Hong Kong SFC Permits VA Brokers to Offer Margin Financing and Shared Order Book Access, February 2026

The Hong Kong Securities and Futures Commission issued Circular SFO/IS/005/2026 on 11 February 2026, establishing the conditions under which licensed corporations providing virtual asset dealing services under omnibus account arrangements (VA brokers) may offer margin financing to clients for virtual asset trading and may route client orders through shared order books operated by affiliated virtual asset trading platform operators (VATPs). The circular takes effect as supervisory guidance under the Securities and Futures Ordinance (Cap. 571) and applies immediately to VA brokers licensed or registered under that statute.

The controlling authority is the Terms and Conditions for Licensed Corporations or Registered Institutions Providing Virtual Asset Dealing Services under an Omnibus Account Arrangement (the "Terms and Conditions"), paragraph 4.4 of which previously prohibited any financial accommodation for VA acquisition. Circular SFO/IS/005/2026 amends that prohibition by permitting VA financing where the client is already a securities margin financing client of the VA broker and posts sufficient collateral. Eligible VA collateral is limited to bitcoin and ether, and the VA broker must apply a haircut of 60% or more to the market value of VA collateral. The SFC also stated that the full Guidelines for Securities Margin Financing Activities (SMF Guidelines) continue to apply, with their principles extended to VA financing and VA collateral.

VA brokers that engage in VA financing must assess client financial capability with specific regard to VA volatility, digital asset sector concentration risk, idiosyncratic risks such as infrastructure failure, and correlations between VA prices and equities in stress scenarios. A VA broker may permit clients to trade on a Shared Order Book only after disclosing to those clients the additional settlement and cross-border risks, and only upon the client's express election to participate. Responsible Officers and the manager-in-charge of risk management bear individual accountability for implementing these controls.

Until the SFC revises the Securities and Futures (Financial Resources) Rules, VA collateral held against VA financing positions is subject to a 100% haircut for capital adequacy purposes, effectively meaning VA collateral provides no capital relief to VA brokers at this stage. The SFC stated it will consult on revised capital requirements in due course.

Source: Securities and Futures Commission, Circular SFO/IS/005/2026, "Circular on licensed corporations providing virtual asset dealing services (1) to offer financing for virtual asset dealing and access to shared order book, and (2) to safeguard client virtual assets relating to withdrawals," issued 11 February 2026. Official URL: https://apps.sfc.hk/edistributionWeb/gateway/EN/circular/intermediaries/supervision/doc?refNo=26EC5. Confirmed 19 March 2026.

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