🇭🇰 Hong Kong vs 🇮🇪 Ireland: e-money licensing compared
Decision context and regulator route
On paper, Hong Kong's No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). and Ireland's E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. answer the same question; in practice the detail decides it. The two regimes differ on 9 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Hong Kong: verified 2026-08-15 · Ireland: verified 2026-08-15
| Dimension |
🇭🇰 Hong Kong
analogue
partly open
Verified 2026-08-15
|
🇮🇪 Ireland
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). | E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. |
| Regulator | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. | Central Bank of Ireland (CBI). |
| 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. |
| EMIs authorised | Hong Kong emis authorised is included in the £349 pass. | Ireland emis authorised 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. |
| Safeguarding | Hong Kong safeguarding is included in the £349 pass. | Ireland safeguarding is included in the £349 pass. |
| Recent changes | The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types. | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. |
| Difficulty rating | Hong Kong difficulty rating is included in the £349 pass. | Ireland difficulty rating is included in the £349 pass. |
The two regimes differ on 9 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇭🇰 Hong Kong (verified 2026-08-15): The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types.
🇮🇪 Ireland (verified 2026-08-15): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
Quick answers
Who regulates e-money licensing in Hong Kong and Ireland?
Hong Kong: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.. Ireland: Central Bank of Ireland (CBI)..
What licence do you need in Hong Kong compared with Ireland?
In Hong Kong the authorisation route is No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).; in Ireland it is E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Hong Kong vs Ireland comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/hong-kong-vs-ireland.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.