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.