State of Play

Who can do what: virtual asset licensing

Latest change ·

First version, covering India, Singapore and Hong Kong.

Sources: fiuindia.gov.in, mas.gov.sg, info.gov.hk

Which licence an exchange, broker, custodian or asset manager needs in India, Singapore and Hong Kong

As of 30 September 2026, Hong Kong and Singapore license crypto businesses activity by activity, and India registers them for anti-money laundering (AML) purposes only. Hong Kong licenses trading platforms and stablecoin issuers today, and has confirmed four more regimes, for dealers, custodians, advisers and managers, that await a bill in 2026. Singapore licenses digital payment token services under the Payment Services Act and, since June 2025, Singapore firms serving only overseas customers under the Financial Services and Markets Act. India has no licensing law, and FIU-IND registration is the only binding requirement.

Side by side

India Singapore Hong Kong
Exchanges FIU-IND registration Payment Services Act licence for digital payment token services SFC licence for virtual asset trading platforms
Brokers and dealers FIU-IND registration Payment Services Act licence Existing securities licence with SFC conditions; dealer regime to come
Custodians FIU-IND registration Payment Services Act licence (custodian wallet services) Through licensed platforms and banks; custodian regime to come
Asset managers No specific rule Capital markets services licence for tokenised securities Existing Type 9 licence above a 10% threshold; manager regime to come with no threshold
Firms serving only overseas clients Must register if serving Indian users, wherever based Must hold a DTSP licence, which MAS says it will generally not grant Not applicable
Banks No framework Must notify and engage MAS before taking on crypto exposure HKMA-registered institutions under joint SFC and HKMA circulars

By market

India

India has no law that licenses crypto businesses. Providers of exchange, transfer or safekeeping of virtual digital assets must register with the Financial Intelligence Unit (FIU-IND) as reporting entities under the Prevention of Money Laundering Act, and follow its January 2026 AML guidelines. Registration carries AML duties, not conduct, capital or custody rules.

FIU-IND applies registration to offshore platforms that serve Indian users. In September 2026 it issued notices to 15 unregistered providers and sought takedown of their apps and websites, stating that the obligations “are activity-based and are not contingent on physical presence” (PIB release). Earlier rounds targeted nine platforms in December 2023 and 25 in October 2025.

Singapore

The Monetary Authority of Singapore (MAS) licenses dealing in, exchanging, transferring and safekeeping digital payment tokens under the Payment Services Act 2019. Its guidelines on providing these services to the public restrict how licensees market to retail customers. Tokens that are capital markets products, such as tokenised securities and fund units, fall under the Securities and Futures Act and its licences instead.

Since 30 June 2025, Singapore firms that provide digital token services only to customers outside Singapore need a licence under Part 9 of the Financial Services and Markets Act. MAS said it will generally not grant one, because it cannot supervise business carried on elsewhere, and existing firms of this kind had to stop. Stablecoin issuers will need a new licence once the Payment Services Act amendments pass.

Hong Kong

Virtual asset trading platforms have needed a licence from the Securities and Futures Commission (SFC) since June 2023. The SFC keeps a list of licensed platforms. In February 2026 it allowed crypto margin financing by brokers, affiliated market makers and perpetual contracts for professional investors. Stablecoin issuers need an HKMA licence under the Stablecoins Ordinance (Stablecoin rules).

Four more regimes are confirmed and wait for legislation. The Financial Services and the Treasury Bureau and the SFC concluded consultations on dealer and custodian regimes in December 2025, the dealer regime closely aligned with Type 1 (dealing in securities). In May 2026 they confirmed advisory and management regimes modelled on Types 4 and 9, with no de minimis threshold for managing crypto. A bill covering all four is targeted for the Legislative Council in 2026. Banks deal in and custody crypto as registered institutions under joint SFC and HKMA circulars, and follow the HKMA’s custody standards.

For Ethereum

Hong Kong’s advisory and management conclusions keep staking open to SFC-authorised crypto funds and do not restrict private funds from staking (para 50), and treat automated tools that make discretionary decisions as management (para 40), which would reach on-chain vault strategies run for Hong Kong clients. India’s September 2026 notices name hosted swap services alongside exchanges, so a service that swaps one token for another must register. The notices do not address self-custodial wallets or front-ends to on-chain protocols.

Open questions

  • Whether India legislates a licensing regime, and which regulator it names. A Parliamentary Standing Committee on Finance study of virtual digital assets was under way in 2026.
  • Whether Hong Kong grants a transition period to Type 9 managers now below the 10% threshold.

Next milestones

  • 2026: Hong Kong bill for the dealer, custodian, adviser and manager regimes.
  • 16 October 2026: comments close on Singapore’s stablecoin licence.
  • Ongoing: FIU-IND enforcement against unregistered offshore platforms.

Regulatory Wire items on this topic

India · FIU-IND · Enforcement

FIU-IND issues non-compliance notices to 15 offshore crypto platforms and seeks takedown of their apps and sites

In force · Applies to VASPs

FIU-IND issued notices under section 13 of the Prevention of Money Laundering Act to 15 crypto service providers operating in India without registering as reporting entities. It also issued takedown notices under the Information Technology Act for their apps and websites. The list includes exchanges such as Weex, Blofin, XT.com and WhiteBIT, and swap services such as ChangeNow, SimpleSwap and FixedFloat.

Why it matters: FIU-IND now names swap services alongside exchanges, which widens the practical reach of India's registration requirement.

For Ethereum: Instant swap services that exchange one token for another count as crypto service providers in India and must register, even without an Indian presence.

Source: FIU-IND · Archived copy

Updates: Who can do what: virtual asset licensing

Hong Kong · SFC and HKMA · Circular

SFC and HKMA lighten intermediary rules for stablecoins from licensed issuers

Final · Applies to VASPs, Brokers, Banks, Stablecoin issuers, Retail

The SFC and HKMA issued parallel circulars for platforms, brokers and banks dealing in stablecoins issued by HKMA-licensed issuers. These stablecoins are exempt from the token liquidity and index tests, the crypto knowledge test for stablecoin-only clients, and client exposure limits. Intermediaries may also partner with the licensed issuer directly and custody clients' stablecoins with it.

Why it matters: Hong Kong now treats a licensed stablecoin as a payment instrument for distribution purposes, which is what issuers need for retail reach.

Source: SFC and HKMA · Archived copy

Updates: Who can do what: virtual asset licensing

Hong Kong · FSTB and SFC · Report

FSTB and SFC confirm licensing regimes for crypto advisers and crypto asset managers

Proposal · Applies to Fund managers, Brokers

The FSTB and SFC published consultation conclusions confirming separate licensing regimes for virtual asset advisory and virtual asset management service providers, modelled on securities advising and asset management licences. There will be no de minimis threshold for crypto asset management. A bill covering these regimes and the earlier dealing and custody regimes is targeted for the Legislative Council in 2026.

Why it matters: Any Hong Kong manager touching crypto, even a sliver of a portfolio, will need a crypto licence, which ends the 10% threshold that let most managers stay out.

For Ethereum: The conclusions confirm that SFC-authorised crypto funds may keep staking and that private funds will not be restricted from staking.

Source: FSTB and SFC · Archived copy

Updates: Who can do what: virtual asset licensing

Hong Kong · SFC · Circular

SFC permits crypto margin financing, affiliated market makers and perpetual contracts

Final · Applies to Brokers, VASPs, Retail

The SFC issued two circulars and a framework on the same day. Brokers that already offer securities margin financing may now lend to those clients for crypto trading and route orders to shared order books. Licensed trading platforms may let an affiliated company make markets on their platforms, and may propose perpetual contracts for professional investors.

Why it matters: Hong Kong is adding leverage and liquidity in steps, each tied to the securities rulebook, and the first step is narrow.

For Ethereum: Ether is one of only two tokens a broker may accept as collateral for crypto financing, at a haircut of at least 60%.

Source: SFC · Archived copy

Updates: Who can do what: virtual asset licensing

India · FIU-IND · Circular

FIU-IND consolidates AML and travel rule obligations for crypto service providers

In force · Effective · Applies to VASPs

FIU-IND issued updated AML, counter-terrorist financing and counter-proliferation financing guidelines for virtual digital asset service providers, replacing its March 2023 guidelines. The guidelines cover registration, governance, customer due diligence, transaction monitoring, the travel rule, sanctions screening and reporting. They add operational detail such as liveness checks and geolocation at onboarding.

Why it matters: India still has no crypto law, so FIU-IND's AML rulebook remains the only binding framework for exchanges operating in the country.

Source: FIU-IND · Archived copy

Updates: Who can do what: virtual asset licensing