Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-07-03
|
🇸🇬 Singapore
partly open
Verified 2026-07-01
|
|---|---|---|
| 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). | Payment Services Act 2019 Digital Payment Token (DPT) service licence, held as a Standard (SPI) or Major Payment Institution (MPI) - most crypto firms are MPIs. Plus the newer DTSP regime (FSMA 2022 Part 9) and a finalised (not-yet-legislated) stablecoin issuer framework. |
| 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. | Monetary Authority of Singapore (MAS) - central bank and integrated regulator; administers the PSA, the DTSP regime, the SFA and the stablecoin framework. |
| Capital requirement | Hong Kong capital requirement is locked. Unlock with the £349 pass. | Singapore capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is locked. Unlock with the £349 pass. | Singapore timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Hong Kong local substance is locked. Unlock with the £349 pass. | Singapore local substance is locked. Unlock with the £349 pass. |
| Application cost | Hong Kong application cost is locked. Unlock with the £349 pass. | Singapore application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is locked. Unlock with the £349 pass. | Singapore ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Hong Kong passporting is locked. Unlock with the £349 pass. | Singapore passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is locked. Unlock with the £349 pass. | Singapore mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Hong Kong key restrictions is locked. Unlock with the £349 pass. | Singapore 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. | DTSP regime (FSMA Part 9) commenced 30 Jun 2025 - Singapore firms serving only overseas customers must be licensed, and MAS 'will generally not issue' such licences (no transition). MPI DPT licensees ~37 by mid-2026. MAS revoked Bsquared Technology's MPI licence (May 2026). Stablecoin legislation still in drafting. |
| Difficulty rating | Hong Kong difficulty rating is locked. Unlock with the £349 pass. | Singapore 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.