How much capital do you need for the SFC VASP (VATP) Licence?

HK$5M paid-up + liquid requirements. Paid-up share capital: HKD 5,000,000; Liquid capital: Higher of HK$3,000,000 or the basic amount (Financial Resources Rules); Liquid-asset runway: 12 months of actual operating expenses in non-VA liquid assets, rolling.

General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.

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Recently verified:28 July 2026·Source →

SFC VASP (VATP) Licence

Q: How long does the SFC VASP (VATP) Licence take?

In practice: Around 12 months in practice (industry estimate), including two phases of external assessor reports: phase 1 (design effectiveness) before approval-in-principle and phase 2 (implementation effectiveness) before the licence is granted.

Q: What does the SFC VASP (VATP) Licence application cost?

Application fee: Approximately HK$4,740 per regulated activity (Type 1 + Type 7 ≈ HK$9,480), plus per-Responsible-Officer and per-representative fees — consistent with the standard SFC schedule; confirm in the VATP Licensing Handbook fee table.. Ongoing: Annual licence fees per SFC schedule via the WINGS platform; monthly business reports due within two weeks of month-end; annual audit by a certified auditor.

Hong KongExchange / tradingCustodyLive

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General information only — not legal advice

CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.

Hong Kong's licensing regime for virtual asset trading platforms, in force since June 2023. Platforms apply for SFO Type 1 and Type 7 licences and the AMLO VASP licence simultaneously — the SFC strongly encourages the dual route given shifting token classifications. Retail access is permitted with investor-protection add-ons, and November 2025 circulars opened access to global liquidity. Client asset custody must sit in a wholly-owned subsidiary of the platform: third-party custodians are not accepted.

Capital requirements

Tier	Capital	Covers
Paid-up share capital	HKD 5,000,000 Maintained at all times	All licensed VATP activity
Liquid capital	Higher of HK$3,000,000 or the basic amount (Financial Resources Rules)	All licensed VATP activity
Liquid-asset runway	12 months of actual operating expenses in non-VA liquid assets, rolling	All licensed VATP activity

Application process

Structure for the dual licence

Prepare a simultaneous application for SFO Types 1 and 7 plus the AMLO VASP licence — the SFC processes them together and dual licensing protects against token reclassification.

Build the custody subsidiary

Client assets must be held by a wholly-owned subsidiary of the platform meeting SFC custody standards, with cold-storage expectations — third-party custodians are not accepted.

Assemble governance and financial resources

Two-plus Responsible Officers, managers-in-charge mapping, HK$5M paid-up capital, liquid capital and the 12-month liquid-asset runway (virtual assets do not count as liquid assets).

Phase 1 external assessor report

Design-effectiveness assessment of systems and controls, submitted with the application, leading to approval-in-principle.

Phase 2 assessor report and grant

Implementation-effectiveness assessment on the live build precedes the licence grant; retail access requires the investor-protection measures to be in place.

Ongoing obligations

Paid-up capital — HK$5,000,000 at all times, plus liquid capital at the higher of HK$3,000,000 or the basic amount under the Financial Resources Rules.

12-month expense runway — liquid assets (cash, deposits, T-bills — not virtual assets) covering at least 12 months of actual operating expenses, on a rolling basis, held in Hong Kong.

Custody via wholly-owned subsidiary — segregated client assets, cold-storage expectations, insurance or compensation arrangements.

Token due diligence — listing committees and a 12-month track-record rule for tokens (stablecoins from HKMA-licensed issuers exempt).

Reporting — monthly business reports within two weeks of month-end; annual audited accounts; ongoing notification obligations.

Common rejection & delay reasons

Custody architecture not subsidiary-based

Plans built around third-party custodians fail the SFC's requirement that custody sit in a wholly-owned subsidiary.

Liquid-asset runway underfunded

The rolling 12-month expense requirement in non-VA liquid assets is the quiet budget-killer — in practice a custodial platform holds roughly HK$15M in qualifying liquid assets (industry estimate).

Responsible Officer gaps

Two ROs with the right regulatory papers and at least one executive director is a hard requirement that delays under-resourced applications.

What's changing

New licensing regimes for VA dealing services and VA custodians — legislation intended following consultations; will pull brokers, OTC desks and standalone custodians into scope

· consultation

VA advisors and managers regime consulted (closed 23 Jan 2026): proposed HK$5M paid-up plus HK$3M liquid where holding client assets, with no transitional arrangements

· consultation

Frequently asked questions

JurisdictionHong Kong

RegulatorSecurities and Futures Commission (SFC)

TypeLicence (dual: SFO + AMLO)

CapitalHK$5M paid-up + liquid requirements

Application feeApproximately HK$4,740 per regulated activity (Type 1 + Type 7 ≈ HK$9,480), plus per-Responsible-Officer and per-representative fees — consistent with the standard SFC schedule; confirm in the VATP Licensing Handbook fee table.

Ongoing feesAnnual licence fees per SFC schedule via the WINGS platform; monthly business reports due within two weeks of month-end; annual audit by a certified auditor.

Realistic timelineAround 12 months in practice (industry estimate), including two phases of external assessor reports: phase 1 (design effectiveness) before approval-in-principle and phase 2 (implementation effectiveness) before the licence is granted.

PassportingNone

Last verified28 Jul 2026

Hong Kong incorporated or registered company; at least two Responsible Officers of whom at least one is an executive director; managers-in-charge regime; fit-and-proper requirements including local regulatory paper (exemptions for existing SFC licensees).

https://www.sfc.hk →

HK VATP Licensing →Hong Kong: HKMA Stablecoin Issuer Licence →

Disclaimer

This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.