Full guide to applying for stablecoin licenses in Hong Kong: core conditions, practical difficulties and key to success

In June 2023 , the Hong Kong Virtual Asset Service Provider ( VASP ) licensing system officially came into effect, marking a solid step in its virtual asset regulatory framework. The Stablecoin Bill (the “Regulations”) was adopted by the Legislative Council on May 21 , 2025 . Immediately afterwards, in order to further implement the requirements of the Ordinance, the Hong Kong Monetary Authority ( HKMA ) issued two important consulting documents on May 26, 2025 to provide detailed regulatory guidance for stablecoin issuers, the "Draft Regulatory Guidelines" (hereinafter referred to as the " Regulatory Guidelines " ) and the "Guidelines for Combating Money Laundering and Terrorist Funding" (hereinafter referred to as the " AML Consultation Document " ), covering relevant regulatory guidance and consultation on the guidelines for Combating Money Laundering and Terrorist Funding. This has caused a huge response in the market, especially in various industries that are looking forward to .

Stablecoins, as a bridge connecting the traditional finance and the crypto world, are self-evident. However, the market turmoil caused by the past Luna/UST collapse is still lingering in fear, revealing the huge risks of algorithmic stablecoins. Even the US dollar stablecoin with the largest market share, such as USDT ( Tether ), has been questioned and regulated for its reserve assets many times because of its transparency and adequacy. These events highlight the urgency and necessity of effective regulation of stablecoins.

The stablecoin regulatory framework launched by Hong Kong this time aims to provide a clear and stable regulatory environment for the issuance and operation of stablecoins through a clear license system, strict reserve asset management requirements, a sound risk management framework and complete investor protection measures, so as to attract responsible innovators, enhance market confidence, and consolidate Hong Kong's position as the world's leading virtual asset center.

For institutions that are interested in issuing stablecoins in Hong Kong, a deep understanding of these regulatory requirements and preparing for compliance in advance will be the key to their success. This article will combine the latest "Regulations", "Regulatory Guidelines" and " AML Consultation Documents" to provide potential applicants with a detailed " Comprehensive Guide to Application for Hong Kong Stable Coin License " .

1. Overview of core conditions: Become a " hard indicator

" for Hong Kong licensed stablecoin issuers

According to the "Regulatory Guidelines", if you apply for a Hong Kong stablecoin license (the official name may be " stablecoin issuer license " ), the applicant needs to meet a series of strict core conditions. These conditions form the basis for the regulator to assess whether the applicant has the ability, resources and integrity to operate the stablecoin business safely and stably. In summary, it mainly includes the following seven aspects:

1. Adequate financial resources : Ensure that the issuer has sufficient capital to deal with operational risks and potential losses.
2. Strong Reserve Assets Management : Ensure that stablecoins are supported by sufficient, high-quality and high-liquid assets, and reserve assets are properly kept and isolated.
3. A sound issuance, redemption and distribution mechanism (Issuance, Redemption and Distribution) : Ensure that the issuance and redemption process of stablecoins is efficient, fair and transparent, and that the distribution channels are properly managed.
4. A strict risk management framework : Ensure that issuers can identify, evaluate, monitor and manage various risks related to their business, including technical risks, operational risks, market risks, liquidity risks, legal compliance risks, etc.
5. Complete Corporate Governance : Ensure that issuers have a sound governance structure, competent management team and effective internal control mechanisms.
6. Business Practices and Conduct : Ensure that issuers operate in an honest, fair and transparent manner, and fully protect user data and rights.
7. Effective anti-money laundering and terrorist fundraising ( AML/CFT ) measures: Ensure that issuers strictly abide by Hong Kong's AML/CFT regulations and effectively prevent their stablecoins from being used for illegal activities.

2. **Detailed explanation of core conditions and practical

difficulties**

1. Sufficient financial resources

The core requirement is minimum paid-in capital (Minimum Paid-up Share Capital)

According to the Regulatory Guidelines, “An applicant for a stablecoin issuer licence must have a minimum paid-up share capital of HK$25 million, or such higher amount as the Monetary Authority may specify, having regard to the scale and nature of the applicant's proposed operations” , or a higher amount that the Monetary Authority may specify, having regard to the scale and nature of the applicant's proposed operations.

Although HK$ 25 million is a clear threshold, the HKMA will conduct a comprehensive assessment, taking into account factors such as the applicant 's business model, risk exposure, and expected issuance scale, which may require higher capital. The issuer should be prepared to demonstrate that its capital level is sufficient to cover potential risks.

This part of the capital is usually required to be used exclusively to support the operation and risk resistance of stablecoin business, and cannot be arbitrarily used for other non-related businesses or shareholder distributions. After obtaining a license, the issuer still needs to continue to meet the capital adequacy requirements and regularly report its capital status to the HKMA. This may mean capital adjustments need to be made based on business development dynamics.

2. Strong reserve asset management

This is the core of stablecoin regulation and the part that the market is most concerned about.

There are six core requirements for preliminary asset management, namely:

1. Full Backing and Appropriate Over -collation ;
2. Scope and composition of reserve assets ;
3. Reference currency and consistency of reserve assets ;
4. Isolation and safekeeping (Segregation and safekeeping) ;
5. Non-interest bearing on stablecoins ;
6. Disclosure and reporting on reserve assets

1 ) Full Backing and Appropriate Over -collation

According to the Regulatory Guidelines, “A licensed stablecoin issuer must ensure that its stablecoins are at all times fully backed by a pool of high-quality and highly liquid reserve assets. The Monetary Authority may also require an appropriate level of over-collateralization depending on the risk profile of the reserve assets”. The Monetary Authority may also require appropriate levels of over-collateral based on the risk profile of reserve assets. Every word of this sentence is the point.

"fully backed/ full support " is the bottom line, that is, the value of reserve assets must not be lower than the total value of stablecoins in circulation at any time. The " appropriate/ appropriate" in " appropriate over-mortgage " deserves attention. There is no one-size-fits-all standard for what is " appropriate " . In fact, it is difficult for regulatory authorities to determine a unified standard from the current stage. The HKMA will decide whether and how much over-collateral is required based on the volatility, liquidity of the reserve assets and the issuer's own risk management capabilities. This means that the issuer needs to communicate fully with the HKMA and be prepared to dynamically adjust its reserve levels in accordance with regulatory requirements .

(1) Scope and composition of reserve assets

“Reserve assets must predominantly consist of high-quality liquid assets (HQLA) such as short-term bank deposits with authorized institutions in Hong Kong, short-term government securities with a satisfaction credit rating, or other assets as may be accepted by the Monetary Authority on a case-by-case basis. Algorithmic stablecoins or stablecoins backed by other virtual assets are generally not acceptable” , reserve assets must consist mainly of high-quality liquid assets ( HQLA ), such as short-term bank deposits in Hong Kong approved institutions, short-term government securities with satisfactory credit ratings, or other types of assets that the Monetary Authority may accept based on the circumstances. Algorithmic stablecoins or stablecoins backed by other virtual assets are usually not accepted.

Regulators have a very clear conservative attitude towards reserve assets, and are prioritized for bank deposits and short-term government bonds with high credit ratings.

For CNH stablecoins and gold stablecoins that many people are concerned about in the market , it should be clearly pointed out that although the "Regulatory Guidelines" leave a hole in " other types of assets accepted by the HKMA " , for such innovative assets, applicants must prepare extremely detailed and convincing argumentation materials to prove that they are not inferior to or even better than the high-liquid and low-risk assets clearly listed in the "Regulatory Guidelines" in terms of liquidity protection (especially under stressful situations), price fluctuation management mechanisms (such as effective hedging strategies), valuation transparency and reliability, and custody security . We understand that the HKMA is very cautious about such innovations, and the approval process will be longer and stricter.

For gold stablecoin applicants, one path worth exploring is to consider working with local licensed financial institutions in Hong Kong (such as banks or asset management companies) to use their issued gold ETFs traded on the Hong Kong Exchange as their main reserve assets. This may be easier to gain regulatory recognition in liquidity, valuation and custody than holding physical gold directly, as ETFs themselves are under some level of regulation. You can refer to the compliance framework and reserve proof mechanism of existing gold stablecoins such as PAX Gold (PAXG) , but you must be clear that the definition and requirements of ' high-quality liquid assets ' in the Hong Kong Regulatory Guidelines may be stricter and cannot simply copy the practices of other jurisdictions.

CNH stablecoin applicants should pay special attention to the fact that reserve assets ( CNH deposits or high-quality CNH bonds) must be deposited in qualified custodian banks in Hong Kong or major offshore RMB centers (such as Singapore, required approval by the HKMA). It is necessary to demonstrate to the HKMA that sufficient CNH liquidity contingency arrangements are available, such as signing a backup line of credit or liquidity support agreement with one or more banks with CNH clearing capacity to deal with large-scale redemptions or market liquidity tightness. Even if CNH is anchored , it is necessary to explain how to manage the potential exchange rate fluctuation risks between CNH and other major currencies (such as Hong Kong dollar, US dollar), especially in extreme cases such as capital controls or market intervention.

(2) Reference currency and consistency of reserve assets

Under the Ordinance, “Unless with the prior written approval of the Monetary Authority, a specified reserve asset pool must be held in the same reference asset as the specified stablecoin to which the pool related” , unless prior written approval from the Monetary Authority is obtained.

If a Hong Kong dollar stablecoin is issued, the reserve assets should in principle be Hong Kong dollar assets (such as Hong Kong dollar deposits). This is to avoid the risk of currency mismatch and ensure that it can be redeemed in full in Hong Kong dollars at any time. Hong Kong's linked exchange rate system also provides a relatively stable exchange rate environment for Hong Kong dollar stablecoins.

If you want to issue a US dollar stablecoin, but the reserve assets contain a large amount of Hong Kong dollar assets, or the RMB stablecoin is issued, but the reserve assets are US dollars, this constitutes a currency mismatch. In this case, it is not allowed unless the prior written approval of the HKMA is obtained. Even if approved, the issuer must demonstrate to the HKMA that it has the ability to manage the resulting exchange rate risks and may be required to be higher over-collateralized. The HKMA will be very cautious in approving such requests because it is directly related to the " stability " of the stablecoin .

(3) Isolation and safekeeping (Segregation and safekeeping)

According to the Regulatory Guidelines, “Reserve assets must be segregated from the issuer's own assets and the assets of other stablecoin arrangements, and held with a qualified custodian. The custodial arrangements must ensure that the reserve assets are protected in the event of the issuer's insolvency”. The custody arrangement must ensure that the reserve assets are protected in the event of bankruptcy of the issuer.

For many Web3 startups, their existing corporate structure may not be optimized for ' bank quarantine ' . Achieve effective bankruptcy segregation often means the need to establish independent special purpose entities ( SPVs ) with the sole purpose of holding reserve assets and establishing complete trust arrangements. This may involve complex legal structure design and company restructuring, requiring advance planning and corresponding costs. Finding and signing contracts for qualified custodians (usually licensed banks or trust companies with specific qualifications) that meet the requirements of the HKMA, especially for issuers with non-traditional financial backgrounds, may face certain negotiation difficulties and cost pressures. The terms of the custody agreement also require careful review to ensure compliance with regulatory requirements.

(4) Non-interest bearing on stablecoins

According to the Regulatory Guidelines, “A licensed stablecoin issuer must not pay any interest or similar return to stablecoin holders on their stablecoin holders” , licensed stablecoin issuers are not allowed to pay any interest or similar returns on their stablecoin holders.

The provisions to avoid any form of " interest-like " arrangement are to clarify the payment tool attributes of stablecoins, rather than investment products. Any behavior of paying returns to stablecoin holders in disguise through airdrops, pledge rewards, etc. may be deemed to be a violation of this provision, causing regulatory risks . Issuers need to carefully examine their business model to avoid touching this red line.

(5) Disclosure and reporting on reserve assets

According to the Regulatory Guidelines, “A licensed stablecoin issuer must provide regular and timely public disclosures on its reserve assets, including their composition, valuation, and the reports of independent auditors. It must also submit periodic reports to the Monetary Authority”. It also has to submit periodic reports to the Monetary Authority.

Obtaining a license is not a one-time solution. Issuers must be aware that the continuous meeting of frequent (daily, weekly, monthly, annual) and detailed disclosure and reporting requirements in the Regulatory Guidelines will bring huge operating costs and compliance pressures. This includes regular reserve asset forensics (usually issued by an accredited accounting firm), annual financial audits, AML/CFT system audits, technical system audits, etc.

The frequency and level of detail of public disclosures are demanding, aiming to give clear understanding of the status of reserve assets by the public and regulators. If abnormal data appears in the report (for example, the reserve coverage rate briefly falls below 100% , or the transaction monitoring system discovers a large number of suspicious transactions), it is crucial to report to the HKMA in a timely and transparent manner and actively propose effective remedial measures and explanations . Concealing or delaying reporting can lead to serious regulatory penalties. The HKMA has the right to conduct field inspections and temporary inquiries, and the issuer needs to be ready for review at any time and ensure that all records are complete and accurate.

3. A sound issuance, redemption and distribution mechanism

(Issuance, Redemption and Distribution)

The core requirements of a sound issuance, redemption and distribution mechanism are prudent issuance, efficient redemption at face value, prudent distribution, and compliant customer acceptance.

According to the Regulatory Guidelines, “Issuance must be conducted in a prudent manner. Redemption must be processed at par value and in a timely manner (eg, within T+1 business day). Distribution channels must be carefully selected and monitored. Customer onboarding procedures must comply with AML/CFT requirements”. Redemption must be processed in a timely manner at face value (for example, within T+1 working day). Distribution channels must be carefully selected and monitored. Client acceptance procedures must comply with the requirements for raising anti-money laundering / anti-terrorist funding.

The operating pressure of T+1 redemption requires the issuer to have efficient fund liquidation and liquidity management capabilities, which puts forward high requirements for both the operation team and the technical system. If stablecoins are distributed through third parties, the issuer needs to conduct due diligence on the distributor and clarify the responsibilities of both parties in AML/CFT , customer solicitation, etc. When issuing and redeeming stablecoins in primary markets, client due diligence procedures must be strictly implemented, which is closely related to AML/CFT requirements.

4. Strict risk management framework (Risk Management)

As the most important financial license in the web3 industry, the HKMA has made strict requirements on the risk management framework, and its core is that applicants should have comprehensive and commensurate risk management policies and procedures.

According to the Regulatory Guidelines, “A licensed stablecoin issuer must establish and maintain a comprehensive risk management framework, with policies and procedures proportionate to the scale, nature, and complexity of its operations. This includes, but is not limited to, operational risk, technology risk (including cybersecurity and smart contract risk), market risk, liquidity risk, legal and compliance risk, and custody risk” , Licensed stablecoin issuers must establish and maintain a comprehensive risk management framework whose policies and procedures should be commensurate with the scale, nature and complexity of their operations. This includes but is not limited to operational risks, technical risks (including cybersecurity and smart contract risks), market risks, liquidity risks, legal and compliance risks, and custody risks. ”

For any company in the financial industry, it is not easy to establish and maintain a comprehensive risk management framework, and as a financial license for the web3 industry, it is obviously more complicated. Simply put, stablecoin applicants should establish " three lines of defense " .

First of all, the first line of defense is the business department, which is the first person in charge of risk management, responsible for identifying, evaluating and managing risks in daily business activities.

The second line of defense is the independent risk management and compliance function, which should be responsible for formulating risk management policies, monitoring risk status, reporting risks to management and board of directors, and ensuring compliance. Risk management managers usually need to have many years of risk management experience in financial institutions or regulated virtual asset service providers, and be familiar with relevant risk measurement models and stress testing methods. Even in Hong Kong, there are not many people who meet the requirements. The compliance officer ( MLRO -Money Laundering Reporting Officer ) must have solid AML/CFT knowledge and practical experience, and those who hold relevant professional qualifications (such as CAMS ) must be preferred. The HKMA has high requirements for localization experience in this position and its understanding of Hong Kong's regulatory environment. The key to the independence of the second line of defense is that it can report directly to the board of directors (or its risk management committee / audit committee) without being disturbed by the business department. The appointment, dismissal and remuneration of its person in charge should be decided at the board level to ensure its objectivity.

The third line of defense is an independent internal audit department, which is responsible for independent assessment and auditing of the effectiveness of risk management and internal controls. The person in charge of internal audit should have a professional audit background and be familiar with the internal control and audit procedures of financial institutions or technology companies. The independence of the internal audit function is reflected in its direct reporting to the Board of Directors Audit Committee. In terms of staffing, it is possible to consider setting up a special internal audit position, or for smaller institutions, outsourcing this function to qualified independent third-party audit institutions on the premise of obtaining the consent of the HKMA. But even if outsourcing, the ultimate responsibility remains on the board. In addition, to strengthen the independence of corporate governance and internal audit, it is crucial to have a sufficient number of independent non-executive directors ( INEDs ) on the board , who usually play a key role in the Audit Committee and the Risk Management Committee. For non-accredited institutions, the guidelines recommend that at least one-third of INEDs be INEDs .

There are many difficulties in the actual implementation of the company's internal control, including technical aspects. For Web3 startups, although the concept of multiple signing is not unfamiliar with it, to meet regulatory-level security requirements (such as security environments, offline operations, geographical dispersion, regular rotation, emergency recovery plans, etc.), it is often necessary to make major upgrades to their existing IT systems, or even redesign the private key management architecture. This not only involves technical investment, but also requires the establishment of strict operating procedures and internal control mechanisms. Smart contract audit emphasizes continuity, not only audits before the stablecoin issuance and launch, but any subsequent upgrades and changes will require strict independent third-party audits to ensure safety. If you rely on third-party service providers (such as custodians, technical service providers), the issuer needs to conduct strict due diligence on them and establish an effective continuous monitoring mechanism to manage the resulting third-party risks.

5. Complete Corporate Governance

Corporate governance seems to be a cliché. In the context of applying for a stablecoin license, its core requirement is a sound governance structure and competent management personnel.

According to the Regulatory Guidelines, “A licensed stablecoin issuer must have a sound corporate governance structure, with clear lines of responsibility and accountability. Its directors and senior management must be fit and proper persons to hold their positions”. Its directors and senior management must be the appropriate candidates for their position.

So, what is the standard for " Fitness and Propriety" ? For key positions such as compliance officers ( MLROs ), risk management leaders, the HKMA usually expects candidates to have experience in the local financial industry in Hong Kong, or have a deep understanding of Hong Kong financial regulations (especially AML/CFT regulations), and hold relevant professional qualifications (such as Hong Kong lawyers, certified public accountants, CAMS , etc.). Personnel who rely entirely on overseas backgrounds, even if experienced, may be subject to a more scrutiny in adapting to the local regulatory environment. In response to overseas shareholding or complex parent company structures (such as controlling Hong Kong entities through VIE structures), applicants must be fully prepared to clearly and transparently disclose the complete information of the Ultimate Beneficial Ownership ( UBO ) to the HKMA and explain the commercial rationality of their company structure . Any attempt to blur or hide actual control may touch the regulatory redline . Applicants and their principal administrators need to demonstrate their good character, reputation and financial robustness, without a relevant criminal record or history of regulatory penalties.

Specifically, the portrait of KMP - Key Management Personnel is:

CEO ( CEO ): Usually, you need to have a considerable number of senior management experience in the financial services or financial technology field, have a deep understanding of the virtual asset industry, and have good business reputation and leadership skills. Past successful entrepreneurial experience or employment experience in well-known institutions will be a plus.

CFO ( CFO ): Need to have professional accounting qualifications (such as CPA ), be familiar with Hong Kong Financial Reporting Standards, have experience in managing complex financial operations (including reserve asset accounting processing, capital flow management) and accepting external audits.

CTO/CISO ( Technical Director / Chief Information Security Officer ): We must have deep professional knowledge and practical experience in virtual asset technology, blockchain security, network security, private key management, smart contract development and auditing. It is necessary to lead the design and maintenance of technical architectures and security systems that meet regulatory requirements.

MLRO ( Anti-money laundering report officer ): It has been detailed in the aforementioned " Three Lines of Defense " , emphasizing AML/CFT professional experience and localization awareness.

CRO ( Chief Risk Officer, if established ): Have comprehensive financial risk management experience and be able to establish and lead a second line of defense.

Applicants must expect that the HKMA will conduct very rigorous background checks on all nominated KMPs , including their past professional experience, professional ability, integrity records, financial status, etc. When forming a Hong Kong operation team, members with an international perspective and innovative capabilities are required, as well as local professionals who have a deep understanding of Hong Kong's local regulatory environment, legal system and market characteristics. This balance helps better communicate with regulators and ensures that business operates locally. A detailed organizational structure chart is required to clarify the responsibilities and reporting paths of each department to ensure that the decision-making process is clear and efficient.

6. Compliant business operations and ethics **(Business Practices

and Conduct)**

The core requirements of compliant business operations and ethics are: accurate recording, timely disclosure, protection of personal data, and proper handling of complaints.

According to the Regulatory Guidelines, “A licensed stablecoin issuer must maintain accurate and complete records of its operations. It must provide clear, accurate, and timely information to users. It must comply with personal data protection requirements. It must have effective mechanisms for handling user complaints”. It must provide users with clear, accurate and timely information. It must comply with personal data protection requirements. It must have an effective mechanism to handle user complaints.

The "Regulatory Guidelines" have very high requirements for the white paper. It is not just a technical manual or marketing material, it is also a legally binding business plan and compliance commitment . The white paper must disclose all key information to potential users and regulators in a clear, accurate, complete and non-misleading manner, including but not limited to:

1. Detailed information of the issuer (company structure, management team, financial status, etc.)
2. Design mechanism of stablecoins (anchored assets, technical standards, total issuance volume, etc.)
3. Detailed arrangement of reserve assets (constitution, custody, audit, valuation methods, etc.)
4. Issuance and redemption mechanism (process, fees, time, restrictions, etc.)
5. Technical details and safety measures adopted
6. Detailed disclosure of risk factors (this is the top priority and must be comprehensive and objective)
7. Overview of AML/CFT measures
8. User rights and complaint handling mechanism
9. Overview of the Orderly Exit Plan. It is worth noting that any exaggeration, opaque information or deliberately concealing risks in the white paper may lead to rejection of the application or subsequent regulatory actions.

In addition, the HKMA also requires applicants to comply with the requirements of the Hong Kong Personal Data (Privacy) Ordinance to ensure that the collection, use, storage and transmission of user personal data are compliant and legal. As well as establish clear and convenient complaint channels and ensure that complaints are handled in a timely and impartial manner.

7. Effective anti-money laundering and terrorist fundraising (

AML/CFT ) measures

AML/CFT is a crucial part of all financial license applications, and is a top priority in stablecoin license applications.

The AML Consulting Document clearly defines specific requirements for client due diligence (CDD) , continuous monitoring, suspicious transaction reporting (STR) , sanctions screening, employee training, record preservation, etc. For example, regarding risk assessment and mitigation measures for non-custodial wallets, regarding the adoption of risk-based approaches (RBA) , etc.

In order to effectively fulfill the obligations of transaction monitoring and wallet address screening, issuers usually need to purchase professional blockchain analysis tools. Mainstream tools on the market include Chainalysis ( such as its KYT products ), Elliptic, TRM Labs, Coinfirm , etc. When choosing, you need to consider the scope of the blockchain it covers, the accuracy of the risk score model, the integration capabilities with existing systems, and service support.

Purchasing AML tools is only the first step. More importantly, it is to establish a matching internal operating process, a clear risk escalation and handling mechanism, sufficient training for relevant personnel, and necessary manual review links. Technical tools are auxiliary, and ultimate judgment and decision-making still depend on trained professionals.

For interactions with non-custodial wallets, in addition to relying on blockchain analytics tools for risk assessment and monitoring, applicants can also consider clarifying risk warnings and user responsibilities in the user agreement, setting stricter limits for transactions in high-risk non-custodial wallets or conducting additional due diligence, and even refusing to trade with them in extreme cases. It is crucial to present a multi-level, multi-dimensional risk mitigation program to the HKMA.

Regarding the boundaries of monitoring responsibility for stablecoins circulating in secondary markets, the " AML Consulting Document" reflects the exploratory attitude of supervision. At this stage, applicants should adhere to the principle of best efforts , actively explore and adopt feasible technical solutions (such as continuously monitoring suspicious addresses and transaction models related to stablecoins) and cooperation mechanisms (such as sharing risk information with other VASPs ), and clearly explain its monitoring scope, methods, limitations and plans for continuous improvement to the HKMA.

In addition, MLRO is the core of AML/CFT work, and its qualifications and experience are crucial. Applicants should establish a comprehensive AML/CFT policy and procedures, including customer identity identification and verification, risk assessment, transaction monitoring, suspicious transaction reporting, sanctions compliance, employee training, recordkeeping, etc., and ensure that all relevant employees are aware of AML/CFT 's regulatory requirements and internal policies.

Application process, time estimates and common misunderstandings

1. Application process time estimate:

Based on the application experience of similar financial licenses in Hong Kong (such as VASP licenses for virtual asset service providers ), as well as the complexity and rigor of stablecoin licenses, a complete application cycle usually takes 6 to 12 months, or even longer . This process can be roughly divided into:

ØPre -communication and preliminary assessment phase (about 1-2 months): conduct preliminary communication with the HKMA (consider 's sandbox through the " stablecoin issuer " ), understand regulatory expectations, and whether self-assessment basically meets the core conditions.

ØFormal application materials preparation stage (about 3-6 months): This is the most time-consuming and labor-intensive stage, and requires the preparation of a large number of detailed documents, including business plans, white papers, risk management frameworks, compliance manuals, technical structure descriptions, financial forecasts, personnel background information, etc. It may be necessary to hire an external professional consultant to assist .

ØHKA Review and Inquiry Phase (approximately 2-4 months or longer): The HKMA will conduct strict reviews of submitted materials and may raise multiple rounds of questions and requirements for supplementary materials. The quality and speed of the response will affect the overall progress.

Ø License grant (if approved): The HKMA will not formally grant the license after all conditions are met.

Please note that this is just a rough estimate, and the actual time will vary depending on the complexity of the application case, the quality of material preparation, and the efficiency of communication with the regulatory authorities. In addition, the actual cycle may also change due to the HKMA review pace or policy adjustments .

2. Key considerations: Self-examination of “ **the degree of

fit between business model and regulatory requirements** ” :

When designing a stablecoin business model, applicants should take ' actively moving closer to regulatory requirements ' as their core principle, rather than trying to challenge the regulatory bottom line or find regulatory arbitrage space. For example, when choosing reserve assets, high-liquid and low-risk assets (such as short-term bank deposits, high-quality government bonds) clearly listed in the "Regulatory Guidelines" should be given priority.

For innovative stablecoins (such as CNH stablecoins and gold stablecoins), as mentioned earlier, extremely sufficient and rigorous argumentation materials must be prepared to prove to the HKMA that their risks are completely controllable and are not inferior to or even better than standard solutions in terms of stability, liquidity and investor protection. Never try blindly without doing enough homework.

3. Key considerations: Preparation of plan for " **exit

mechanism and consumer protection** " :

Although the Regulatory Guidelines have been mentioned, we strongly recommend that applicants prepare a detailed, clear and operational Wind - down Plan when submitting their application . This plan should specify in detail the circumstances under which the exit mechanism will trigger (e.g., persistent losses, insufficient reserves, regulatory requirements, etc.), as well as how to protect the legitimate rights and interests of stablecoin holders during the exit process, especially their right to be redeemed at face value, how to safely and orderly dispose of remaining reserve assets, and how to communicate with users and regulators. This is not only a regulatory requirement, but also an important indicator that reflects the issuer's responsible attitude towards consumers.

4. Common application misunderstandings and focus of the HKMA:

ØUnderstanding or avoiding risks: Attempts to cover up or weaken risks in business models and fail to conduct comprehensive and objective risk assessments and stress testing.

ØOverempt on " decentralization " and ignore issuer responsibilities: Even if blockchain technology is adopted, licensed stablecoin issuers are still centrally responsible and must assume core responsibilities such as reserve management, risk control, and compliance operations.

ØInadequate understanding and investment in AML/CFT measures: I believe that everything will be fine if I buy a set of software, and ignore the importance of supporting system construction, personnel training and continuous monitoring.

ØThe core team background does not match the business to be conducted : for example, the technical team is strong but lacks financial compliance experience, or management lacks awareness of virtual asset risks.

ØThe reserve asset plan is impractical or insufficiently proof : especially for innovative reserve assets, it has not been fully proved that they meet the requirements of " high quality, high liquidity, and low risk " .

Ø 公司治理结构不健全或透明度不足 ： 股权结构复杂且不透明，董事会缺乏独立性，内部制衡机制缺失。

Ø 白皮书内容空泛、夸大或存在误导性信息 。

Ø 与 监管机构沟通不积极、不透明，或对监管问询回复不及时、不充分 。

结语：香港稳定币之路，机遇与审慎同行，专业与合规并重

香港《稳定币条例草案》及其配套指引的出台，为稳定币在香港的合规发展奠定了法律基础，也为全球虚拟资产监管树立了新的标杆。对于Web3 行业的参与者而言，这既是巨大的机遇，也带来了前所未有的合规挑战。

申请香港稳定币牌照是一个系统性的工程，需要申请人具备充足的财务实力、稳健的储备管理能力、强大的技术安全保障、完善的风险管理和公司治理架构，以及对AML/CFT 合规的深刻理解和坚定执行。

正如我们所分析的，从公司内控的实际落地，到 “ 三道防线 ” 的精细化人员配置；从创新资产审批的极高门槛，到 “ 适当人选 ” 的严格标准；从持续合规的长期投入，到 AML/CFT 措施的深度实践；再到清晰的退出机制和透明的白皮书 —— 每一个环节都考验着申请人的专业能力、合规意识和长远眼光。

我们强烈建议有意向的申请人：

• 尽早规划，并寻求 Web3 行业经验丰富的法律、会计和合规专业顾问的协助。
• 以 “ 合规优先、风险可控 ” 为核心战略，主动拥抱监管。
• 对团队建设、技术投入和合规成本做好充分准备。
• 与香港金管局保持积极、透明和建设性的沟通。

香港的稳定币监管框架旨在促进负责任的创新，同时维护金融稳定和保护投资者。只有那些真正具备实力、坚守合规、并致力于为市场提供安全可靠稳定币产品的发行人，才能在这片充满机遇的土地上行稳致远。