The Hong Kong Stablecoins Ordinance (Cap. 656) is the standalone licensing regime for fiat-referenced stablecoin issuers operating in or from Hong Kong. The Legislative Council passed the bill on 21 May 2025 and the regime commenced on 1 August 2025, supervised by the HKMA (Hong Kong Monetary Authority) (HKMA implementation press release). The Ordinance covers single-fiat and multi-fiat referenced designs (including HKD and offshore CNH) and applies extraterritorially to any issuer marketing an HKD-referenced stablecoin to Hong Kong residents. For a tokenisation product team, it determines which fiat-referenced designs can be issued from Hong Kong, what reserve composition is allowed, and what redemption obligations look like. Editorial deep-dive on the licensee population and offshore-RMB angle lives at hong kong stablecoins ordinance in themes.
Scope
The Ordinance covers "specified stablecoins," defined as cryptographically secured digital representations of value that purport to maintain a stable value by reference to one or more fiat currencies. The perimeter is fiat-referenced rather than single-fiat, which is broader than the MAS Single-Currency Stablecoin (SCS) framework and the EU's MiCA EMT category. Algorithmic stablecoins, crypto-collateralised stablecoins, and stablecoins referenced to commodities or precious metals sit outside the perimeter (Sidley analysis).
The licensing trigger has three branches. Anyone issuing a specified stablecoin in Hong Kong needs a licence. Anyone issuing a stablecoin that references the HKD needs a licence regardless of where the issuer sits. Anyone actively marketing a specified stablecoin to Hong Kong residents needs a licence or an exemption. Tokenised deposits issued by licensed banks sit outside the Ordinance and remain supervised under existing banking law. Tokenised funds and tokenised securities are out of scope; SFC (Securities and Futures Commission) supervision applies.
Mechanics
A licensee must be a body corporate incorporated in Hong Kong with minimum paid-up share capital of HK$25 million, HK$3 million liquid capital, and excess liquid capital sufficient to cover at least 12 months of operating expenses (Morgan Lewis HK Stablecoins Ordinance overview). Banks may apply, but the licence is non-bank in shape, distinct from a banking, stored-value-facility (SVF), or money-services-operator licence.
Reserves must be high-quality liquid assets at least equal to par value at all times. Acceptable assets are cash, bank deposits with maximum three-month terms, government and central-bank securities with maximum one-year residual maturity, and qualifying investment funds; tokenised equivalents are permitted where they meet equivalent quality standards. Reserves must be segregated and held in custody arrangements designed to insulate them from issuer insolvency. HKMA expects overcollateralisation to buffer volatility and operational costs (Sidley analysis).
Holders have an absolute right to redeem at par in the reference asset, with processing required within one business day unless HKMA approves a longer period. Unreasonable fees and burdensome conditions are prohibited. Reserve disclosure runs at minimum monthly. The Ordinance does not formally prohibit interest payments, but parallel positioning to MiCA EMT and the GENIUS Act means licensed issuers are not expected to pay holding-period interest.
Two HKMA guidelines were gazetted on 1 August 2025 alongside commencement: the Guideline on Supervision of Licensed Stablecoin Issuers and the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for licensed stablecoin issuers (HKMA implementation press release).
Status
In force from 1 August 2025. The Ordinance was gazetted on 30 May 2025 following Legislative Council passage on 21 May 2025, and the commencement notice setting 1 August 2025 was published on 6 June 2025 (Stablecoins Ordinance Commencement Notice). HKMA has not, as of late April 2026, published a complete public list of issued licences. The applicant queue runs across bank-led, payment-firm-led, and technology-firm-led contender clusters. Operators tracking the regime should treat any "licensee count" reported in secondary press as provisional until HKMA publishes its own register.
Implications for tokenisation
For an issuer choosing between Asian regimes, the Ordinance is more permissive on currency reference than the MAS SCS framework. The space for an offshore-CNH-referenced design is the cleanest comparative advantage, since the EU and US frames foreclose multi-fiat constructions and Singapore foreclosed CNH explicitly. For an HKD-referenced design, the extraterritorial reach means an offshore issuer cannot route around the licence by incorporating elsewhere; HKMA's perimeter follows the reference currency.
The one-business-day redemption obligation is tight enough that an issuer cannot rely on extended T+2 or T+3 reserve-conversion windows. The reserve must be liquid enough to fund par redemption within a single business cycle, constraining how aggressively the issuer can sweep cash into longer-dated instruments even within the permitted asset list.
Tokenised deposits remain the parallel route for bank-issued tokenised cash, supervised through existing banking law and through Project Ensemble. For an institutional treasury choosing between a Stablecoins Ordinance-licensed instrument and a tokenised deposit, the trade-off is roughly bearer-style transferability with non-bank credit exposure versus account-based transferability with bank credit exposure.
Open questions
- Whether HKMA will publish licensee counts and conditions on a regular cadence, or whether the register will remain partial.
- The treatment of CNH-referenced stablecoins under the Ordinance for cross-border use cases that touch onshore RMB counterparties, which the Ordinance does not bridge.
- How the comparability provisions under the GENIUS Act will treat HKMA-licensed stablecoin issuers wishing to market into US persons.
- The interaction with the SFC tokenised-funds regime where a licensed issuer wishes to use a tokenised money-market fund as a reserve asset.