License follows
behind the product function

01

“Payment company” is not the name of the license

One interface can connect several adjustable functions. Stored value, remittance, FX, securities dealing, custody, automated trading and fiat-referenced stablecoin release are analyzed separately. White-label provider or foreign the license does not exclude Hong Kong requirements if the activity is carried out here or is actively offered to local clients.

02

Accepting deposits: three levels of authorization

Banking Ordinance provides for licensed banks, restricted license banks and deposit-taking companies. HKMA checks controllers, directors and chief executives, capital, financial stability, home supervision of a foreign bank, management risks, internal controls and ability to comply with requirements constantly, and not just on the day the authorization is issued.

Licensed bank

Minimum capital HK$300 million; full banking perimeter

Restricted licence bank

Minimum capital HK$100 million; limited deposit-taking business

Deposit-taking company

Minimum capital HK$25 million; specialized deposit perimeter

Digital bank

Not a separate light license: authorized institution criteria apply

03

Stored Value Facility: e-wallet and prepaid products

Multi-purpose facility in which monetary value is stored and which is used by third parties or for P2P payments, usually falls under the SVF license under Payment Systems and Stored Value Facilities Ordinance. Single-purpose prepayment to the issuer only, as well as means of payment without stored-value function are analyzed otherwise.

Product

Wallet, prepaid card or other facility with stored monetary value

Float

Security and separation of user funds

Controls

Security, resilience, AML/CFT, complaints and reconciliation

Register

Legal entity and license number are verified in the HKMA SVF Register

04

MSO: transfers and currency exchange without a banking license

Remittance service and money changing service are regulated Commissioner of Customs & Excise by AMLO. The applicant submits business plan and AML/CFT policy, discloses directors, partners and ultimate owners, confirms fit and proper status and suitable room. The MSO license does not allow accepting deposits, issuing SVF or conduct securities business.

05

SFC: function is more important than technological shell

Dealing, advising, asset management, automated trading, corporate finance and other regulated activities are verified by Securities and Futures Ordinance. Designed for licensed corporation responsible officers, competence, substantial shareholders, capital, premises, custody, conflicts, outsourcing, cybersecurity and client documentation.

Type 1

Dealing in securities

Type 4

Advising on securities

Type 7

Providing automated trading services

Type 9

Asset management

The activity number should not be chosen by its short name: boundaries, exemptions and licensing conditions are determined by real functions, assets, clients and execution method.

06

VATP: centralized platform and custody

Centralized virtual asset trading platform, leading business in Hong Kong or actively offering services to local investors, should analyze the SFO and AMLO regimes. For security tokens Type 1 and Type 7 are applicable; for non-security tokens - VASP regime by AMLO. The SFC recommends that platforms provide both perimeters, as the token classification may change.

Application includes policies and procedures and independent external assessment. Licenses continue to be valid after issuance requirements for custody, token admission, market surveillance, conflicts, cybersecurity, AML/CFT and key personnel.

07

Stablecoin issuer: separate HKMA license

Stablecoins Ordinance is effective from August 1, 2025 and introduces mode for regulated activities with specified fiat-referenced stablecoins. Reserve assets, redemption, governance, risk management, technology, AML/CFT, disclosure and local operational readiness.

This is the composition of the official register as of the date of inspection. Before public license or application statements must be verified current register: false statement of status is prohibited.

08

License and access to payment infrastructure are different issues

Hong Kong supports HKD, USD, EUR and RMB RTGS, Faster Payment System and related clearing arrangements. Direct access depends on participant status, approvals and operator rules; many fintech use sponsor bank or licensed SVF arrangement.

FPS

24/7 transfers, P2P, merchant payments and wallet top-up via members

RTGS

Settlement in HKD, USD, EUR and RMB with secure finality

Payment Connect

Since 2026, links Hong Kong FPS and Mainland IBPS for allowed cross-border payments

Correspondent bank

We need a separate onboarding, liquidity and transaction-monitoring model

09

Route from product to license

1. 01
   Funds-flow map

   Who receives the money, who owns it, and when the obligation to repay arises.

2. 02
   Perimeter memorandum

   Banking, SVF, MSO, SFC, VATP, stablecoin and applicable exclusions.

3. 03
   Regulatory engagement

   Preliminary discussion of the model with the competent authority, where appropriate.

4. 04
   Application file

   Ownership, controllers, business plan, forecasts, policies, systems and key persons.

5. 05
   Operational readiness

   Vendor due diligence, testing, safeguarding, reporting and incident response.

10

What should work on the first operating day

Application cannot be built as a presentation of future intentions. The regulator and banking partners expect agreed operating model, contracts, designated responsible persons, working procedures and provable capital runway.