VATP License
Dual license under SFO and AMLO for operating virtual asset trading platforms with external assessor review.
AMLO Part 5A, Securities and Futures Ordinance
Capital Required
HKD 5,000,000 paid-up + HKD 3,000,000 liquid capital + 12 months expenses
Timeline
3-6 months
Fees
HKD 100,000-300,000 application + annual supervision fees
Regulatory Body
Securities and Futures Commission (SFC) / Hong Kong Monetary Authority (HKMA)
Legislative Framework
Securities and Futures Ordinance (SFO), Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Stablecoins Ordinance 2025
Last updated: August 2025
Key Requirements
Minimum HKD 5,000,000 paid-up share capital and HKD 3,000,000 liquid capital continuously per SFO
External assessor certification confirming SFO operational standards and cybersecurity in two phases
Real-time order matching infrastructure with guaranteed settlement within 24 hours per standards
Comprehensive market surveillance system detecting abuse, manipulation, and suspicious patterns
Dual governance structure with SFC Responsible Officers and AMLO-appointed Money Services Officers
Professional indemnity insurance of minimum HKD 2,000,000 covering trading platform liabilities
Segregated customer fund accounts with independent custodian or internal custody license
Clear fee schedules and service terms with mandatory dispute resolution through ombudsman
Application Process
Prepare comprehensive VATP license application to SFC specifying trading platform architecture
Submit organizational structure with Responsible Officers CVs and AMLO fit-and-proper assessments
Arrange external assessor engagement for pre-authorization phase assessment of operational standards
Submit compliance manual, market surveillance procedures, and AML/CFT controls per standards
SFC preliminary review and in-principle approval upon assessment of compliance framework
Complete external assessor post-authorization verification following operational commencement
Expected Total Timeline
3-6 months
Ongoing Obligations
After obtaining your VATP License, these are the continuing compliance requirements you must maintain.
Quarterly capital adequacy reports and annual independent audit by SFC-approved auditors
Monthly market surveillance reports identifying suspicious activity and regulatory referrals
Daily trading activity monitoring and quarterly metrics including volumes, settlement, and uptime
Mandatory notifications to SFC of material changes to systems, governance, or risk management
Annual fit-and-proper assessments for all Responsible Officers and Management Team with updates
Maintain external assessor engagement for periodic compliance audits and cybersecurity assessments
Cost Summary
Capital Requirement
HKD 5,000,000 paid-up + HKD 3,000,000 liquid capital + 12 months expenses
Application & Licensing Fees
HKD 100,000-300,000 application + annual supervision fees
Jurisdiction Setup Cost
$120,000-$350,000
Annual: $100,000-$300,000
Other Hong Kong Licenses
Explore other license types available in Hong Kong.
Stablecoin Issuer License
Type 9 Asset Management License
Type 1 Dealing in Securities
Money Service Operator License
Need help with VATP License?
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