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Dimension Pinned
🇭🇰 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.
Verified 2026-07-02 Source: EMRs 2011 / FCA, https://www.legislation.gov.uk/uksi/2011/99/contents/made
Regulator Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.
Verified 2026-07-03 Source: HKMA
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.
Verified 2026-07-02 Source: FCA
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).
Verified 2026-07-02 Source: estimate
Local substance Hong Kong local substance is included in the £349 pass. UK entity with UK mind and management, MLRO, adequate local staffing.
Verified 2026-07-02 Source: FCA
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).
Verified 2026-07-10 Source: FCA application fees: https://www.fca.org.uk/firms/authorisation/apply/fees
Ongoing cost Hong Kong ongoing cost is included in the £349 pass. FCA periodic fees, annual safeguarding audit, compliance headcount.
Verified 2026-07-02 Source: FCA
Passporting Hong Kong passporting is included in the £349 pass. None after Brexit, no EEA passport.
Verified 2026-07-02 Source: FCA
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.
Verified 2026-07-02 Source: thebanks.eu directory, cross-checked to FCA register and EBA register
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.
Verified 2026-07-02 Source: EMRs 2011
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.
Verified 2026-08-01 Source: HM Treasury, Modernising Payment Services Regulation consultation: https://www.gov.uk/government/consultations/modernising-payment-services-regulation
Difficulty rating Hong Kong difficulty rating is included in the £349 pass. 4. Rigorous on financial crime and safeguarding, very large market.
Verified 2026-07-02 Source: owner rating

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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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