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.
The consultation closed in late January 2026 with 51 submissions, most supporting the proposals (press release). The conclusions paper confirms:
The advisory regime mirrors Type 4 (advising on securities) and the management regime mirrors Type 9 (asset management) under the Securities and Futures Ordinance.
The management regime covers anyone managing a portfolio of crypto assets for another person with discretion, including funds, discretionary accounts and model portfolios. There is no de minimis threshold (para 32).
Managers already licensed for Type 9 that hold crypto below today’s threshold will need the new licence and will be held to the same standards as those above it (para 51).
A crypto management licensee does not need a separate dealing licence for dealing done solely for its management business (para 38).
Intermediaries get exemptions for activities involving stablecoins from HKMA-licensed issuers (para 39).
Staking by SFC-authorised crypto funds remains allowed, and private funds will not be restricted from staking (para 50).
Implications
Removing the de minimis threshold is the main change for the industry. Today a manager whose portfolios hold less than 10% in crypto can operate under its existing licence. Under the new regime the same manager needs a crypto management licence. Some respondents asked for a transitional period for those firms (para 60). The paper records the request, and the FSTB and SFC have yet to say whether they will grant it.
Together with the platform, stablecoin, dealing and custody regimes, this completes the licensing map the government set out in its 2025 Policy Statement 2.0. Nothing takes effect until the bill passes.
For Ethereum
The staking confirmation is the most useful line for Ethereum. Hong Kong fund managers, public and private, will be able to stake ether under the new licence without a separate ban. The paper also treats technology tools that make discretionary decisions, including automated rebalancing, as management (para 40). That would catch on-chain vault strategies run for Hong Kong clients.
What to watch
Publication of the bill and its first reading in the Legislative Council, targeted for 2026. Also the SFC’s separate consultation on the detailed conduct requirements for these licensees.