Hong Kong SFC Launches ASPIRe Regulatory Roadmap for Virtual Asset Markets, February 2025

On 19 February 2025, the Securities and Futures Commission of Hong Kong (SFC) published a policy statement titled "A-S-P-I-Re for a brighter future: SFC's regulatory roadmap for Hong Kong's virtual asset market." The Roadmap sets out 12 concrete initiatives organized under five pillars: Access (A), Safeguards (S), Products (P), Infrastructure (I), and Relationships (Re). It is an active regulatory commitment at the policy statement stage, not a binding rule or final regulation. Individual initiatives within the Roadmap require separate consultations, legislative action, or formal licensing regime development before taking legal effect.

The Roadmap is issued under the SFC's authority as Hong Kong's regulator for securities and futures under the Securities and Futures Ordinance (Cap. 571). Current licensing of virtual asset trading platform operators (VATPs) operates under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and the Securities and Futures Ordinance. Pillar A (Access), Initiative 1 commits the SFC to support the HKSAR Government in establishing dedicated licensing regimes for virtual asset OTC trading and custody services, with legislative preparations targeting completion by end-2025. Pillar P (Products), Initiative 6 proposes regulatory exploration of new token listings and derivative trading for professional investors (as defined in Schedule 1 to the Securities and Futures Ordinance), and Initiative 8 addresses staking and borrowing/lending services. Pillar S (Safeguards) targets custody technology standards and insurance/compensation arrangements. Pillar I (Infrastructure) covers straight-through regulatory reporting and advanced surveillance tools under Initiative 9, and cross-agency collaboration under Initiative 10.

VATP operators, OTC dealers, custodians, staking service providers, and virtual asset lending businesses operating in or targeting Hong Kong must monitor the Roadmap's implementation timeline. VATPs already licensed under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance face the most immediate changes: the Roadmap signals a shift from prescriptive cold-storage ratios toward outcome-based custody standards and a relaxation of rigid margin requirements for professional investors. OTC trading desks not currently licensed will need a dedicated licence once HKSAR Government legislation proceeds. Staking service providers and borrowing/lending platforms targeting Hong Kong-based professional investors must await SFC guidance before offering those services through or in connection with licensed VATPs.

The Roadmap does not impose legal obligations; each initiative advances through separate processes. Initiative 1 (OTC and custody licensing) requires HKSAR Government-led legislation, with statutory implementation a 2026 or later event. Existing cold-storage ratio requirements and compensation mandates remain operative until formally amended. Decentralized exchanges and DAO-operated protocols fall outside the current VATP licensing perimeter, and the Roadmap does not explicitly address those, leaving their regulatory treatment unresolved. A February 2026 Policy Statement on virtual asset perpetual contracts, issued under Pillar P, demonstrates the SFC is actively advancing individual product initiatives at pace.

Source: Securities and Futures Commission of Hong Kong, "A-S-P-I-Re for a brighter future: SFC's regulatory roadmap for Hong Kong's virtual asset market," Policy Statement, 19 February 2025; last updated 23 September 2025. Official URL: https://www.sfc.hk/en/News-and-announcements/Policy-statements-and-announcements/A-S-P-I-Re-for-a-brighter-future-SFCs-regulatory-roadmap-for-Hong-Kongs-virtual-asset-market. Confirmed: 5 March 2026.

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