Hong Kong Stablecoin Licence: The Stablecoins Ordinance Issuer Regime Explained

The Stablecoins Ordinance (Cap. 656) came into force on 1 August 2025 and establishes a licensing regime for issuers of fiat-referenced stablecoins (FRS). Two activities fall within scope: issuing fiat-referenced stablecoins in Hong Kong, and issuing stablecoins pegged to the Hong Kong dollar regardless of where the issuer is located. In other words, an offshore issuer that issues an HKD stablecoin needs an HKMA licence all the same.

The ordinance pairs licensing with sales-side restrictions: only stablecoins from licensed issuers may be sold to the Hong Kong retail public, and advertising is also restricted. That rules out the "issue first, get licensed later" approach in Hong Kong.

Financial threshold: paid-up capital or approved financial resources of at least HKD 25 million. Reserve assets are the heart of the regime: they must consist of high-quality, highly liquid assets whose market value fully covers the face value of stablecoins in circulation, held in custody segregated from the issuer's own assets, with regular disclosure and audits. Holders must have the right to redeem at par, and redemption must not carry unreasonable conditions. Two hard rules are easy to miss: issuers must not pay interest to stablecoin holders, and appointments of key personnel require the HKMA's prior consent. Issuers must also publish a white paper and meet fit and proper and AML/CFT requirements.

The HKMA has published Explanatory Notes on the Licensing of Stablecoin Issuers. Applicants prepare under the notes and contact the HKMA (the first round of expression-of-interest engagement ran until 31 August 2025), then file a formal application for review; successful applicants are entered in the official register of licensees. The HKMA has said publicly that it will license sparingly and prudently, with only a limited number of licences in the first batch. The regulator has not published an application fee or processing time.

For most practitioners the near-term question is not how to get a licence but how to use stablecoins compliantly: checking whether a stablecoin's issuer appears in the HKMA register determines whether it can be sold to the Hong Kong retail public.