Hong Kong Stablecoin License(FRS)Application threshold，In-depth analysis of the first batch of lists

With the accelerated tightening and standardization of the global virtual asset regulatory framework，Hong Kong’s institutional construction in the field of digital finance reaches a historic milestone。The Financial Secretary of the Hong Kong SAR Government, Paul Chan Mo-po, clearly pointed out in the 2026-2027 budget that，The licensing system for fiat currency stablecoin issuers has been officially implemented。

As of March 2026，The Hong Kong Monetary Authority (HKMA) has received a total of 36share Stablecoin issuer license application，The first batch of official licenses are expected to be issued within this month。This is the critical stage of transition from "sandbox testing" to "official licensing"，A closer look at its legal basis、Regulatory thresholds and market participant landscape，It has great strategic guidance significance for enterprises planning to enter the field of Web3 and cross-border payments.。

one、 Legal source basis and core regulatory definition

Hong Kong’s stablecoin regulatory framework has a high degree of legal certainty。This system is based onChapter 656 of the Laws of Hong Kong "Stable Coins Ordinance"(Stablecoins Ordinance) as the legal basis，Has officially entered into force on August 1, 2025。Its core legal concepts are as follows：

• Regulatory system name： Regulatory Regime for Stablecoin Issuers。
• Official license name： Stablecoin Issuer License。
• Core supervision objects： Fiat-Referenced Stablecoin，(referred to as FRS)。
• Legal licensing entity： Hong Kong Monetary Authority (HKMA)。

According to the provisions of the Stable Coin Ordinance，Any entity operating the business of issuing FRS in Hong Kong，or actively promote its FRS issuance services to the Hong Kong public，All constitute regulated stablecoin activities.，Must obtain a license issued by the Hong Kong Monetary Authority in accordance with the law。

two、 Core threshold for obtaining a license：Six compliance and regulatory pillars

The Chief Executive of the Hong Kong Monetary Authority, Yue Weiman, emphasized at the previous meeting of the Financial Affairs Committee of the Legislative Council，The issuance of the first batch of licenses will adhere to the bottom-line thinking of "stability first"。Applicants must meet stringent statutory standards in the following six core dimensions:：

1. Localized entity requirements： The applicant must be inA company legally established in Hong Kong，A physical office with actual operations and identifiable management。
2. Legal capital access： Applicants must meetMinimum paid-up share capital requirement of HK$25 million，Or maintain capital of no less than 1% of the circulating face value (whichever is higher)，to ensure that it has the financial resilience to continue operating。
3. 100% full custody of reserve assets： Issuers must hold 100% high quality、Highly Liquid Reserve Assets。What is particularly important is，Reserve assets must be strictly insolvent from the issuer’s own funds，And handed over to regulated and compliant custody institutions (such as Zodia Custody, etc.) for independent custody。
4. Legal right of redemption protection： FRS holders have the absolute right to redeem at face value according to law.。Issuers must establish transparency、Timely redemption mechanism (usually required to be completed within T+1 working days)，and shall not set unreasonable redemption conditions or charge punitive fees。
5. Fit and Proper Test： Proposed controlling shareholder、director、Core executives such as Chief Executive Officer (CEO) and Stablecoin Manager，Must pass the strict background of the Hong Kong Monetary Authority、Qualification and Integrity Review。
6. Comprehensive risk management and AML compliance： A network security system that complies with international standards must be established、Smart contract audit mechanism，and strict customer identification (KYC)、Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) Compliance Processes。If cross-border activities are involved，It is also necessary to comply with the local regulatory requirements of the mainland and other jurisdictions.。

three、 Perspective on license application list：Who will drink the first batch of "head soup"?

Judging from the currently disclosed information and market trends，36The applicant institutions showed obvious cross-border and diversified characteristics。It is expected that the first batch of very small number of licenses will be issued from the following leading institutions that have passed the "sandbox test"：

1. Core sandbox participants (starting camp)

2024The first batch of sandbox participants announced in July，Completed compliance and technical run-through in a controlled environment，Have significant first-mover advantage：

• JINGDONG Coinlink： Relying on JD.com’s technology ecosystem，Highly focused on B-side payment infrastructure and supply chain finance solutions。
• RD InnoTech： Founded by former Hong Kong Monetary Authority Chief Executive Norman Chan.，Focus on solving the pain points of enterprise cross-border payment and B2B trade settlement。
• Anchorpoint (Standard Chartered Bank、Animoca Brands、Hong Kong Telecommunications Association)： Integrates top-level risk control of note-issuing banks and legal currency channels、Web3 native technology ecosystem and huge local telecom user scenarios，Formed a demonstration effect of strong alliance。

2. Traditional financial and technology giants enter the game

Except for sandbox members，Many major institutions have also confirmed their participation or been reported to have submitted applications.：

• tech giants： Ant Group’s digital technology arm is actively seeking the license，To improve its global compliance payment landscape。
• Note-issuing banks and large commercial banks： Bank of China Hong Kong (BOCHK)、Traditional financial giants such as HSBC and ICBC are actively deploying。
• Compliance virtual asset platform： Licensed VASP platforms represented by HashKey that are already operating in Hong Kong，We are trying to open up the closed loop of compliance between legal currency and digital assets through stable coins.。

Four、 Conclusion：Building a global digital financial moat

Official issuance of stablecoin license，Not only will it provide a solid infrastructure for RWA (Tokenization of Real World Assets) and cross-border B2B payments，It also marks that Hong Kong occupies the commanding heights in the formulation of global digital financial rules.。

Faced with extremely stringent paid-in capital、Asset custody and anti-money laundering compliance requirements，Precise architectural design and professional legal compliance support are the keys to enterprise approval。

GXT-HKas deep cultivationGlobal financial license agency and compliance consultingprofessional organizations，Committed to providing full life cycle compliance empowerment for B-side enterprises。Not only are weHong Kong MSO (Money Service Operator)、Has profound practical experience in the field of VASP (Virtual Asset Service Provider) license，more proficientUS MSB license、NFA、Application path for high-value financial licenses such as RIA。Whether you are planning to apply for a Hong Kong stablecoin license，Or build a compliant payment and asset management structure on a global scale?，Hong Kong Xintong's expert team can provide you with rigorous、Efficient floor-to-ceiling solutions，Help you win the global game of digital finance with certainty。

Reference content：

Hong Kong Monetary Authority – Register of Licensed Stablecoin Issuers

Securities Times：Hong Kong’s first batch of stablecoin licenses may be available in March，Who will stand out?