- Platforms must use delivery-versus-payment settlement and maintain Hong Kong reserve funds.
- Retail access to global pools requires explicit opt-in after risk disclosure.
- Overseas affiliates must operate in FATF-member jurisdictions meeting SFC standards.
Hong Kong’s Securities and Futures Commission published two circulars on Nov. 3, 2025, permitting licensed virtual asset trading platform operators to combine order books with affiliated overseas platforms. The move ends the territory’s closed-loop system that previously restricted platforms to domestic liquidity only.
Platforms using shared liquidity must implement delivery-versus-payment settlement mechanisms, maintain a reserve fund in Hong Kong for compensation, and operate joint market surveillance programs with overseas partners, according to the SFC announcement. The guidance sets out standards for platform operators to follow when connecting with global order flows.
Retail clients can only access global liquidity pools if they receive clear information about additional risks and explicitly elect to participate. The SFC specified that platforms must obtain express consent from retail investors before granting them access to shared order books.
Shared Order Books with Overseas Platforms
Overseas affiliates must operate in jurisdictions that are members of the Financial Action Task Force. The SFC requires these platforms to meet Hong Kong standards for investor protection before they can share liquidity with licensed operators in the territory.
The SFC waived the 12-month track record requirement for virtual assets offered to professional investors. The regulator also removed this requirement for Hong Kong Monetary Authority-licensed stablecoins provided to retail investors. Licensed platforms can now distribute tokenized securities and digital asset-related investment products.
The changes advance Pillar A (Access) and Pillar P (Products) of the SFC’s ASPIRe roadmap published on Feb. 19, 2025. Associated entities of platform operators may now provide custody services for virtual assets or tokenized securities that are not traded on their platforms. SFC CEO Julia Leung discussed the new guidance during a fireside chat at Hong Kong FinTech Week 2025 on Nov. 3.
