🇭🇰 Hong Kong vs 🇱🇮 Liechtenstein: e-money licensing compared
Decision context and regulator route
Hong Kong and Liechtenstein are commonly considered side by side for e-money authorisation. In Hong Kong the route is the No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). overseen by Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.; in Liechtenstein it is the E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process under Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Hong Kong: verified 2026-08-15 · Liechtenstein: verified 2026-08-15
| Dimension |
🇭🇰 Hong Kong
analogue
partly open
Verified 2026-08-15
|
🇱🇮 Liechtenstein
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 licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process |
| Regulator | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. | Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | Liechtenstein capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong timeline to authorisation is included in the £349 pass. | Liechtenstein timeline to authorisation is included in the £349 pass. |
| Local substance | Hong Kong local substance is included in the £349 pass. | Liechtenstein local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | Liechtenstein application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | Liechtenstein ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | Liechtenstein passporting is included in the £349 pass. |
| EMIs authorised | Hong Kong emis authorised is included in the £349 pass. | Liechtenstein emis authorised is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | Liechtenstein key restrictions is included in the £349 pass. |
| Safeguarding | Hong Kong safeguarding is included in the £349 pass. | Liechtenstein 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. | Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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. | Liechtenstein difficulty rating is included in the £349 pass. |
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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.
🇱🇮 Liechtenstein (verified 2026-08-15): Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 Liechtenstein?
Hong Kong: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.. Liechtenstein: Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA).
What licence do you need in Hong Kong compared with Liechtenstein?
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 Liechtenstein it is E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Hong Kong vs Liechtenstein comparison?
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Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.