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Hong Kong's deliberate scarcity: 36 stablecoin applications, a handful of licences

The HKMA received 36 applications and has signalled it will grant very few. Restricting supply is a legitimate supervisory strategy, and it is the opposite of the approach the EU has just finished testing.

6 min readTGMRC Advisory

Hong Kong's Stablecoins Ordinance took effect on 1 August 2025. The Hong Kong Monetary Authority received 36 applications and has been clear about what happens next: only a very small number of licences will be granted in the first batch, expected in March 2026.

Stablecoin issuer applications received
36Stablecoin issuer applications received
Minimum paid-up capital for an issuer
HK$25mMinimum paid-up capital for an issuer
Required frequency of reserve disclosure
DailyRequired frequency of reserve disclosure

Two regulators, two perimeters

Hong Kong runs a dual-licensing structure. The Securities and Futures Commission licenses virtual asset trading platforms; the Monetary Authority licenses stablecoin issuers. The split follows function rather than technology: market conduct and investor protection sit with the securities regulator, monetary and payment-system risk sits with the central bank. Proposals to regulate virtual asset dealers and custodians are slated for the Legislative Council during 2026, extending the same logic.

The issuer requirements are conventional central-bank requirements rather than novel crypto ones: HK$25m paid-up capital, reserves in cash or near-cash high-quality liquid assets, daily reserve disclosure, strong redemption rights and AML/CFT controls. The applicant list reflects that framing: Standard Chartered, Ant Group and JD.com are among those that applied.

Scarcity as a supervisory decision

Granting a small number of licences is often read as protectionism. It is more usefully read as a capacity statement. A stablecoin issuer requires continuous supervision: reserve composition, redemption performance under stress, custody arrangements, and the operational capability to meet redemptions on a bad day. That is intensive, and a supervisor that authorises more issuers than it can genuinely watch has not created a market: it has created a list.

Authorise what you can supervise. A licence the regulator cannot stand behind is worth less than no licence at all, because it carries an implied assurance nobody is actually providing.

The contrast with Europe is instructive. MiCA's transitional period closed on 1 July 2026 with roughly 204 authorised crypto-asset service providers out of more than 1,200 previously registered firms: an outcome that emerged from processing pressure rather than from a stated policy of restriction. Hong Kong has arrived at a small licensed population too, but by declaring it in advance. Firms could price the odds before spending on an application.

Neither model is inherently better. But announcing scarcity is more honest than producing it accidentally, and it is considerably easier to defend when the unsuccessful applicants ask why.

Sources

  1. 01Hong Kong implements new regulatory framework for stablecoins (Sidley Austin)
  2. 02Hong Kong's virtual assets licensing regime: what lies ahead in 2026 (King & Wood Mallesons)
  3. 03Hong Kong regulators target 2026 legislation for virtual asset dealer and custodian rules (CoinDesk)

This article is analysis, not legal advice. Regulatory positions change; verify against the relevant authority before acting.