🇭🇰 Hong Kong vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Choosing between Hong Kong and United Kingdom for a e-money licence starts with who you will answer to: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. on one side, Financial Conduct Authority (FCA). on the other, via the No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). and the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. respectively. The two regimes differ on 8 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Every figure behind the comparison carries a last-verified date and a primary source.
Hong Kong: verified 2026-08-01 · United Kingdom: verified 2026-08-01
| Dimension |
🇭🇰 Hong Kong
analogue
partly open
Verified 2026-08-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-01
|
|---|---|---|
| Licence type | No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. | Financial Conduct Authority (FCA). |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Hong Kong timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Hong Kong local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Hong Kong application cost is included in the £349 pass. | FCA application fee GBP 5,580 for an authorised EMI (Category 5) or GBP 1,120 for a small EMI (Category 3), plus roughly GBP 75k to 200k professional; representative all-in around GBP 145k (~EUR 168k at 1.16). |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Hong Kong passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Hong Kong emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Hong Kong safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| 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. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Hong Kong difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 8 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 2026-08-01): 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.
🇬🇧 United Kingdom (verified 2026-08-01): FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026.
Quick answers
Who regulates e-money licensing in Hong Kong and United Kingdom?
Hong Kong: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.. United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Hong Kong compared with United Kingdom?
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 United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the 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 United Kingdom 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-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.