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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-10-01
|
🇸🇬 Singapore
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). | 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 included in the £349 pass. | Singapore capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is included in the £349 pass. | Singapore timeline to authorisation is included in the £349 pass. |
| Local substance | Hong Kong local substance is included in the £349 pass. | Singapore local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | Singapore application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | Singapore ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | Singapore passporting is included in the £349 pass. |
| MiCA CASPs approved | Hong Kong mica casps approved is included in the £349 pass. | Singapore mica casps approved is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | Singapore key restrictions is included in the £349 pass. |
| Recent changes | The SFC register lists 13 licensed virtual asset trading platforms, with NewBX the latest licence on 18 May 2026. Consultation on the proposed dealing, custodian, advisory and management licensing regimes is complete. On 16 September 2026 the Government said it was still formulating the legislative proposals and continued to target introduction of the bill within 2026; no bill had yet been introduced. | 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 included in the £349 pass. | Singapore 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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