An HKMA stablecoin license is the authorization the Hong Kong Monetary Authority (HKMA, the territory's monetary authority) grants under the Stablecoins Ordinance (Cap. 656) to a company that issues fiat-referenced stablecoins in Hong Kong, or Hong Kong dollar stablecoins from abroad. The regime has applied since August 1, 2025, and the register listed two licensees on November 1, 2026.
The license attaches to the issuer, not to the coin, the payment or the business that pays with it. That decides what a payments team asks about Hong Kong: whether a supplier's token is licensed, whether a foreign issuer needs a license, and whether the Ordinance reaches a company that only pays in a stablecoin. This post reads the HKMA's own texts and says where it stops.
What the Stablecoins Ordinance covers
The HKMA's regime page for stablecoin issuers states that since August 1, 2025 issuing fiat-referenced stablecoins is a regulated activity in Hong Kong and a license is required. Fiat-referenced is the narrow case: a token that purports to keep a stable value by reference wholly to one or more official currencies. The explainer on what a stablecoin is covers the product in general, and the Ordinance regulates a subset of it. Our news posts on bank-issued stablecoin wallets in Hong Kong, Circle and Hong Kong and Asian regulatory milestones cover the surrounding events.
The HKMA's Explanatory Note on Licensing of Stablecoin Issuers (July 2025) walks through the definitions. A person carries on a "regulated stablecoin activity" under section 5 in three cases: it issues a specified stablecoin in Hong Kong in the course of business, it issues one outside Hong Kong that purports to keep a stable value by reference, wholly or partly, to the Hong Kong dollar, or it carries on an activity the HKMA has specified. Section 8 makes it an offence to carry on, or hold oneself out as carrying on, that activity without a license or an exemption. The note does not state the sanction, so the penalty is a question for counsel.
Whether a coin is issued "in Hong Kong" is decided case by case. The note says a coin is typically considered issued when it is first recorded on a distributed ledger and assigned to a wallet address, and the HKMA looks at where the issuer is managed and incorporated, where minting and the reserve sit, and where the bank accounts are. No single factor is conclusive.
Who holds an HKMA stablecoin license today?
Two companies, on the register as we read it on November 1, 2026. The HKMA announced the grants on April 10, 2026 and the licenses took effect that day.
Licensees on the HKMA Register of Licensed Stablecoin Issuers, read November 1, 2026 (register page last revised April 23, 2026).
Licensee | License number | Effective date |
Anchorpoint Financial Limited | FRS01 | April 10, 2026 |
The Hongkong and Shanghai Banking Corporation Limited | FRS02 | April 10, 2026 |
The register is open to public inspection. The list is short by design: on August 14, 2025 the HKMA's chief executive said only a handful of licenses would be granted initially.
Issuers already operating before the start date had a dated path. Under Schedule 7, as the HKMA's Explanatory Note on Transitional Provisions (July 2025) describes it, a pre-existing issuer had to apply, with a declaration and an undertaking to comply as if licensed, by October 31, 2025, and could continue until January 31, 2026 if it had done so. After that date the register is the list. Lumx keeps no list of licensed coins, so a client that needs to confirm one reads the register.
What does the HKMA require before it grants a license?
The minimum criteria sit in Part 2 of Schedule 2 to the Ordinance, and the HKMA's note and guidelines turn them into expectations.
Licensing criteria as described by the HKMA, Explanatory Note on Licensing (July 2025) and Guideline on Supervision of Licensed Stablecoin Issuers.
Area | What the HKMA states |
Corporate status | A company incorporated in Hong Kong, or an authorized institution incorporated elsewhere. Other foreign institutions incorporate a Hong Kong subsidiary as the applicant. |
Financial resources | Paid-up share capital of at least HKD 25,000,000, or approved financial resources of at least that amount, at all times. |
Reserve assets | A segregated pool per type of coin, with market value at all times at least equal to the par value in circulation, in high quality, liquid assets held on trust. |
Redemption | A right to redeem at par, without unreasonable fees or burdensome conditions. Valid requests should be processed within 1 business day unless otherwise approved. |
Reporting | Daily statements of coins in circulation and reserve value, weekly reporting to the HKMA and on the issuer's website, and regular attestation by an independent auditor. |
People | Chief executive, directors, stablecoin managers and controllers must be fit and proper. |
Per the note, an applicant is encouraged to hold an informal discussion with the HKMA Licensing Team, then submits the forms and the 23 items of documents in its Annex B. A Stablecoin Advisory Committee considers every application, and the note gives no processing deadline.
For a payments company the reserve and redemption rows matter most: they make a licensed coin redeemable at par on a stated timetable, which a treasury team can price. Redemption is the holder's right against the issuer, not a payout service. On the Lumx side the payout is an off-ramp from the customer's wallet to a verified destination, and the coverage page shows which currencies and rails it can end in.
Foreign issuers and how coins are offered
The Ordinance reaches past the border in one direction. Under section 5 an issuer abroad whose coin is referenced partly or wholly to the Hong Kong dollar is carrying on a regulated activity, and the Government's May 21, 2025 release on the Bill's passage says the same. "Holding out" reaches further: under section 5(2), a person that actively markets to the public, in Hong Kong or elsewhere, an activity that would be regulated if done in Hong Kong is treated as carrying it on.
The regime also governs how a coin reaches the public. Under section 6, a person offers a coin when it communicates enough about the coin, its terms and its channels for someone to decide to acquire it. Under section 9(2), a licensee may engage only a "permitted offeror": another licensee, an authorized institution under the Banking Ordinance, a stored value facility licensee, a virtual asset trading platform licensed by the Securities and Futures Commission, or a corporation licensed for Type 1 regulated activity. The May 21, 2025 release adds that only a licensed issuer's coin may be offered to a retail investor and that only advertisements of licensed issuance are allowed.
A wallet or payments app that presents an unlicensed fiat-referenced coin to Hong Kong retail users is in the territory these provisions were written for. A business that sends a stablecoin payment to its own supplier is not described in the HKMA documents we read as an issuer, offeror or advertiser. Lumx is not an issuer and holds no HKMA license; it serves Hong Kong clients by reverse solicitation. It is the conversion and payout layer a client builds on, converting to and from USDC and USDT, and the client decides which coin it presents to its users.
The Brazil regulation guide shows a different design, where the provider is the licensed party. For the three-jurisdiction comparison, see UK, Singapore and Hong Kong compared.
What the anti-money-laundering guideline asks of issuers
The HKMA's Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for Licensed Stablecoin Issuers (August 2025) is the compliance text a counterparty will cite. It covers risk assessment, customer due diligence, monitoring, stablecoin transfers, sanctions, suspicious transaction reports and record keeping. Its transfers chapter applies the travel rule (the requirement to pass originator and beneficiary data with a transfer). An issuer must identify a customer's wallet address and ascertain that the customer owns or controls it. For custodial wallet providers, or self-hosted wallets used by financial institutions or VASPs (virtual asset service providers, the FATF term), it must understand the owner and assess its AML controls.
Lumx runs KYB (know your business, the verification of a company and its owners) and KYC (know your customer, the verification of an individual) before a customer transacts, and each payout destination is verified before it can be used.
What a Hong Kong supplier question turns on
<!-- OPERATOR PARAGRAPH --> I would not take "licensed" from a supplier's invoice note, a press mention or a wallet app. I would take it from the register, and I would write the license number and the date of the check into the supplier file. The register is public and gives a name, a number and an effective date, and it is the one place where the HKMA says who holds a license. The check is yours to make, and it belongs in the file before the first payment.
The register answers one question and leaves another. A Hong Kong company can still receive coins from issuers that are not on it, because holding or receiving is not the regulated activity. The HKMA warns that unlicensed stablecoins are held at the holder's own risk. The mainland is a different answer: a supplier in mainland China is paid in USD by SWIFT, because the People's Bank of China's notice Yinfa [2026] No. 42 of February 6, 2026 prohibits foreign crypto services to people there. The steps are in paying suppliers in China from Brazil, and the Hong Kong supplier guide covers the payment itself.
When the HKMA regime is the wrong question
When you only pay or collect. A company that sends or receives stablecoin payments through a provider is not issuing, offering or advertising under the texts above.
When you want to be the issuer. The question is then the application: a Hong Kong company or subsidiary, HKD 25,000,000 of capital or equivalent resources, a segregated reserve and a redemption mechanism the HKMA accepts. Lumx's docs list stablecoin issuers among the high-risk activities allowed with disclosure and Enhanced Due Diligence, so an issuer should expect a deeper review than a standard one.
When the question is a reserve on a given day. A license shows the HKMA found the issuer met its criteria, not the state of the reserve today.
What this looks like for a business paying or collecting in Hong Kong with Lumx
Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.
The coverage page lists Hong Kong among the Asia Pacific countries where Lumx supports payments (as of November 2026). It shows no Hong Kong dollar rail. A payout to a Hong Kong company goes out in USD over SWIFT to its USD account, which is how Lumx's marketplace guide treats sellers in Hong Kong, and a Hong Kong company that wants a stablecoin receives it as a transfer to an external wallet. A Hong Kong company can also be a paying customer: it goes through standard KYB, while mainland China is a high-risk country. The operator map shows which entity performs each leg, the supported countries page states jurisdiction tiers, and the global payments page covers payouts.
Lumx has no license from the HKMA, MAS or FCA. It onboards Hong Kong clients by reverse solicitation and does not market or prospect in Hong Kong. It takes no position on whether a coin is HKMA-licensed; that status is the register's to state. Its docs list USDC and USDT as the stablecoins on the platform.
Methodology and sources
Every statement about the Hong Kong regime comes from texts on hkma.gov.hk read on November 1, 2026: the regime page (last revised July 13, 2026), the Register of Licensed Stablecoin Issuers (last revised April 23, 2026), the Explanatory Note on Licensing and the Explanatory Note on Transitional Provisions (July 2025), the Guideline on Supervision, the AML/CFT Guideline (August 2025) and the press releases of May 21, 2025, July 29, 2025, August 14, 2025 and April 10, 2026. Section numbers are the ones those documents cite. The Hong Kong e-Legislation site, where the Ordinance is linked above, served only a loading page to our checker, so we did not read the Ordinance text itself. Lumx statements were checked on docs.lumx.io and lumx.io/coverage the same day.
Verified on November 1, 2026. Operational context, not legal, tax, or investment advice. Stablecoins Ordinance (Cap. 656) as described in the HKMA's Explanatory Notes, guidelines and press releases, checked against hkma.gov.hk on November 1, 2026. Register of Licensed Stablecoin Issuers checked against hkma.gov.hk on November 1, 2026.
Cover photo: Margaret Giatras on Unsplash.
Who needs an HKMA stablecoin license?
A company that issues a fiat-referenced stablecoin in Hong Kong in the course of business needs one, and so does a company that issues a coin abroad that purports to keep a stable value by reference, wholly or partly, to the Hong Kong dollar. Under the Stablecoins Ordinance (Cap. 656), carrying on that activity or holding oneself out as doing so without a license is an offence. A Lumx customer that only pays through the platform is not in that position: Lumx issues no coin of its own and holds no HKMA license.
Which companies hold an HKMA stablecoin license today?
On the HKMA register read on November 1, 2026, two: Anchorpoint Financial Limited (FRS01) and The Hongkong and Shanghai Banking Corporation Limited (FRS02), both effective April 10, 2026. Before a Lumx payout to a Hong Kong counterparty, the customer's KYB is complete and the payout destination is verified; the license check on any coin is a separate read of the register.
Is USDT or USDC licensed in Hong Kong?
Not by the register as read on November 1, 2026: it lists two licensees, and Circle and Tether are not among them. The HKMA said on July 29, 2025 that holders of unlicensed stablecoins hold them at their own risk, and holding or receiving a coin is not itself the regulated activity. For Hong Kong payouts, Lumx's marketplace guide sends USD over SWIFT to a USD account, and a company that wants a stablecoin receives it as a transfer to an external wallet.
Does a foreign stablecoin issuer need an HKMA license to reach Hong Kong users?
It can. A coin referenced to the Hong Kong dollar needs a license wherever it is issued, and actively marketing a regulated activity to the Hong Kong public counts as holding out. For a client serving Hong Kong users, Lumx supplies conversion and payout behind the client's product, and the client chooses which coin to present.
Does the Stablecoins Ordinance regulate a business that pays suppliers in stablecoins?
The HKMA texts we read regulate issuers, the offering of coins and their advertising, and set an AML guideline for licensees. They do not describe a rule for a business paying its own supplier, and we did not read the Ordinance itself, so Hong Kong counsel should confirm a specific flow. A Lumx customer completes KYB before transacting, has each payout destination verified, and pays Hong Kong suppliers in USD over SWIFT or by transfer to an external wallet.
