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Hong Kong

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Hong Kong is the comparison that matters for three reasons. It is the only other common-law international financial centre in Asia, it shares Singapore's tax neutrality on capital gains and the two cities have competed for the same banks, funds and family offices for fifty years. Its digital-asset policy has moved in the opposite direction to Singapore's since 2022. Where Singapore tightened retail access after the collapses of that year, Hong Kong announced in a policy statement of October 2022 that it would welcome virtual-asset businesses and would consider retail access to licensed platforms. It has since built a regime of unusual breadth.1

The core of the regime is the licensing of virtual asset trading platforms. Since 1 June 2023, under amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, any centralised platform trading non-security tokens in Hong Kong needs a licence from the Securities and Futures Commission. Platforms trading security tokens already needed a licence under the Securities and Futures Ordinance. Existing platforms had a twelve-month transitional period. Licensed platforms may serve retail investors if they implement suitability assessments, a token admission committee and a restriction of retail trading to large-capitalisation tokens included in at least two acceptable indices.2 In April 2024 Hong Kong approved the first spot Bitcoin and Ether exchange-traded funds for retail investors, a product MAS has not permitted. The Securities and Futures Commission published a roadmap for the virtual-asset market in February 2025 and the Government a second policy statement in June 2025 that extended the agenda to tokenisation of real-world assets and to the licensing of dealers and custodians.3

Hong Kong's stablecoin regime moved faster than Singapore's. The Stablecoins Bill was introduced into the Legislative Council on 18 December 2024, passed in May 2025 and commenced on 1 August 2025. It requires anyone issuing a fiat-referenced stablecoin in Hong Kong, or a Hong Kong-dollar-referenced stablecoin anywhere, to hold a licence from the Hong Kong Monetary Authority, with reserve, redemption and governance requirements comparable to those of the Singapore framework of 2023.45 By mid-2026 Hong Kong therefore had in force a statute that Singapore still had in draft, and several of the stablecoin issuers that had planned Singapore issuance under the 2023 framework were weighing Hong Kong instead.

The author holds a Hong Kong practising certificate and has advised on both sides of the Singapore–Hong Kong line for many years. Part O, Chapter III examines the Hong Kong regime in depth and shows how it fits into a strategy built on Zug and Singapore. For present purposes the contrast with Singapore can be stated in a table.

AxisSingapore (30 June 2026)Hong Kong (30 June 2026)
Regulator for exchangesMAS, under the Payment Services Act 2019SFC, under the AMLO (non-security tokens) and the SFO (security tokens)
Retail spot tradingPermitted by licensees under severe conduct restrictions (no credit, no incentives, risk assessment)Permitted by licensed platforms for large-cap tokens with suitability checks
Spot crypto ETFs for retailNot permittedPermitted since April 2024
Stablecoin issuance2023 framework; legislation pendingStablecoins Ordinance in force since 1 August 2025
Overseas-only providersLicence required under FSMA Part 9, almost never grantedNo equivalent regime; licensing turns on activity in or toward Hong Kong
Tax on crypto gainsNone for investors; trading income taxedNone for investors; trading income taxed; offshore-sourced profits exempt
Banking for licenseesDomestic banks engaged under MAS encouragementBanks engaged under HKMA encouragement since 2023
CourtsCommon law; SICC; proprietary status of tokens recognisedCommon law; proprietary status recognised in Re Gatecoin
Political overlayIndependent city state; ASEAN memberSpecial administrative region; National Security Law since 2020
Access to mainland ChinaIndirectDirect policy aim; mainland capital controls still apply

Notes

  1. Financial Services and the Treasury Bureau, Hong Kong, "Policy Statement on Development of Virtual Assets in Hong Kong", 31 October 2022. ↩
  2. Hong Kong Securities and Futures Commission, Consultation Conclusions on the Proposed Regulatory Requirements for Virtual Asset Trading Platform Operators, 23 May 2023; the virtual asset trading platform regime under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) commenced on 1 June 2023 with a twelve-month transitional period, per Clyde & Co, "Hong Kong virtual assets regulatory update" (June 2023). ↩
  3. Hong Kong Securities and Futures Commission, "ASPIRe" roadmap for the virtual asset market, 19 February 2025; Financial Services and the Treasury Bureau, "Policy Statement 2.0 on the Development of Digital Assets in Hong Kong", 26 June 2025. ↩
  4. Stablecoins Bill introduced into the Legislative Council on 18 December 2024, licensing by the Monetary Authority of issuers of "specified stablecoins" referencing one or more official currencies, per Legislative Council Panel on Financial Affairs paper of 17 January 2025 (LC Paper No. CB(1)55/2025(02)). ↩
  5. Stablecoins Ordinance (Cap. 656), passed by the Legislative Council on 21 May 2025 and in operation from 1 August 2025; the Hong Kong Monetary Authority's licensing guidelines and the first licences issued thereafter. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.