Hong Kong
June 4, 2026
19 min read
1. Legal Status
NFTs are legal in Hong Kong. There is no prohibition on the creation, sale, purchase, or holding of non-fungible tokens. The Securities and Futures Commission (SFC) has clarified that where an NFT is a "genuine digital representation of a collectible" — unique, non-fungible, and without payment or investment features — it does not fall within the definition of a "virtual asset" (VA) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) and is therefore outside the SFC's regulatory remit.
However, NFTs that go beyond the scope of a collectible — for example, those containing fungible elements, allowing holders to vote on arrangements, or representing fractional interests in underlying assets — may be classified as a virtual asset under the AMLO, a security under the Securities and Futures Ordinance (SFO), or an interest in a collective investment scheme (CIS). This substance-over-form approach means the regulatory treatment depends entirely on the token's structure and rights.
Sources:
- SFC, "Reminder to investors: Beware of risks associated with NFTs" (6 June 2022): https://www.sfc.hk/en/News-and-announcements/Policy-statements-and-announcements/Warning-statement-on-unregulated-virtual-asset-trading-platform
- Tanner De Witt, "SFC warns of risks associated with NFTs": https://www.tannerdewitt.com/sfc-warns-nft-risks/
- South China Morning Post, "Hong Kong extends regulatory rules to NFT-based collective investment schemes" (June 2022): https://www.scmp.com/tech/policy/article/3180689/hong-kong-securities-watchdog-says-some-nfts-will-require-licences
2. Regulatory Framework
2.1 Securities and Futures Ordinance (SFO) (Cap. 571)
The SFO is the primary legislation governing securities, futures, and leveraged foreign exchange trading in Hong Kong. NFTs that constitute "securities" — defined in Section 1, Part 1 of Schedule 1 to include shares, debentures, interests in CIS, and structured products — are subject to the full SFO regime, including:
- Prospectus requirements (Part II, Companies (Winding Up and Miscellaneous Provisions) Ordinance)
- Licensing requirements for intermediaries (Type 1: dealing in securities; Type 7: providing automated trading services)
- Market misconduct provisions
- Investor compensation fund coverage
2.2 Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) (Cap. 615)
Part 5B of the AMLO, effective 1 June 2023, established a mandatory licensing regime for Virtual Asset Service Providers (VASPs). Under the AMLO, a "virtual asset" is defined as a cryptographically secured digital representation of value that is expressed as a unit, can be transferred/stored/traded electronically, and is used (or intended to be used) as a medium of exchange or for payment or investment.
NFTs classified as virtual assets under this definition trigger the VASP licensing requirement if the platform provides:
- A service of exchanging VAs for money or other VAs
- Custody services for VAs
- An automated trading service matching VA orders
2.3 Dual Licensing Regime
Hong Kong operates a dual licensing regime for virtual asset trading platforms (VATPs):
- SFO Licence — Type 1 (dealing in securities) and Type 7 (automated trading services) for platforms trading security tokens
- AMLO VASP Licence — for platforms trading non-security virtual assets
The SFC recommends that applicants obtain licences under both regimes to avoid compliance issues if a token's classification changes over time.
Sources:
- SFC, "Virtual asset trading platform operators": https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators
- K&L Gates, "The Dual Licensing Regime for Virtual Asset Trading Platforms in Hong Kong" (July 2023): https://www.klgates.com/The-Dual-Licensing-Regime-for-Virtual-Asset-Trading-Platforms-in-Hong-Kong-Key-Highlights-Part-1-7-17-2023
- Gibson Dunn, "Hong Kong Licensing Regime for Virtual Asset Service Providers": https://www.gibsondunn.com/hong-kong-licensing-regime-for-virtual-asset-service-providers-passed-with-three-month-delay-to-implementation-timelines/
3. Securities Classification
The SFC applies a substance-over-form analysis when determining whether an NFT constitutes a security. The critical factors are:
3.1 When NFTs Are Securities
NFTs are likely to be classified as securities when they:
- Represent fractional ownership — fractionalized interests in real-world or digital assets (e.g., artwork, land, commodities) structured differently from a traditional fund
- Constitute CIS interests — where multiple purchasers' contributions are pooled and managed by a third party with the expectation of returns
- Have dividend-like features — profit-sharing, revenue distribution, or yield mechanisms
- Confer governance rights over pooled assets or investment arrangements
3.2 When NFTs Are Not Securities
NFTs are generally not securities when they:
- Are a "genuine digital representation of a collectible" — unique, non-fungible art, music, or cultural artifacts
- Provide purely utility functions (access passes, membership tokens) without investment features
- Do not involve pooling of funds or management by a third party
3.3 SFC Guidance on Fractionalized NFTs
The SFC has specifically warned that fractionalized NFTs structured in a form similar to securities, or representing an interest in a CIS, may require:
- SFC licensing for persons marketing or distributing such NFTs
- Authorisation under the SFO for any offer to the Hong Kong public
- Compliance with prospectus requirements
The SFC gave the example of fractionalised interests in real-world or digital assets (such as artwork or land) as arrangements that may constitute CIS even when structured differently from a traditional fund.
Sources:
- SFC circulars on tokenisation (2 November 2023): https://www.fintechanddigitalassets.com/2023/11/hong-kongs-sfc-lays-out-regulatory-pathway-for-tokenisation/
- CMS Expert Guide, "Crypto Regulation in Hong Kong": https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/hong-kong
- Global Legal Insights, "Fintech Laws and Regulations 2025 — Hong Kong": https://www.globallegalinsights.com/practice-areas/fintech-laws-and-regulations/hong-kong/
4. IP Rights & Licensing
Hong Kong's intellectual property framework applies to NFTs under existing legislation:
- Copyright Ordinance (Cap. 528): Copyright in a work vests in the creator. Purchasing an NFT does not transfer copyright ownership unless the creator expressly assigns rights in writing. Most NFT purchasers receive only the token and a limited licence to display the associated artwork for personal use.
- Trade Marks Ordinance (Cap. 559): Minting an NFT depicting a third party's registered trade mark without authorisation may constitute infringement.
- Patent Ordinance (Cap. 514): The underlying technology of an NFT (smart contract logic, novel minting mechanisms) may be patentable.
The Hong Kong government released a public consultation paper on copyright and artificial intelligence in July 2024, addressing AI-generated content (AIGC) and concluding that existing Copyright Ordinance provisions on computer-generated works already support copyright protection for AI-generated NFT artwork.
The Hong Kong Intellectual Property Department published its 2025 Policy Blueprint, which included references to digital assets and blockchain technology but did not propose NFT-specific IP amendments.
Sources:
- Norton Rose Fulbright, "NFTs and Intellectual Property Rights — Hong Kong SAR": https://www.nortonrosefulbright.com/en-hk/knowledge/publications/1a1abb9f/nfts-and-intellectual-property-rights
- Mayer Brown, "Unlocking Innovation: The Hong Kong 2025 Policy Blueprint for Intellectual Property": https://www.mayerbrown.com/en/insights/publications/2025/10/unlocking-innovation-the-hong-kong-2025-policy-blueprint-for-intellectual-property
- HK Lawyer, "Stablecoins, NFTs, VATP Licence and Type 9 Licence Uplift": https://www.hk-lawyer.org/content/stablecoins-nfts-vatp-licence-and-type-9-licence-uplift-recent-developments
5. Taxation
Hong Kong has no capital gains tax, no VAT/GST, and no sales tax. This makes it one of the most tax-efficient jurisdictions globally for NFT transactions.
5.1 Profits Tax
Under the Inland Revenue Ordinance (IRO) (Cap. 112), profits arising in or derived from Hong Kong from a trade, profession, or business carried on in Hong Kong are subject to Profits Tax. The key determination is whether NFT activities constitute a business or a passive investment:
| Scenario | Tax Treatment |
|---|---|
| NFT held as long-term investment | Not taxable (no capital gains tax) |
| Active NFT trading as business | Profits taxable: 8.25% on first HKD 2 million; 16.5% thereafter (corporations); 15% for unincorporated businesses |
| NFT minting/creation as business | Revenue taxable as business profits |
| NFT royalties (ongoing) | Taxable as business income if arising from trade |
| Occasional sale of NFT | Generally not taxable (capital in nature) |
The Inland Revenue Department (IRD) published Departmental Interpretation and Practice Notes No. 39 (DIPN 39), which was updated in 2025 to address digital assets including cryptocurrency and DeFi activities. The IRD considers factors including: frequency of transactions, holding period, reasons for disposal, method of financing, and whether the taxpayer has expertise in the asset class.
5.2 Stamp Duty
NFT transactions are generally not subject to stamp duty unless the NFT represents an interest in Hong Kong stock or real property. The Stamp Duty Ordinance (Cap. 117) applies to instruments (documents) evidencing transactions in "Hong Kong stock" (stock of a company registered in Hong Kong) or immovable property.
Sources:
- IRD, Departmental Interpretation and Practice Notes No. 39 (DIPN 39): https://www.ird.gov.hk/eng/pdf/dipn39.pdf
- KPMG China, "Taxation of digital assets in Hong Kong": https://kpmg.com/cn/en/home/insights/2020/04/tax-alert-8-hk-taxation-of-digital-assets-in-hk.html
- HKWJ Tax Law, "Crypto Tax Regulations Around the World": https://www.hkwj-taxlaw.hk/crypto-tax/
6. Licensing/Registration Requirements
6.1 VASP Licence (AMLO Part 5B)
NFT platforms trading virtual assets (where NFTs meet the VA definition) must obtain a VASP licence from the SFC.
| Field | Detail |
|---|---|
| Licence Name | Virtual Asset Service Provider (VASP) Licence |
| Issuing Authority | Securities and Futures Commission (SFC) |
| Governing Legislation | Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Part 5B |
| Licence Type | Activity-based |
| Who Must Apply | Centralised VA trading platforms operating in Hong Kong or actively marketing to Hong Kong investors |
| Capital Requirements | Paid-up share capital of HKD 5,000,000 (approximately USD 640,000) |
| Key Personnel | Minimum 2 SFC-approved Responsible Officers (ROs); ROs must pass competency exams, background checks; relevant qualifications (CFA, FRM, or equivalent) |
| Application Fee | HKD 4,740 per regulated activity (for SFO licence); VASP application fees per SFC schedule |
| Annual Fee | Per SFC fee schedule |
| Application Process | Consolidated application via WINGS platform for both SFO and AMLO licences; external assessor report required |
| Processing Time | SFC performance pledge: up to 15 weeks |
| Cybersecurity Requirements | Regular independent cybersecurity audits and penetration tests; at least 98% of client assets in cold storage |
| Insurance Requirements | Adequate insurance coverage for risks associated with custody of virtual assets |
| Ongoing Obligations | Monthly reporting; material change notifications; annual external audit; compliance with SFC VATP Guidelines and AML/CFT requirements |
| Renewal | Annual; subject to continued compliance |
| Territorial Scope | Applies to platforms operating in or actively marketing to Hong Kong |
| Transition Deadline | Pre-existing VATPs were required to submit applications by 29 February 2024 or cease operations by 31 May 2024 |
6.2 SFO Licences (Type 1 and Type 7)
Platforms trading NFTs classified as securities require:
| Field | Detail |
|---|---|
| Licence Name | Type 1 (Dealing in Securities) and Type 7 (Providing Automated Trading Services) |
| Issuing Authority | SFC |
| Governing Legislation | Securities and Futures Ordinance (Cap. 571) |
| Capital Requirements | HKD 5,000,000 paid-up share capital; liquid capital requirements per Securities and Futures (Financial Resources) Rules |
| Key Personnel | Minimum 2 ROs per regulated activity |
| Application Fee | HKD 4,740 per regulated activity |
| Ongoing Obligations | Semi-annual financial returns; compliance with SFC Code of Conduct; client money rules |
6.3 Current Licensing Status
The licensed VATP cohort has expanded substantially through 2026. As of 29 May 2026, the SFC's official list shows 13 formally licensed VATPs (including OSL Exchange, HashKey Exchange, HKVAX, HKbitEX, Accumulus, DFX Labs, EX.IO, PantherTrade, YAX, Bullish, BGE, VDX, and Bixin.com), plus several "deemed-to-be-licensed" applicants still pending approval (which the SFC stresses are NOT formally licensed). This is up sharply from the nine entities licensed as of early 2025, following a batch of approvals in April 2026. During 2024, several major exchanges (OKX, Bybit, Gate.HK, Huobi HK) had withdrawn their original applications, indicating that the regime requires significant operational and compliance investment, though some have since re-engaged as deemed-licensed applicants.
Sources:
- SFC, "Lists of virtual asset trading platforms" (official register, updated 29 May 2026): https://www.sfc.hk/en/Welcome-to-the-Fintech-Contact-Point/Virtual-assets/Virtual-asset-trading-platforms-operators/Lists-of-virtual-asset-trading-platforms
- SFC, "Virtual asset trading platform operators": https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators
- Hacken, "Hong Kong Crypto License: Key Insights for 2025": https://hacken.io/discover/hong-kong-crypto-license/
- Tanner De Witt, "VATP Regulation in Hong Kong: The licence application requirements": https://www.tannerdewitt.com/the-application-for-a-vatp-licence/
- PwC, "2023 SFC Virtual asset trading platform (VATP) Regime": https://www.pwchk.com/en/asset-management/sfc_vatp_regime_sep2023.pdf
7. AML/KYC/Compliance
7.1 AMLO Requirements for Licensed VASPs
Licensed VASPs must comply with Schedule 2 of the AMLO, which imposes:
- Customer due diligence (CDD): Identity verification before establishing business relationships; ongoing monitoring
- Enhanced due diligence (EDD): For politically exposed persons, high-risk jurisdictions, correspondent relationships
- Record keeping: Minimum 6-year retention for all transaction and CDD records (note: longer than the FATF minimum of 5 years)
- Suspicious transaction reporting (STR): Mandatory reporting to the Joint Financial Intelligence Unit (JFIU) under AMLO Section 25A
- Travel rule: VASP-to-VASP information sharing for virtual asset transfers (originator/beneficiary details)
- Screening: Sanctions screening against UN/HKMA sanctions lists
- Internal controls: Designated compliance officer, AML/CFT policies, staff training, independent audit
7.2 NFT Platforms Outside VASP Regime
NFT platforms dealing exclusively in "genuine digital representations of collectibles" that do not meet the VA definition under AMLO are not subject to the VASP licensing and AML/CFT regime. However, they remain subject to:
- General criminal law provisions on money laundering (Organized and Serious Crimes Ordinance, Cap. 455)
- Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)
- United Nations Sanctions Ordinance (Cap. 537)
7.3 FATF Alignment
Hong Kong is a FATF member jurisdiction. The VASP regime was designed to comply with FATF Recommendation 15 (new technologies) and the updated FATF Guidance on Virtual Assets and Virtual Asset Service Providers (October 2021). Hong Kong's mutual evaluation by FATF is a key driver of its regulatory approach.
Sources:
- AMLO (Cap. 615), Schedule 2: https://www.elegislation.gov.hk/hk/cap615
- Dentons, "Hong Kong's evolving regulatory regime for virtual assets" (January 2025): https://hongkong.dentons.com/en/insights/articles/2025/january/27/hong-kong-evolving-regulatory-regime-for-virtual-assets
- A&O Shearman, "Investigations update: Hong Kong authorities ramp up enforcement in virtual assets" (2024): https://www.aoshearman.com/en/insights/cross-border-white-collar-crime-and-investigations-review-2024/investigations-update-hong-kong-authorities-ramp-up-enforcement-in-virtual-assets-and-other-sectors
8. Enforcement
8.1 JPEX (September 2023)
The most significant enforcement action in Hong Kong's virtual asset sector. In September 2023, the SFC referred JPEX — an unregulated virtual asset trading platform — to the Hong Kong Police Force (HKPF) for investigation. JPEX had actively promoted its services to the Hong Kong public through social media influencers and over-the-counter (OTC) crypto shops while operating without a VASP licence. Over 2,000 complaints were received, with estimated losses of approximately HKD 1.4 billion (USD ~180 million). The investigation resulted in over 60 arrests for alleged fraud.
8.2 Hounax (November 2023)
In November 2023, the SFC designated Hounax — another unlicensed platform — as suspicious and warned investors. The Hong Kong police received reports from 145 individuals claiming losses of approximately HKD 148 million (USD ~19 million). Hounax had used social media to falsely claim associations with Coinbase's founding team and investments from Sequoia Capital and IDG Capital.
8.3 SFC Enforcement Approach
Following the JPEX and Hounax incidents, the SFC and HKPF have significantly increased enforcement capacity in the virtual asset sector. The SFC maintains a publicly accessible Alert List of suspicious virtual asset trading platforms and unregulated entities. The SFC has also enhanced coordination with the HKPF and the Customs and Excise Department on crypto-related enforcement.
8.4 NFT-Specific Enforcement
As of June 2026, there have been no public SFC enforcement actions specifically targeting NFT platforms or NFT-related securities offerings. However, the SFC has made clear through its public statements that any NFT structured as a security or CIS interest will be treated under the SFO and persons involved in marketing or distributing such NFTs without a licence face enforcement action.
Sources:
- Skadden, "JPEX Is Test Case for Hong Kong's New Regulatory Regime" (November 2023): https://www.skadden.com/insights/publications/2023/11/jpex-and-hong-kongs-tightened-regulatory-controls
- A&O Shearman, "Investigations update: Hong Kong authorities ramp up enforcement" (2024): https://www.aoshearman.com/en/insights/cross-border-white-collar-crime-and-investigations-review-2024/investigations-update-hong-kong-authorities-ramp-up-enforcement-in-virtual-assets-and-other-sectors
- SFC, "Warning statement on unregulated virtual asset trading platform": https://www.sfc.hk/en/News-and-announcements/Policy-statements-and-announcements/Warning-statement-on-unregulated-virtual-asset-trading-platform
- The Block, "Hong Kong launches probes into alleged $15.4 million crypto scam by Hounax" (November 2023): https://www.theblock.co/post/264724/hong-kong-crypto-probe-hounax
9. Recent Developments (2025–2026)
| Date | Development |
|---|---|
| 20 April 2026 | SFC issued a circular (press release 26PR59) launching a pilot regulatory framework permitting 24/7 secondary trading of tokenised SFC-authorised investment products on SFC-licensed VATPs, settled using regulated stablecoins/tokenised deposits; tokenised money market funds are the inaugural eligible products. This is the clearest signal yet that financialised/fractionalised digital-asset structures (the category most relevant to NFT securities risk) are being brought onto regulated venues rather than left in a grey zone |
| 29 May 2026 | SFC official VATP register shows 13 formally licensed platforms (up from nine in early 2025) plus several deemed-to-be-licensed applicants, following an April 2026 batch of approvals |
| 24 December 2025 | FSTB and SFC published consultation conclusions on legislative proposals to establish licensing regimes for virtual asset dealing and custodian services (101 and 93 submissions respectively; >190 total responses); dealing rules to mirror Type 1 securities-dealing requirements, custodian regime focused on securing private keys and protecting client assets. Target: introduce bill into the Legislative Council in 2026. A separate one-month consultation on VA advisory/management licensing closed 23 January 2026 |
| 1 August 2025 | Stablecoins Ordinance (Cap. 656) came into operation; licensing regime for fiat-referenced stablecoin issuers administered by HKMA |
| 2 November 2023 | SFC issued two circulars on tokenisation during Hong Kong FinTech Week — guidance on tokenised securities-related activities and tokenisation of SFC-authorised investment products |
| 1 June 2023 | VASP licensing regime under AMLO Part 5B commenced |
| 29 February 2024 | Deadline for pre-existing VATPs to submit licence applications |
| 31 May 2024 | Deadline for unlicensed VATPs to cease operations |
| 2025–2026 (ongoing) | SFC's ASPIRe roadmap — initiatives to improve access to regulated virtual asset markets |
Key trends for NFTs:
- Hong Kong's explicit pro-virtual-asset policy stance creates a favourable environment for compliant NFT businesses
- The expanding regulatory perimeter (VASP regime, stablecoin regulation, upcoming dealer/custodian rules) is progressively capturing more types of digital asset activity
- Fractionalized NFTs and NFT derivatives face the highest regulatory risk as they are most likely to trigger securities classification; the April 2026 tokenised-products secondary-trading pilot shows the SFC's preferred response is to channel such financialised structures onto licensed VATPs rather than ban them
- The forthcoming 2026 dealer and custodian regulations may impact NFT custody and secondary market trading activities
Sources:
- SFC, "SFC unveils new regulatory framework to allow secondary trading of tokenised SFC-authorised investment products" (press release 26PR59, 20 April 2026): https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=26PR59
- HK Government, "FSTB and SFC publish consultation conclusions on legislative proposals for regulating virtual asset dealing and custodian services" (24 December 2025): https://www.info.gov.hk/gia/general/202512/24/P2025122400265.htm
- Mayer Brown / JSM, "Hong Kong pilots 24/7 secondary trading of tokenised SFC-authorised investment products" (2026): https://www.jsm.com/publications/2026/hong-kong-pilots-24-7-secondary-trading-of-tokenised-sfc-authorised-investment-products/
- CoinDesk, "Hong Kong's SFC, FSTB target 2026 legislation for virtual asset dealer and custodian rules" (December 2025): https://www.coindesk.com/policy/2025/12/25/hong-kong-regulators-target-2026-legislation-for-virtual-asset-dealer-and-custodian-rules
- HK Lawyer, "Hong Kong's Dual Licensing Regime for Virtual Asset Trading Platforms and Virtual Asset Service Providers": https://www.hk-lawyer.org/content/hong-kong%E2%80%99s-dual-licensing-regime-virtual-asset-trading-platforms-and-virtual-asset-service
10. Assessment
Regulatory Posture: Balanced / Pro-Innovation
Hong Kong adopts a proactive but structured approach to NFT regulation. The government has explicitly positioned Hong Kong as a virtual asset hub, while implementing robust licensing and investor protection frameworks. The substance-over-form approach to NFT classification provides reasonable certainty while maintaining flexibility.
Strengths:
- No capital gains tax, no VAT/GST — highly tax-efficient for NFT transactions
- Clear SFC guidance on when NFTs are/are not securities
- Comprehensive VASP licensing regime aligned with FATF standards
- Government policy actively supports virtual asset innovation (ASPIRe roadmap)
- Dual licensing regime provides regulatory clarity for platforms dealing in both security and non-security tokens
- Strong enforcement track record (JPEX, Hounax) demonstrates credibility
Weaknesses:
- High licensing costs and capital requirements (HKD 5 million) create barriers for smaller NFT platforms
- Withdrawal of major exchanges from licensing process suggests compliance burden may be excessive
- No NFT-specific legislation — classification uncertainty for novel hybrid tokens
- CIS definition is broad and may inadvertently capture NFT projects with community governance features
- HKMA position on NFT-related banking activities remains unclear
Comparison: Hong Kong's approach is more explicitly pro-innovation than Singapore's restrictive-leaning stance and far more developed than most EU member states under MiCA (which largely excludes unique NFTs). Compared to the US, Hong Kong provides greater regulatory certainty through its defined VASP regime, though both jurisdictions apply a securities law analysis based on substance over form. Hong Kong's tax treatment is significantly more favourable than Japan's and South Korea's regimes.
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Verification Notes
- SFC VASP licensing requirements verified against SFC official website (sfc.hk) and published guidelines
- AMLO Part 5B provisions verified against Hong Kong e-Legislation (elegislation.gov.hk)
- JPEX enforcement details (2,000+ complaints, HKD 1.4 billion losses, 60+ arrests) verified via Skadden analysis and A&O Shearman investigation update
- Hounax details (145 individuals, HKD 148 million losses) verified via The Block and Fortune reporting
- Capital requirement (HKD 5 million) verified via multiple law firm analyses
- Correction (2026-06-04): §6.3 previously stated "nine entities had been granted VASP licences ... as of early 2025." This figure became stale. Updated to 13 formally licensed VATPs as of 29 May 2026 (plus several deemed-to-be-licensed applicants) per the SFC's official register (sfc.hk Lists of virtual asset trading platforms), following an April 2026 batch of approvals. The early-2025 figure of nine is retained as historical context.
- Correction (2026-06-04): §8.4 "As of March 2026" updated to "As of June 2026" to reflect the current research date; the substantive conclusion (no NFT-specific public enforcement actions) is unchanged after re-verification.
- Stablecoins Ordinance designation (Cap. 656) and effective date (1 August 2025) re-verified against HK e-Legislation (elegislation.gov.hk/hk/cap656) and HKMA implementation press release (20250729-4)
- Tax rates (8.25%/16.5% profits tax) verified against IRD published rates
- DIPN 39 (2025 update) referenced via KPMG and industry analysis; original DIPN 39 available on IRD website
- NFT classification stance (SFC reminder: "genuine digital representation of a collectible" outside remit; fractionalised/financialised NFTs may be securities/CIS) re-verified June 2026 — unchanged; no NFT-specific SFC rule or enforcement action since the 2022 reminder
- Added (2026-06-04) to Recent Developments and verified against primary sources: 20 April 2026 SFC tokenised-products secondary-trading pilot (SFC PR 26PR59); 24 December 2025 FSTB/SFC consultation conclusions on VA dealing and custodian licensing (info.gov.hk P2025122400265)
- All URLs accessed and verified during June 2026 research