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.

← Back to licensing guides|Licensing→Hong Kong→SFC VASP (VATP) Licence

Verify recommended:28 July 2026·Source →

SFC VASP (VATP) Licence

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

In practice: No published processing time. The Handbook (para 6.7.1) lists what lengthens it: the services and products proposed, the adequacy of internal controls, the quality and completeness of the application and supporting documents, later changes to business scope, ownership, Responsible Officers or MICs, employment visas, the time taken to inject capital, other regulators' vetting responses, the applicant's own response time and the SFC's caseload. Because the external assessment is performed on the deployed platform after the application is lodged, build and staffing must be complete before grant.

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

Application fee: HKD 14,220. Ongoing: Annual fees, due within one month of each licence anniversary: HK$4,740 per regulated activity or VA service for the Platform Operator, and for each individual HK$4,740 (Responsible Officers) or HK$1,790 (other licensed representatives) per regulated activity or VA service (Handbook para 8.10.1); late payment attracts a surcharge rising to suspension after three months. Recurring filings: monthly financial resources returns (8.9.1) and audited accounts within four months of each financial year end (8.8.1).

Hong KongExchange / tradingCustodyLive

⚠

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 the dual-route application

SFO Types 1 and 7 plus the AMLO VA service, submitted as one consolidated application on WINGS. Forms VA1 (corporate), VA3 (at least two Responsible Officers, all lodged with the corporate application), VA6 (Associated Entity), Supplements VA1–VA3, and Questionnaire VA-1 with the twelve policies listed at Q102.

Submit with the external assessor identified

The bundle must include the written policies and procedures, evidence that a suitable assessor has been identified and the assessor’s capability statement; the SFC may return the application if it opposes the assessor (Handbook 6.3.1, 6.5.1).

Deploy systems, controls and staff

Including the Associated Entity that holds client assets (wholly owned, Hong Kong-incorporated, TCSP-licensed) and the bank account, whose details the SFC needs before approval (6.10.5).

Tripartite agreement and single external assessment

The SFC, applicant and assessor agree the scope; one direct-assurance assessment, signed off by a practising CPA, covers whether policies, procedures, systems and controls are suitably designed and implemented (3.2.23).

Close outstanding matters and grant

Paid-up capital of HK$5m, liquid capital and twelve months’ non-virtual-asset liquid assets held in Hong Kong, RO approvals; the licence carries standard conditions: prior SFC approval for any new or materially changed service, monthly business reports within two weeks of month end, and an annual independent review with the first report due within 18 months of approval (1.2.3). Retail access needs the Guidelines Chapter 9 investor-protection measures in place first.

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 feeHKD 14,220

Ongoing feesAnnual fees, due within one month of each licence anniversary: HK$4,740 per regulated activity or VA service for the Platform Operator, and for each individual HK$4,740 (Responsible Officers) or HK$1,790 (other licensed representatives) per regulated activity or VA service (Handbook para 8.10.1); late payment attracts a surcharge rising to suspension after three months. Recurring filings: monthly financial resources returns (8.9.1) and audited accounts within four months of each financial year end (8.8.1).

Realistic timelineNo published processing time. The Handbook (para 6.7.1) lists what lengthens it: the services and products proposed, the adequacy of internal controls, the quality and completeness of the application and supporting documents, later changes to business scope, ownership, Responsible Officers or MICs, employment visas, the time taken to inject capital, other regulators' vetting responses, the applicant's own response time and the SFC's caseload. Because the external assessment is performed on the deployed platform after the application is lodged, build and staffing must be complete before grant.

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.