# Hong Kong: the Stablecoins Ordinance — the HKMA Issuer Licence and the Limits of the Regime > Cap. 656 since 1 Aug 2025: HKD 25m capital, one-business-day redemption, 36 applications and two licences by 10 Apr 2026 — who must license and who may sell. Author: Ksenia Voronova — Lawyer, Family Office (https://wiki.private.law/en/authors/voronova) Last modified: 2026-08-14T13:13:00.000Z Canonical: https://wiki.private.law/en/hk-stablecoin-ordinance Topics: banking Jurisdictions: hong-kong, china Product tags: stablecoin, crypto, compliance, neobank Semantic tags: stablecoin, crypto, compliance, neobank --- ## What Hong Kong Actually Licenses — and Why It Is Not a Crypto Licence The Stablecoins Ordinance \(Cap. 656\) is not an extension of crypto regulation. It is a standalone prudential regime for one narrow product: a digital claim referenced to an official currency. The supervisor is the Monetary Authority — the same body that supervises banks and stored value facility operators — and the logic is banking logic: capital, reserves, redemption at par, orderly exit. The Ordinance was [passed by the Legislative Council on 21 May 2025](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/05/20250521-3/), gazetted on 30 May, and a [Commencement Notice of 6 June 2025](https://www.info.gov.hk/gia/general/202506/06/P2025060600275.htm) set 1 August 2025 as the date it came into operation. One number frames everything else. As at 13 August 2026 the [HKMA register of licensees](https://www.hkma.gov.hk/eng/regulatory-resources/registers/register-of-licensed-stablecoin-issuers/) holds two entries — Anchorpoint Financial Limited \(FRS01\) and The Hongkong and Shanghai Banking Corporation Limited \(FRS02\), both effective 10 April 2026. The first batch drew 36 applications. That ratio tells you more about the regime than any of its sections. The currency behind the token matters just as much. The Hong Kong dollar is held to the US dollar within a 7.75–7.85 band under the [Linked Exchange Rate System](https://www.hkma.gov.hk/eng/key-functions/money/linked-exchange-rate-system/), so an HKD-referenced stablecoin is, in economic terms, a dollar proxy issued under an Asian rulebook and supervised by an Asian central bank. That is the strategic question behind the licence, not the token itself. ## Timeline and the Transition Window The regime took four years to build — from the [HKMA discussion paper of January 2022](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2022/01/20220112-3/) to the [FSTB/HKMA conclusions on the legislative proposal in July 2024](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2024/07/20240717-3/). The operative part fitted into twelve months after enactment. | **Date** | **Milestone** | | --- | --- | | 21 May 2025 | Legislative Council passes the Stablecoins Bill | | 30 May 2025 | Ordinance gazetted \(Cap. 656\) | | 6 June 2025 | Commencement Notice sets 1 August; the same day the Financial Secretary carves professional investors out of the ban on offering unlicensed stablecoins | | 29 July 2025 | HKMA publishes the Supervisory Guideline, the AML/CFT Guideline and two explanatory notes — on licensing and on transitional provisions | | 1 August 2025 | Ordinance comes into operation; guidelines gazetted | | 31 Aug / 30 Sept 2025 | Deadline to indicate interest to the HKMA licensing team, then the deadline for the first batch of applications — 36 filed | | 31 October 2025 | Application deadline for pre-existing issuers \(Schedule 7\) | | 31 January 2026 | End of the six-month window for pre-existing issuers without a provisional licence | | 10 April 2026 | First two licences: FRS01 Anchorpoint, FRS02 HSBC | | 28 April 2026 | HKMA warns about counterfeit tokens using the tickers "HKDAP" and "HSBC" | | 27 May 2026 | HKMA and SFC relax requirements for activities in Relevant Stablecoins | | 12 August 2026 | Anchorpoint launches HKDAP — the first regulated HKD stablecoin | | 2026 \(announced\) | Bill on licensing digital asset dealing and custody to be introduced in the Legislative Council | The transition was short and unforgiving. Under the [Explanatory Note on Transitional Provisions](https://www.hkma.gov.hk/media/eng/doc/key-functions/ifc/stablecoin-issuers/Explanatory_Notes_on_Transitional_Provisions_for_Pre-existing_Stablecoin_Issuers_eng.pdf), anyone actually issuing stablecoins in Hong Kong before 1 August 2025 had to file an application, a declaration and an undertaking by 31 October 2025 — failing which a one-month closing down period began on 1 November. Those who filed could keep operating until 31 January 2026, with the possibility of a provisional licence treated as a licence. A shell incorporated in Hong Kong before 1 August did not qualify as a pre-existing issuer. ## The Perimeter: What Is Caught and What Is Not The regulated object is not a "stablecoin" but a specified stablecoin. Per the [Explanatory Note on Licensing](https://www.hkma.gov.hk/media/eng/doc/key-functions/ifc/stablecoin-issuers/Explanatory_Notes_on_Licensing_of_Stablecoin_Issuers_eng.pdf), that means a token referenced wholly to one or more official currencies — what the market calls fiat-referenced. The Ordinance lets the Monetary Authority extend the perimeter to specified "units of account" and "stores of economic value", meaning commodity and basket pegs, but that power has not been used. A licence is required in two cases: issuing a specified stablecoin in Hong Kong in the course of business, and issuing anywhere in the world a token referenced wholly or partly to the Hong Kong dollar. The second limb is straightforward extraterritoriality: the place of incorporation and of minting is irrelevant, the reference currency is not. For the first limb the HKMA takes a holistic view — where day-to-day management sits, where the issuer is incorporated, where minting and burning happen, where reserves are managed, where the bank accounts for issuance and redemption flows are held. "Active marketing" is caught separately: Chinese-language content, a Hong Kong domain, targeting of residents, a detailed marketing plan. The trigger point is technical: a stablecoin is treated as issued when it is first recorded on a distributed ledger and assigned to a wallet address — at minting. One relief valve exists in section 13\(1\): the Monetary Authority may exempt a person or class of persons from the licensing prohibition where the risks to holders and to Hong Kong's monetary and financial system are immaterial, and may attach conditions such as a cap on circulation or a limit on who may be offered the token. In practice the route is theoretical — no public exemptions have been granted. Five categories fall outside: anything issued by a central bank or government \(see the [CBDC landscape](https://wiki.private.law/en/cbdc-landscape)\); limited purpose digital tokens under the AMLO; securities and futures under the SFO; a float or SVF deposit under Cap. 584; and a deposit under the Banking Ordinance. The last two boundaries are the practical ones. A tokenised wallet holding Hong Kong dollars is almost certainly an [SVF](https://wiki.private.law/en/svf-license-hk) rather than a stablecoin: the test is whether the claim circulates on a ledger as a freestanding transferable instrument. A tokenised bank deposit is a deposit; how these forms differ in law is set out in the note on the [four legal forms of the digital dollar](https://wiki.private.law/en/digital-dollar-forms). ## What the Licensee Must Deliver | **Area** | **HKMA requirement** | | --- | --- | | Corporate status | A company under the Companies Ordinance \(Cap. 622\) or an overseas-incorporated authorized institution. A non-bank foreign group must incorporate a Hong Kong subsidiary — the subsidiary is the applicant | | Capital | Paid-up share capital of at least HKD 25,000,000 or the equivalent in a freely convertible currency — or other financial resources of the same amount approved by the regulator. Authorized institutions are exempt; the funds may not be used in dealings with related parties | | Reserves: composition | Cash; bank deposits of up to 3 months; marketable debt of governments, central banks, PSEs and multilateral development banks with residual maturity up to 1 year and a 0% risk weight under the Banking \(Capital\) Rules; overnight reverse repo against those; funds established solely to manage the issuer's reserves. Tokenised representations are permitted | | Reserves: backing | Market value of the pool at least equal to the par value of tokens in circulation at all times, plus an over-collateralisation buffer. A separate pool per type of stablecoin; reserve currency must match the reference currency, and any mismatch needs prior written approval | | Reserves: segregation and reporting | A trust for holders, protected from other creditors, supported by an independent legal opinion on its effectiveness; custodian must be a licensed bank or another custodian acceptable to the HKMA. Daily computation of par value and reserve value, weekly reporting to the HKMA and website updates, periodic external-auditor attestation published on the website, an annual audit, quarterly policy review, and immediate escalation of unresolved reconciliation discrepancies | | Redemption | At par, without unreasonable fees or unduly burdensome conditions, processed within 1 business day of the day of receipt. On insolvency the holder can direct disposal of the pool pro rata and claim against the issuer for any shortfall | | Interest | Prohibited outright — whether by reference to holding period, par value or market value. Income and losses on the reserves accrue to the issuer | | Governance and people | Fit and proper testing for the chief executive, directors, the stablecoin manager and controllers, with regulator consent before appointment. Senior management and key personnel are generally expected to be based in Hong Kong; a face-to-face meeting with the licensing team forms part of the process. Any non-core business needs consent | | Risk and AML | A dedicated AML/CFT Guideline; blockchain analytics in day-to-day operations; verification of holders' identity, directly or through reliable third parties. Private keys in an HSM in a secure facility in Hong Kong | | Ongoing duties | Licence fee under Schedule 3 within 14 days of the licence taking effect and annually thereafter, with the amount varied by Financial Secretary notice in the Gazette. The licence number must appear on advertising and in the app interface | | Exit | Recovery planning for critical functions and a business exit plan with scenarios, triggers, procedures and an assessment of the time and resources required | The table describes the floor, not the full perimeter of obligations. Under section 17 the Monetary Authority may attach any conditions it considers appropriate to a licence, and may add or amend conditions at any time after grant. Meeting Schedule 2 opens the door; it does not fix the rules for the life of the licence. ## Distribution: Who May Sell, and to Whom The Ordinance regulates offering as well as issuance. Only a permitted offeror may offer a specified stablecoin: a licensee, an authorized institution, an SVF licensee, an SFC-licensed virtual asset trading platform, or a corporation licensed for Type 1 regulated activity. Retail investors may only be offered stablecoins issued by a licensee; unlicensed ones, USDT and USDC included, may be offered to professional investors only — and that carve-out comes from a separate Financial Secretary notice of 6 June 2025, not from the statute itself. Advertising is permitted only for licensed issuance, at all times including the six-month non-contravention period. The licence number must appear on advertising material and in the app interface. A symmetric constraint applies at the point of issuance: under the Supervisory Guideline a licensee issues only to its own onboarded and due-diligenced customers, and must not issue or offer where doing so is unlawful — down to IP geolocation and controls against VPN circumvention. Enforcement is criminal. Carrying on the activity without a licence, and breaching the offering restrictions, each carry a fine of up to HKD 5,000,000 and up to seven years' imprisonment, with — per Charltons' analysis — a further daily fine of up to HKD 100,000 while the offence continues. Falsely holding yourself out as an applicant or licensee is a separate offence, one the HKMA was already stressing in July 2025, long before any licence existed. On 27 May 2026 the regulators moved toward the market. The [SFC circular](https://apps.sfc.hk/edistributionWeb/api/circular/openFile?lang=EN&refNo=26EC26) introduced the concept of a Relevant Stablecoin — a specified stablecoin issued by a licensee under its licence — and stripped away part of the crypto overlay: the liquidity and index requirements for retail trading do not apply, holdings are excluded from a client's virtual asset exposure limit, and the virtual asset knowledge test is not required for clients served only in such tokens. Licensed corporations may now deal through omnibus accounts at platforms carrying a professional-investor-only condition while still serving retail, and may hold client tokens in segregated accounts with the issuer itself. A parallel HKMA circular extended the same logic to banks: no Type 1 registration for Relevant Stablecoin-only dealing, and no Type 9 for portfolios composed solely of them. ## The Filter: Sandbox, 36 Applications, Two Licences The sandbox launched in March 2024 and [participants were named on 18 July 2024](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2024/07/20240718-4/): JINGDONG Coinlink Technology Hong Kong, RD InnoTech, and a consortium of Standard Chartered Bank \(Hong Kong\), Animoca Brands and HKT. None was allowed to handle public money. One of the three converted into a licence — the consortium, which became Anchorpoint. On 14 August 2025 the HKMA and SFC issued a [joint statement on stablecoin-related market movements](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/08/20250814-8/) after listed share prices jumped on nothing more than press releases announcing an intention to apply. Eddie Yue put it plainly: the bar is high, only a handful of licences would be granted initially, and engagement with the regulator is not an endorsement. The outcome is set out in [Eddie Yue's inSight of 10 April 2026](https://www.hkma.gov.hk/eng/news-and-media/insight/2026/04/20260410/). Two criteria decided it: capability and track record in risk management together with a commitment to comply with Hong Kong and other jurisdictions' rules, and a distinct use case supported by a viable business plan. Both licensees carry banking backgrounds and prior participation in HKMA pilots on CBDC and tokenised deposits. On the other 34 the regulator has said nothing beyond that it will "continue to engage the remaining applicants" — it has published no refusal or withdrawal figures at all. Its stance on a second batch is "open yet prudent, with no definitive inclination at this stage"; if further licences follow, "the overall number will remain very limited". The decision is not one official's. Every application goes to a Stablecoin Advisory Committee of senior HKMA officers chaired by a senior executive, which recommends to the Monetary Authority. Nor is an application filed complete: independent assessment reports on regulatory compliance are not required at submission — the HKMA decides when they must be produced, which stretches the review. The real cost of entry sits in the annexes rather than the fee: independent assessment reports, an external auditor's report on paid-up capital, trust documentation with an independent legal opinion on the trust's effectiveness, a second opinion on holders' rights, custodian agreements, a white paper and a smart contract audit. On timing: applications closed on 30 September 2025 and licences were granted on 10 April 2026 — roughly six months of review after two months of pre-application engagement. ## What Backs a Regulated Stablecoin and How to Verify It The core protection is that reserves sit under a trust rather than a promise: the pool is separated from the issuer's assets, shielded from other creditors, valued daily and confirmed by published attestation. On insolvency the holder has two rights — to direct disposal of the pool for pro rata redemption, and to claim against the issuer for any shortfall. That is materially stronger than the offshore model, where the holder is an unsecured creditor, and materially weaker than a bank deposit: deposit protection schemes do not extend to stablecoins. A less obvious consequence follows. The issuer must verify holders' identity, itself or through reliable third parties, which makes a regulated Hong Kong stablecoin closer in construction to a registered payment instrument than to a bearer token. Anonymous use is not part of the design — a point worth weighing against the reporting perimeter discussed in the note on [crypto for private wealth](https://wiki.private.law/en/crypto-private-wealth). Second, redemption at par within one business day, with the procedure and fees publicly disclosed. Third, no interest: a regulated Hong Kong stablecoin is by definition not a yield instrument, and all income from the reserves belongs to the issuer. Yield on a stablecoin balance is sought outside the Cap. 656 perimeter, with everything that implies. Fourth, verifiability. On 28 April 2026 the HKMA had to [issue a warning](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2026/04/20260428-5/): tokens bearing the tickers "HKDAP" and "HSBC" had appeared on the market with no connection to the licensees — at a point when neither licensee had issued a single regulated stablecoin. The genuine HKDAP launched on 12 August 2026 in beta, for institutional and professional clients, through HashKey and OSL as distributors, with retail access flagged for late 2026. The rule is simple: the ticker means nothing, the register entry means everything. ## Entering the Regime: Own Issuance or the Permitted-Offeror Route HKD 25 million is the entry ticket, not the barrier. Of 36 applicants — banks, technology companies, asset managers, payment firms, e-commerce platforms and Web3 start-ups — two got through, both with a bank balance sheet behind them and a defensible use case. An application built on "we will issue an HKD stablecoin and see what happens" does not clear the use-case filter. The sober alternative is to distribute rather than issue. The permitted offeror perimeter opens three doors: an SVF licence under Cap. 584, an SFC trading platform licence, or Type 1. May 2026 widened that door, and the infrastructure layer already exists — [HashKey](https://wiki.private.law/en/hashkey-group) and OSL became the first HKDAP distributors, and the SFC register held 13 licensed platforms as at mid-August 2026. FX and remittance legs of a product are covered by the [MSO licence](https://wiki.private.law/en/mso-license-hk); how the Hong Kong entry compares with European and US routes is mapped in the [financial licence map](https://wiki.private.law/en/fintech-license-map). The second design constraint is locality: senior management in Hong Kong, keys in an HSM on Hong Kong premises, reserve custody with a licensed bank. This is not a regime for a holding structure with the operating team in another time zone. Third, extraterritoriality widens the perimeter — an HKD peg triggers the licence wherever the entity sits and wherever minting occurs, and active marketing at the Hong Kong public counts as carrying on the activity. The converse also holds: a USD-referenced product not directed at Hong Kong falls outside Cap. 656 even if the team sits in Central. ## Hong Kong Against GENIUS, MiCA, Singapore and Japan | **Regime** | **Capital** | **Reserves** | **Redemption** | **Who may be sold to** | **Status at 13.08.2026** | | --- | --- | --- | --- | --- | --- | | Hong Kong, Cap. 656 | HKD 25m paid-up capital; banks exempt | Cash, deposits up to 3m, 0% risk-weight sovereigns up to 1y, repo; held on trust | At par, 1 business day | Permitted offerors only; retail limited to licensed issuers, others to professional investors | In force since 01.08.2025, two licences | | US, GENIUS Act | No statutory floor: capital and liquidity set by regulators in rulemaking | 1:1 in cash, short Treasuries, repo and government money market funds | Published redemption policy required | Issuance limited to permitted payment stablecoin issuers | Signed 18.07.2025, effective no later than 18.01.2027; proposed rules spring 2026 | | EU, MiCA e-money token | Credit institution or EMI; EMI initial capital €350,000 | Funds held in assets in the reference currency, e-money regime | At par, at any time | Through CASPs and banks; retail permitted | Titles III–IV applying since 30.06.2024 | | Singapore, MAS SCS framework | Higher of SGD 1m or 50% of annual operating expenses | Cash, cash equivalents and debt up to 3m from issuers rated AA- or above | At par, 5 business days | No retail prohibition; the "MAS-regulated stablecoin" label restricted to compliant issuers | Framework finalised 15.08.2023, primary legislation not yet passed | | Japan, Payment Services Act | Depends on issuer form: bank, trust company or funds transfer service provider | Depends on form; the trust model segregates assets | At par | Through registered electronic payment instrument intermediaries | In force since 01.06.2023; first yen stablecoin JPYC — October 2025 | The difference between these regimes is not in the numbers but in what each protects. The [GENIUS Act](https://wiki.private.law/en/genius-act) is built around reserve quality and the federal–state supervisory split; [MiCA](https://wiki.private.law/en/mica-eu) around folding stablecoins into the existing e-money regime with an EU passport; Hong Kong around control of how many issuers exist and what they are for. Hong Kong is the only one of the four that gives its regulator discretion over market composition and uses it openly: "a handful of licences" is stated policy, not a by-product of strictness. That produces the first question for anyone choosing an issuance jurisdiction — here you can meet every criterion and still not be licensed, because the market is judged full enough. The flip side is that whoever holds a licence operates with almost no competition. The EU offers no equivalent discretion: a [CASP licence](https://wiki.private.law/en/casp-license-guide) is granted on satisfaction of the criteria. ## To 2028: What Is Still Being Built Stablecoins are one layer of a larger structure. [Policy Statement 2.0 of 26 June 2025](https://www.info.gov.hk/gia/general/202506/26/P2025062600269.htm) framed it as LEAP: a unified framework for exchanges, stablecoin issuers, dealers and custodians, a legal review to enable tokenisation of real-world assets, and regularised issuance of tokenised government bonds. The nearest milestone is licensing for dealing and custody. [FSTB and SFC consultation conclusions were published on 24 December 2025](https://www.info.gov.hk/gia/general/202512/24/P2025122400265.htm): 101 and 93 submissions respectively, with the dealing regime modelled on Type 1 and the custody regime built around the security of client private keys. A further consultation on separate regimes for digital asset advisers and managers ran to 23 January 2026. A bill is promised during 2026, with no transitional period — a licence is needed from day one. Licensed stablecoin issuers are carved out of the dealing regime for their own regulated activity. The monetary infrastructure moves in parallel. On 28 October 2025 the HKMA [closed the second phase of the e-HKD pilot](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/10/20251028-4/) and shifted its priority to wholesale use, deferring a retail e-HKD. On 13 November 2025 [Ensemble TX](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2025/11/20251113-3/) began — a real-value pilot for settlement in tokenised deposits running through 2026, with interbank settlement via the HKD RTGS system and a path toward 24/7 settlement in tokenised central bank money. An offshore renminbi stablecoin remains an idea. The Ordinance formally permits a peg to any official currency, but both licences are HKD-referenced and no CNH stablecoin has been approved in Hong Kong. The Hong Kong–mainland track is advancing in conventional form instead: on [7 July 2026 the HKMA, PBoC and SFC announced](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2026/07/20260707-3/) an expansion of the RMB Business Facility from RMB 200bn to RMB 500bn along with enhancements to Bond Connect and Swap Connect — with no mention of stablecoins anywhere in the package. The mainland constraints behind that silence are covered in the note on [payments with China](https://wiki.private.law/en/china-payments). Building a product around a CNH stablecoin on a 2026–2027 horizon is premature. > 🍓 The Stablecoins Ordinance \(Cap. 656\) has applied since 1 August 2025 and requires an HKMA licence to issue a fiat-referenced stablecoin in Hong Kong, or an HKD-referenced one anywhere in the world. The requirements are banking requirements in substance: paid-up capital from HKD 25m, reserves held on trust with daily valuation and published attestation, redemption at par within one business day, an outright ban on interest, and management in Hong Kong. Of 36 first-batch applications two were granted — Anchorpoint \(FRS01\) and HSBC \(FRS02\), both effective 10 April 2026 — and the first regulated HKD stablecoin, HKDAP, only launched on 12 August 2026. The regime delivers a segregated reserve and a verifiable register, but neither deposit protection nor yield. The decision to apply turns on probability rather than capital: the HKMA has said the overall number of licences will stay very limited, which makes the permitted offeror role worth weighing against the issuer role. ## Q/A ### **Whether an HKMA licence is needed if the stablecoin is issued outside Hong Kong** Yes, if it is referenced wholly or partly to the Hong Kong dollar: issuing such a token anywhere in the world is a regulated stablecoin activity under section 5 of the Ordinance. For any other peg the licence is only triggered by issuance "in Hong Kong", which is assessed holistically — where day-to-day management sits, where the issuer is incorporated, where minting and burning occur, where reserves are managed and where issuance and redemption accounts are held. Active marketing at the Hong Kong public is caught separately, judged by website language, domain and targeting. ### **Whether USDT and USDC can be sold in Hong Kong** To professional investors only. Retail may be offered only stablecoins issued by a licensee, and the professional investor carve-out came from a Financial Secretary notice of 6 June 2025. The offer itself may only be made by a permitted offeror — a licensee, a bank, an SVF licensee, an SFC-licensed platform or a Type 1 corporation. Breach is criminal: a fine of up to HKD 5m and up to seven years' imprisonment. ### **What protects a holder of a regulated Hong Kong stablecoin** A trust over the reserve pool, segregated from the issuer's assets and shielded from other creditors, plus a right of redemption at par within one business day. On insolvency the holder can direct disposal of the pool for pro rata redemption and claim against the issuer for any shortfall. What is absent: deposit protection and yield — interest is prohibited and reserve income belongs to the issuer. ### **Whether to apply for a licence in a second batch** Only with a distinct use case and a balance sheet that carries the capital, reserve and local presence requirements. As at 10 April 2026 the HKMA had reached no decision on further licences and said the overall number would remain very limited; two of 36 first-batch applications succeeded. Entering as a permitted offeror — through an SVF, Type 1 or a trading platform licence — is often the better economics, the more so since 27 May 2026, when activities confined to Relevant Stablecoins were released from much of the requirement set applying to other digital assets. --- ## FAQ ### What protects a holder of a regulated Hong Kong stablecoin A trust over the reserve pool, segregated from the issuer's assets and shielded from other creditors, plus a right of redemption at par within one business day. On insolvency the holder can direct disposal of the pool for pro rata redemption and claim against the issuer for any shortfall. What is absent: deposit protection and yield — interest is prohibited and reserve income belongs to the issuer. --- ## Factual claims - The regime took four years to build — from the HKMA discussion paper of January 2022 to the FSTB/HKMA conclusions on the legislative proposal in July 2024. - On 27 May 2026 the regulators moved toward the market. - The sandbox launched in March 2024 and participants were named on 18 July 2024: JINGDONG Coinlink Technology Hong Kong, RD InnoTech, and a consortium of Standard Chartered Bank (Hong Kong), Animoca Brands and HKT. - On 14 August 2025 the HKMA and SFC issued a joint statement on stablecoin-related market movements after listed share prices jumped on nothing more than press releases announcing an intention to apply. - The outcome is set out in Eddie Yue's inSight of 10 April 2026. - HKD 25 million is the entry ticket, not the barrier.