Concept
neobank (Stored Value Facility) is a license issued by the Hong Kong Monetary Authority under the Payment Systems and Stored Value Facilities Ordinance, Cap. 584. It regulates the issuance and servicing of stored value products: electronic wallets, prepaid cards, digital wallet services, prepaid instruments for retail and B2B segments. This is a heavier regime than neobank: bank-level capital and fit-and-proper requirements, but without a full banking license.
The regulator is HKMA (not C&ED, as with neobank), which in itself means a different level of supervision. An neobank licensee can hold client funds, issue proprietary payment products with stored value, and integrate with international payment networks.
As of mid-2026 the HKMA register lists eleven non-bank neobank licensees, alongside the banks that are deemed licensed. Most are consumer wallets: Octopus (SVF0001), HKT's Tap & Go, Alipay HK and WeChat Pay HK. Bank-run wallets such as PayMe sit under HSBC's deemed bank status rather than a standalone licence. For a business-payments operator the relevant precedent is UniCard Solution Limited (SVF0009), now part of the Airwallex group, which acquired it in 2021 rather than applying from scratch.
How the neobank regime came about
The current regime is young. The Payment Systems and Stored Value Facilities Ordinance (Cap. 584) commenced on 13 November 2015 with a one-year transition, and from 13 November 2016 it became unlawful to run a stored value facility in Hong Kong without a licence or an exemption. Before that, only card-based 'multipurpose stored value cards' were regulated, under the Banking Ordinance, with Octopus as effectively the sole licensee. The HKMA granted its first batch of five non-bank licences on 25 August 2016: Alipay, HKT, Tencent's WeChat Pay, TNG and Octopus.
Banks do not apply separately. Under the Ordinance a licensed bank is deemed to hold an neobank licence, provided it ring-fences the neobank float from deposits and meets the same safeguarding rules. That is why a bank wallet like PayMe operates under HSBC's banking authorization, while standalone issuers such as Octopus and UniCard each carry their own neobank number. In practice there are two routes to the same product: build inside a bank, or stand up a dedicated licensed company.
When neobank Is Needed
- Issuing proprietary prepaid cards or digital wallets under the company's brand.
- Stored value wallet for retail clients with top-up and payment capabilities.
- B2B prepaid programs — corporate prepaid cards, gift cards, loyalty programs with real monetary value.
- Multi-currency wallet that holds client balances as stored value, closer to a bank's model than to the safeguarding arrangement used by a European neobank.
If the model is only money transfer or currency exchange, with no stored balance, an neobank licence is enough. neobank becomes necessary the moment clients hold a balance with the issuer.
Structural Requirements
- Minimum paid-up capital — HK$25 million. A fundamental difference from neobank, which has no formal minimum.
- HK Ltd registration for the license — standalone company, not offshore.
- Office in Hong Kong with a registered lease agreement — virtual office is not acceptable.
- Chief Executive Officer and Chief Risk Officer — both appointed with fit-and-proper assessment by HKMA, typically with banking or payment experience.
- AML/CFT framework at banking level — Policy Manual, ongoing monitoring, regular reporting to JFIU and HKMA.
- Safeguarding of client funds — segregation according to HKMA rules in approved tier-1 banks or in Hong Kong / US Treasury government bonds.
- Capital scales with the float. The HK$25 million figure is a floor; the HKMA sets each issuer's expectation by reference to its size, user base and product mix, so a large-float wallet carries materially higher capital and safeguarding requirements than a niche prepaid program.
Application Stages
- HK Ltd registration for the future license — 2–5 business days.
- Company capitalization at HK$25 million — mandatory condition for application.
- Hiring CEO and CRO with verifiable CV and experience — 1–3 months of search.
- Preparation of AML/CFT framework, risk management policy, operational procedures — 8–12 weeks.
- Application submission to HKMA — package includes 3–5 year business plan, financial projections, corporate structure, key person documentation.
- HKMA review — series of question and clarification rounds, on-site inspection — 4–8 months.
- Final approval and license issuance — 6–12 months total from submission.
- Ongoing compliance — quarterly returns to HKMA, annual external audit, regulatory inspections.
Timeline
Full cycle from start to license receipt — 12 months and more. neobank is a serious regulatory process, and HKMA does not rush. The timeline depends on the quality of the business plan, team experience, and readiness for capital requirements.
Cost
Our fee for full license acquisition support — from €120,000, depending on product complexity.
Included:
- HK Ltd registration for the license
- Capitalization structuring at HK$25 million
- CEO and CRO selection from our partner pool (optional — client-led search)
- Preparation of banking-level AML/CFT framework and risk management policy
- Preparation of business plan and financial projections for HKMA
- Application submission and support through all HKMA question rounds
- On-site inspection support
- Connection to payment networks (Visa, Mastercard, UnionPay) after approval
Not included:
- Share capital of HK$25 million — paid by client directly
- Office rental in Hong Kong — from HKD 15,000/month
- CEO and CRO salaries — from HKD 80,000/month each
- Annual compliance maintenance after the first year — from €40,000/year
What neobank Permits and What It Does Not
neobank covers stored value issuance and related payments. It does not cover:
- Bank deposit-taking — accepting funds with an obligation to return them with interest. This requires a full HKMA banking license.
- Lending as a standalone product. Only permitted within the authorized stored value function.
- Securities brokerage, asset management — require corresponding SFC license types.
- Insurance — Insurance Authority, separate regulator.
Supervision and the economics of the float
Once licensed, the work shifts to staying licensed. The HKMA supervises on a risk basis: regular returns, an annual external audit, periodic inspections, and float safeguarding held in HKMA-approved banks or in Hong Kong or US government bonds. The float, meaning the money customers leave in the wallet, is what makes the model work because the issuer earns on those balances, yet it is not a deposit and cannot be lent out or commingled.
The Ordinance also fixes what an neobank company may be. Its principal business must be issuing the facility, so it cannot run money lending, financial intermediation or other regulated activities on the side. Combining stored value with brokerage or asset management means stacking the relevant SFC licences on top rather than stretching the neobank. The HKMA sets out its current expectations in its Practice Note on the supervision of neobank licensees, last refreshed in October 2025.
Where the regime is heading
The newest pressure on the neobank question comes from tokenized money. Hong Kong's Stablecoins Ordinance came into force on 1 August 2025, creating a separate HKMA licence for issuers of fiat-referenced stablecoins. The first two issuer licences were granted on 10 April 2026 — to Anchorpoint Financial (a Standard Chartered, HKT and Animoca Brands joint venture) and HSBC, selected from 36 applications. The two regimes rhyme: the stablecoin licence borrows the same HK$25 million capital floor, full reserve backing and redemption at par that neobank made familiar. The difference is technical. Stored value is e-money recorded in the issuer's centralized ledger, while a regulated stablecoin is a tokenized claim that moves on a blockchain.
For a payments founder the choice is concrete. If the product is a wallet or prepaid program denominated in Hong Kong dollars and major currencies, neobank is the licence to pursue, usually paired with an operating Hong Kong company and, where cards are involved, a network sponsor. If the product is a tokenized dollar, the stablecoin regime is the one that applies. Groups like Airwallex show a third path: buy an existing licensee rather than wait out a fresh application.
Sources
- HKMA — Register of neobank Licensees
- HKMA — Regulatory Regime for Stored Value Facilities
- PSSVFO (Cap. 584) — Hong Kong e-Legislation
Related pages
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