated activities; s.8(1) licensing offencein_force_enactedstale2026-06-27
Monetary sovereigntyoffshore HKD-referencing issuance is licensable; non-HKD FRS offering limitedin_force_enactedstale2026-06-27
Permitted activity and yieldSch. 2 s.15 (no interest on issued stablecoins)in_force_enactedstale2026-06-27
Redemptionpar redemption within 1 business dayin_force_enactedstale2026-06-27
Regulatory authorityHKMA as the licensing/supervisory authorityin_force_enactedstale2026-06-27
Reserve and backing100% backing; same-currency reserve with HKD/USD exception; segregation/trustin_force_enactedstale2026-06-27
Securities classificationHKMA stablecoin perimeter vs. the SFO securities/futures definitionsin_force_enactedunknownNot evidenced