Hong Kong SFC Launches Secondary Trading Framework for Tokenised Investment Products in April 2026

On April 20, 2026, the Hong Kong Securities and Futures Commission (SFC) issued a circular establishing a new pilot regulatory framework permitting secondary trading of tokenised SFC-authorised investment products. The framework is final and effective upon the circular's issuance date. It represents the first time the SFC has created a dedicated infrastructure for trading tokenised open-ended funds on SFC-licensed virtual asset trading platforms (VATPs).

The controlling authority is the SFC circular dated April 20, 2026 (SFC Press Release No. 26PR59), issued under the Securities and Futures Ordinance (Cap. 571). The framework builds on two earlier SFC circulars issued on November 2, 2023: the "Circular on tokenisation of SFC-authorised investment products" and the "Circular on intermediaries engaging in tokenised securities-related activities." The new circular permits 24/7 secondary trading and authorises the use of regulated stablecoins — defined as fiat-referenced stablecoins issued under a licence granted under the Stablecoins Ordinance — as well as tokenised deposits to facilitate round-the-clock settlement.

VATPs licensed by the SFC may now offer secondary trading of tokenised open-ended funds subject to compliance measures covering fair pricing, orderly trading, liquidity provision, and disclosure. The SFC may also consider over-the-counter secondary trading arrangements on a case-by-case basis. As of March 2026, 13 tokenised products were authorised for public offering in Hong Kong, with assets under management of their tokenised share classes growing approximately sevenfold to HK$10.7 billion over the prior year. The initial product scope focuses on tokenised money market funds. Product issuers and licensed intermediaries, including VATPs, are expected to consult or notify the SFC prior to launching activities under this framework.

The framework applies exclusively to SFC-authorised investment products that have been tokenised. Products not yet tokenised, and products not carrying SFC authorisation, fall outside its scope. The SFC has reserved discretion to expand the eligible product range following a review of initial operational experience. No transition period is stated; compliance is required at inception for any participant entering this pilot.

Our firm advises on digital asset regulatory compliance, virtual asset trading platform licensing, tokenisation structures, and cross-border financial services in the Asia-Pacific region. We maintain a dedicated partner network covering Hong Kong and major Asia-Pacific jurisdictions and welcome inquiries from issuers, VATP operators, and fund managers seeking guidance on this framework. Relevant matters we handle include: tokenised fund structuring, VATP licensing, stablecoin regulatory compliance, securities tokenisation, and SFC authorisation.

Source: Securities and Futures Commission of Hong Kong, Press Release No. 26PR59, "SFC unveils new regulatory framework to allow secondary trading of tokenised SFC-authorised investment products," April 20, 2026. Available at: https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=26PR59. Confirmed April 24, 2026.

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