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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-08-15
|
🇮🇪 Ireland
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | SFC Virtual Asset Trading Platform (VATP) licence on a dual basis: under the AMLO and, for tokens that are securities, under the SFO (Type 1 dealing + Type 7 automated trading). Stablecoin issuance is separately licensed by the HKMA under the Stablecoins Ordinance (Cap. 656). | MiCA CASP authorisation granted by the Central Bank of Ireland; replaces the legacy VASP registration (CJA 2010, AML). No simplified VASP->CASP conversion - all applicants face the full process. |
| Regulator | SFC regulates VATPs and security-token activity; HKMA regulates stablecoin issuers and banks' VA activities. Staking and intermediary VA activity are covered by joint SFC-HKMA circulars. | Central Bank of Ireland (CBI) - sole competent authority; runs an Innovation Hub. Known as a demanding, gatekeeper-style regulator. |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | Ireland capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is included in the £349 pass. | Ireland timeline to authorisation is included in the £349 pass. |
| Local substance | Hong Kong local substance is included in the £349 pass. | Ireland local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | Ireland application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | Ireland ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | Ireland passporting is included in the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is included in the £349 pass. | Ireland mica casps approved is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | Ireland key restrictions is included in the £349 pass. |
| Recent changes | SFC ASPIRe roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance in force 1 August 2025, with the first two issuer licences (HSBC, Anchorpoint) granted 10 April 2026; the HKMA register lists only these two issuers as of 23 April 2026. FSTB and SFC published consultation conclusions on virtual asset dealing and custodian licensing on 24 December 2025, then published consultation conclusions on virtual asset advisory and management service provider licensing on 26 May 2026. All four new licensing regimes, dealing, custodian, advisory and management, have now completed consultation; FSTB and SFC are finalising the legislative proposals, with a single bill covering all four regimes still targeted for introduction into the Legislative Council within 2026 (not yet introduced). 13 VATPs are licensed by the SFC, unchanged since the last review (most recently NewBX, licensed 18 May 2026). A June 2026 Legislative Council reply confirmed the HKMA received 36 stablecoin-licence applications in the first window and expects the overall number of licences to remain very limited. | Transitional period ended 30 Dec 2025 (12 months; simplified route declined). ~10 CASPs authorised by late 2025 (Kraken Jun 2025, Coinbase, StoneX 10th). Revised Consumer Protection Code from 24 Mar 2026. |
| Difficulty rating | Hong Kong difficulty rating is included in the £349 pass. | Ireland difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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