Pin and benchmark
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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-07-03
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🇯🇵 Japan
partly open
Verified 2026-07-03
|
|---|---|---|
| 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). | Crypto-Asset Exchange Service Provider (CAESP) registration with the Prime Minister (delegated to the FSA), under Article 63-2 of the Payment Services Act (PSA). Crypto derivatives trading is separately regulated as a Type I Financial Instruments Business under the Financial Instruments and Exchange Act (FIEA). A parallel intermediary-only registration category was introduced by the 2025 PSA/LPAI amendments. |
| 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. | Financial Services Agency of Japan (FSA / JFSA), registration authority, acting via the Prime Minister's delegated power and Local Finance Bureaus. The Japan Virtual and Crypto-assets Exchange Association (JVCEA) is the FSA-certified self-regulatory organisation that runs mandatory token-listing screening and conduct rules; JVCEA membership is the de facto baseline for registration even though not a strict legal requirement. |
| Capital requirement | Hong Kong capital requirement is locked. Unlock with the £349 pass. | Japan capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is locked. Unlock with the £349 pass. | Japan timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Hong Kong local substance is locked. Unlock with the £349 pass. | Japan local substance is locked. Unlock with the £349 pass. |
| Application cost | Hong Kong application cost is locked. Unlock with the £349 pass. | Japan application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is locked. Unlock with the £349 pass. | Japan ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Hong Kong passporting is locked. Unlock with the £349 pass. | Japan passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is locked. Unlock with the £349 pass. | Japan mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Hong Kong key restrictions is locked. Unlock with the £349 pass. | Japan key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | SFC 'ASPIRe' roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance commenced 1 Aug 2025 with the first two issuer licences (HSBC, Anchorpoint) granted 10 Apr 2026; VA dealing (OTC) and custody licensing consultation conclusions 24 Dec 2025 (legislation targeted 2026). ~13 VATPs licensed by mid-2026 - confirm live count on the SFC list. | Major overhaul underway: Japan's Cabinet approved an FIEA amendment bill (10 April 2026) to reclassify crypto-assets as 'financial instruments,' moving oversight from the PSA to FIEA, applying insider-trading rules, disclosure obligations, and market-conduct rules akin to securities law, alongside sharply increased criminal penalties (up to 10 years imprisonment / JPY 10 million fines for unregistered solicitation). The Lower House passed the bill 11 June 2026; it awaits Upper House passage, with effect expected as early as 2027. A flat 20% capital-gains tax on crypto (replacing progressive rates up to 55%) has been approved in principle. On 1 May 2025, PSA/LPAI amendments took effect introducing a new intermediary-only registration category and tightening stablecoin/EPI rules; a further overseas trust-type stablecoin equivalence framework takes effect 13 June 2026. |
| Difficulty rating | Hong Kong difficulty rating is locked. Unlock with the £349 pass. | Japan difficulty rating is locked. Unlock with 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.