SVF Stored Value Facility Licence

01 / BUSINESS SCOPE

Business Scope and Application Value

SVF regulation focuses on the pre-storage of monetary value and the issuer’s payment commitment, and may cover e-wallets, prepaid cards and personal remittance accounts. Whether a licence is required should be determined by examining the flow of funds and the contract, not merely the product name. Single-purpose exclusions, statutory exemptions and arrangements under which banks are deemed licensed must be analysed separately. Information verified as at 3 November 2026.

• Within the scope and conditions of the licence, issue or facilitate the issuance of SVFs, establishing a clear Hong Kong regulatory basis for e-wallets, prepaid stored-value cards and related payment services. Holding a licence does not mean that all proposed financial services are approved; the boundaries of each business activity must still be reviewed individually.
• A stored-value payment core business may be designed around top-ups, merchant payments and appropriate transfer functions, with a regulated fund-protection structure presented to banks and business partners. Bank account opening, clearing access or acquiring partnerships remain subject to independent assessment by the relevant institutions.
• Segregation of stored value, an effective trust and exit and refund mechanisms help protect users' funds and clarify their rights if the issuer becomes insolvent. These are regulatory safeguards and should not be promoted as an HKMA guarantee of principal or as meaning that stored value is a protected deposit.
• The Hong Kong Customs and Excise Department’s 2026 MSO Licensing Guide confirms that an SVF licensee may be exempt from obtaining a separate MSO licence for money services ancillary to its principal business. This advantage does not extend to a separate group company and does not exempt the business from local regulatory requirements overseas.
• Consistent risk, compliance and technology management standards help support business expansion and institutional cooperation. New products still require assessment of customer protection, transaction monitoring and stored-value impacts; being licensed must not be promoted as a guarantee of cross-border market access or commercial success.

02 / ENTRY REQUIREMENTS

Entry Conditions and Core Requirements

• First confirm whether the facility stores monetary value that can be used under its rules, and whether the issuer undertakes to accept or arrange payments. A licence must be obtained before issuing or facilitating the issuance of an SVF for which a licence is required. An application having been submitted does not, by itself, permit the commencement of regulated issuance before the licence is granted.
• The application must be made by a company and state its principal place of business in Hong Kong, postal address and email address. The principal business of a licensee should be issuing SVF; other business should generally be conducted only to the extent genuinely necessary to support SVF operations.
• The business plan should cover three years and explain target customers, use cases, fees and sources of profit, with fund flows showing top-ups, payments, merchant settlement and redemption. It must demonstrate that the business can operate safely, efficiently and sustainably, rather than relying solely on market-size forecasts.
• The capital threshold is only a minimum standard; sufficient operating and liquid funds are also needed to meet operating losses, settlement timing differences and exit costs. Meeting HKD 25,000,000 does not mean the HKMA will necessarily be satisfied that financial resources are adequate or that a licence will necessarily be granted.
• Directors, the chief executive and controllers must be fit and proper persons. Persons responsible for the day-to-day management and operation of the SVF scheme must have relevant knowledge and experience. Integrity, financial and regulatory backgrounds must be disclosed; nominal directorships or nominee arrangements cannot replace genuine scrutiny.
• Effective safeguards must be established for stored value and SVF float, usually through a trust with the relevant assets segregated from the company's own funds. Where there are sufficient grounds, an effective bank guarantee or insurance may be considered as an alternative or supplement; the specific arrangement is subject to regulatory assessment.
• Establish customer due diligence, sanctions screening, ongoing transaction monitoring and suspicious transaction reporting procedures proportionate to product risk. Simplified or exceptional treatment for low-risk instruments must satisfy the specific conditions in the guidelines; it should not be assumed that all anonymous or low-value products are unlawful or exempt from licensing.
• Systems must have reliable payment security, access controls, data protection and business continuity arrangements. Provide evidence of actual testing and controls covering cyberattacks, fraud and system interruptions; merely showing that software has been purchased does not demonstrate overall compliance.
• For a first application, independent assessments must be submitted in six areas: corporate governance and risk management, stored-value management, anti-money laundering, technology risk, payment security and business continuity. Applicants should first consult the HKMA on the assessors' qualifications and independence arrangements.
• Terms of use should clearly explain payment and refund responsibilities, fees, usage restrictions, complaints and dispute resolution. A licence is not a banking licence and does not automatically authorise lending, securities, insurance, virtual asset trading or fiat-referenced stablecoin issuance.

03 / PEOPLE & GOVERNANCE

Shareholders, directors and compliance personnel

• A licensee must appoint a chief executive officer and at least one alternate chief executive officer. The appointment of directors and relevant chief executives requires the consent of the Monetary Authority. The application should explain decision-making responsibilities, time commitments and cover arrangements for absences; the number of responsible officers required by the SFC must not be copied over without adjustment.
• The senior management team and key personnel responsible for financial management, internal controls, risk management, compliance and internal audit should be based in Hong Kong in accordance with the HKMA’s supervisory expectations. Merely maintaining a Hong Kong correspondence address while conducting all substantive management overseas is insufficient to demonstrate local governance.
• The board composition should provide checks and balances and collective professional judgment. Regulatory guidance generally uses one-third of the directors being independent non-executive directors as a benchmark, but the specific composition should still be assessed in light of the scale, complexity and nature of the business. It should not be promoted as a fixed composition that applies universally.
• Appoint a compliance officer and a money laundering reporting officer to oversee the AML framework and suspicious transaction reporting, respectively. They would normally be based in Hong Kong and have sufficient seniority and resources, as well as direct access to senior management. Depending on the institution’s size, one person may perform both functions, but independence and workload must be addressed.
• Approval and review duties should be segregated in financial and stored-value operations, avoiding a situation where one person sets up a payee, approves payment and reconciles the account. Roles may be arranged according to the organisation's size, but an authorisation list, cover arrangements and records of periodic access reviews should be maintained.
• The technology, information security and business continuity leads must understand the system architecture, payment flows and dependencies on key suppliers, and be able to explain test results and incident response. Using a group platform or outsourced services does not relieve the licensed management of responsibility for system security and service continuity.
• Establish procedures for assessing managers’ fitness and propriety, appointment and ongoing performance reviews. A manager’s appointment, departure and changes to relevant particulars must be notified in accordance with the law within fourteen days. Employees must also receive ongoing training tailored to their functions, rather than completing a one-off induction course only at the application stage.

04 / CAPITAL & PREMISES

Capital and business address requirements

Financial resources and sources of funds

A non-bank applicant must have paid-up share capital of at least HKD 25 million, or an equivalent amount of foreign-currency capital that meets the requirements, and other financial resources of an equivalent or higher level. Alternative financial resources must be satisfactory to the HKMA; credit facilities or a group guarantee cannot be substituted at the applicant’s discretion. The HKMA may require a higher level based on business risks. Customer stored value and exit refund costs must be safeguarded separately.

Statutory share capital, net assets, liquid capital and other financial resources are not the same concept. Capital is not a government fee or consultancy fee, and must not be conflated with client assets or reserve funds.

Hong Kong Business Address and Substantive Operations

• The application must state the principal place of business in Hong Kong, and the premises arrangements should support local management, compliance and regulatory access. The SVF guidelines reviewed do not specify a uniform minimum floor area or number of workstations; actual needs depend on staffing, information confidentiality, business model and risks.
• Retain evidence of the right to use the premises, office layout and access permissions, and explain the safeguards for client information, company records and sensitive operations. Whether a virtual address or shared office is compliant cannot be determined from its name alone; actual operations and confidentiality capabilities must be demonstrated.
• If top-ups, refunds or customer service are handled through physical outlets, clearly set out the operating arrangements, the safekeeping of cash and records, supervision of agents, and how complaints are received. Agent outlets cannot replace the overall governance of the licensee, nor may they issue stored value products under another person’s licence.
• Data centres, disaster recovery sites and cloud service arrangements must be subject to technology-risk and outsourcing assessments. It should not be claimed that all servers are legally required to be located in Hong Kong. If overseas systems or records are involved, ensure that effective access by the HKMA and auditors is not impeded.
• Before relocating, expanding physical channels or changing a key machine room, assess record accessibility, system continuity and the requirements for updating licence details, and notify the relevant parties or consult them in advance as required. Merely completing an address change with the Companies Registry does not mean that all regulatory formalities have been completed.

05 / APPLICATION DOSSIER

Application Document Checklist

• Prepare the completed SVF licence application form and the board resolution supporting the application, together with the certificate of incorporation, business registration certificate, articles of association and relevant allotment documents. Submit them in accordance with the HKMA's current prescribed format and certification requirements, avoiding obsolete company form numbers.
• Provide the shareholding and voting-rights structure traced from the applicant to the ultimate controller, together with controllers' application information, the latest audited financial statements of institutional controllers, and explanations of the source of funds. Complex trusts, nominee holdings or indirect control relationships must be clearly explained.
• Provide a paid-up share capital report certified by an external auditor and the applicable financial information, and submit audit reports or financial statements for the past three financial years. If a newly established company does not have a complete history, explain this accurately and confirm with the HKMA what alternative or supplementary documents are required.
• The business plan and three-year financial forecasts should explain product functions, customer regions, payment limits, fees and costs, accompanied by a complete fund-flow diagram, clearing and settlement arrangements, bank partnerships and key risk explanations, so that the forecasts can be cross-checked against the system design.
• Submit the prescribed application forms and background information for the chief executive, alternate chief executive, directors and controllers, together with the senior management and staff structure. Explain the responsibilities of key roles, Hong Kong presence arrangements and controls over manager appointments; providing CVs without explaining the governance division of responsibilities is insufficient.
• Submit independent assessment reports covering six core areas, describing the assessment scope, methodology, deficiencies and remediation status. Reports submitted with the initial application must meet the validity requirement of being no more than six months old after signing. Consider updating the assessment evidence after major system changes as well.
• Stored-value materials should include trust or alternative safeguard documents, dedicated bank account arrangements, external legal opinions and reconciliation procedures. They should explain how funds in transit, merchant receivables, redemption liquidity and refund administration expenses are included within the scope of protection.
• Submit anti-money laundering policies, institutional and product money laundering risk assessments, customer due diligence procedures, sanctions screening and transaction monitoring rules. Demonstrate internal escalation, reporting and confidentiality mechanisms for suspicious transactions, and set out record retention, staff responsibilities and training arrangements.
• Technical materials should explain system architecture, access and change controls, payment authentication, logs and vulnerability management. Also prepare evidence of security testing, business continuity and disaster recovery exercises, as well as outsourcing provider assessments, contracts and exit and replacement arrangements.
• Prepare the issuer-user contract, the operating rules for each SVF scheme and agreements among the participating parties. Specify, item by item, responsibility for funds, refunds, fees and complaint handling. The scheme exit plan must set out the trigger conditions, user notifications, refund process and sources of necessary resources.

06 / APPLICATION ROADMAP

Application process and required time

The HKMA has not published a uniform minimum processing period or approval deadline applicable to all SVF applications. Processing begins only after the information is complete and the application has been confirmed in writing as formal. Further documents, interviews or suspension may still be required during the process; a suspension of six months or more generally requires a fresh application. Any preparation or approval timelines quoted by a consultant are case-specific estimates, not regulatory commitments.

1. The first step is to map the products and funds flows and determine whether the activity falls under SVF licensing, a definition-based exclusion or a specific exemption, while identifying cross-border and other business boundaries. The advisory conclusion should be based on the actual contracts and transaction arrangements; the licence category must not be determined in advance solely by the wallet's name.
2. The second step is to discuss the business, shareholding, capital and local management arrangements with the HKMA’s licensing team before making a formal application. The HKMA strongly encourages prior engagement, but attending a meeting or receiving preliminary views does not constitute approval and does not guarantee that an application will subsequently be accepted.
3. The third step is to put in place personnel, financial safeguards, banking and technology arrangements, and translate policies into testable processes. At the same time, seek the HKMA’s views on the independent assessor to ensure that the assessor has not participated in operations or control implementation that will subsequently require independent review.
4. Step 4 is to prepare the application and evidence in accordance with Appendix B of the Licensing Summary, complete the independent assessment across all six areas and address any deficiencies. Before submission, check the validity period of the reports and all supporting materials. Avoid submitting only company documents and a business plan while leaving key controls to be built after licensing.
5. Step 5 is to submit the forms and required documents to the HKMA. Insufficient information may mean that the submission is treated only as a draft application. It is processed as a formal application only after the required complete information has been received and confirmed in writing; therefore, the date of receipt cannot automatically be treated as the start date for approval processing.
6. The sixth step is to respond to requests for supplementary documents and regulatory enquiries within the specified period, cooperate with interviews of directors, senior management or other personnel, and explain how the business and systems operate in practice. Failure to submit information on time may result in suspension; a prolonged suspension may also require updated materials or a new application.
7. At the seventh step, the HKMA decides whether to approve or refuse the application based on the minimum criteria and the applicant’s ability to meet them on an ongoing basis. It may impose conditions such as higher capital, stored-value protection, limits on the business scope or limits on instruments. After licensing, the actual effective date and conditions determine when operations may go live.
8. The eighth step is to implement licence-number disclosure, fee payment and ongoing reporting, and to commence business in accordance with the conditions and subject to supervision. Establish procedures for reporting changes and incidents. Being granted a licence does not mark the end of compliance work, and annual fee payment must not be misrepresented as annual reapproval of the licence.

07 / ACQUISITION & CHANGES

Acquisitions, Changes to Shareholders and Directors, and Completion

• An acquisition usually involves the shares and control of a licensed company; it is not the purchase of a licence certificate that can be used separately from the legal entity. First check the HKMA Register of AIs, the licence conditions and regulatory correspondence. Do not mistake a group brand or an overseas authorisation for Hong Kong authorisation held by the target company.
• Controller reviews do not look only at nominal shareholdings: a minority shareholder controller is a person able to exercise at least 10% but no more than 50% of the voting rights; a majority shareholder controller is a person able to exercise more than 50%; indirect controllers are also included. Voting arrangements and actual influence should be analysed together.
• Becoming a relevant controller requires the prior consent of the Monetary Authority. Indirect holdings and control exercised through agreements do not automatically remove the need for approval. Transaction documents should make the required regulatory consent a condition precedent to closing; transferring control first and applying afterwards creates compliance risk.
• The buyer should prepare information on the control chain, source of funds, financial strength and fit-and-proper persons, and explain the directors, senior management, capital and business model after the acquisition. Having held a licence historically does not mean that a new controller is automatically approved; the HKMA may impose additional requirements based on the new risks.
• Due diligence must verify whether stored value and float are fully covered, whether the trust is valid, and examine merchant settlement, funds in transit and refund liabilities. Do not look only at the company's net assets or total bank balances; mixed funds, reconciliation discrepancies and use of funds by related parties must all be investigated.
• Review anti-money laundering deficiencies, sanctions and fraud incidents, user complaints, data breaches, reliance on outsourcing and outstanding remediation. Transaction valuation and indemnity arrangements should reflect historical compliance risks; an acquisition does not erase the target company's existing liabilities.
• Before completion, confirm that the required consents for the new directors and chief executive have been obtained, and establish arrangements for the handover of personnel and systems and for service continuity. If, after the acquisition, new products are added, stored-value fund protection is changed, or a key platform is migrated, the applicable notification, consultation and independent assessment requirements must be met separately.

Shareholders, Directors and Other Material Changes

• As at 3 November 2026, the current SVF materials should be read together with the 2025 October Supervisory Application Note. Safeguarding stored value must cover not only the segregation of balances, but also funds in transit, direct debit inflows into merchants’ accounts and additional administrative funds needed for refunds.
• The October 2025 Application Note states that the stored value protection and management system should undergo an independent review or audit at least annually, and the HKMA should be consulted before material changes. If assets in a designated account fall below the recorded value of stored value and deposits, the matter should be escalated and reported promptly; action should not be deferred until the annual review.
• The HKMA circular dated 11 April 2025 requires SVF licensees to review, in light of their business models, the measures they have in place to prevent scams involving authorised payments, identify weaknesses and make corresponding system improvements. New product development must also be taken into account. The circular does not require banks’ measures to be adopted wholesale without analysis.
• The Code of Practice for the Computer Systems of Critical Infrastructure Industries, effective from June 12, 2026, applies to SVF licensees designated by the HKMA as critical infrastructure operators. Applicability must be checked against the designation status; the additional obligations for designated entities should not be presented as uniform requirements for all licensees.
• The Customs and Excise Department’s MSO Licensing Guide of May 2026 continues to clarify the exemption for money services incidental to an SVF’s principal business. The website should correct any categorical claim that an SVF must apply separately for an MSO licence as soon as it involves remittance, and verify whether the activity is genuinely an incidental service of the same licensee.
• Hong Kong’s fiat-referenced stablecoin issuer regime took effect on 1 August 2025 and must be assessed under its separate framework. The official website must not continue to describe stablecoin issuance categorically as an automatic business activity following the grant of an SVF licence, nor incorporate the stablecoin regime’s capital requirements into the SVF application threshold.
• Statements in existing guides on the same site concerning Schedule 6 minimum criteria, a uniform number of approval months, fixed licence renewal cycles and unverified section numbers should not be reused. This information is based on official HKMA licensing and supervisory documents and does not present consultant budgets or service timelines as statutory standards.

08 / ONGOING COMPLIANCE

Post-approval maintenance and ongoing responsibilities

• Continue to meet the minimum criteria in Schedule 3 and the conditions of the individual licence, and monitor capital, losses and liquidity pressures. Financial resources required by the regulatory requirements should be used only for the firm’s own business, not for transactions with shareholders, directors, senior management or affiliated companies.
• The applicable licence fee under Schedule 4 to Cap. 584 must be paid: the first payment is due within fourteen days after the licence takes effect, and subsequent payments are due on or before each anniversary of its effective date. The actual amount should be checked against the latest legislation or notice at the time of payment; consultancy fees must not be presented as statutory application fees.
• Stored value and SVF deposits must at all times be protected by effective legal and operational safeguards. Assets in designated accounts must be segregated from proprietary funds and funds used for other business, and reconciled regularly. Amounts payable by merchants and funds in transit must not be excluded from safeguarding calculations solely because they have not yet reached a bank account.
• The stored-value protection and management systems must undergo an independent review or audit at least annually, and external legal opinions and related documents must be retained on an ongoing basis. Consult the HKMA before making major changes. If a shortfall occurs, promptly notify senior management and the HKMA, explaining the cause and remedial measures.
• Conduct a formal risk assessment of the six core areas at least once a year, and use it to determine the frequency and scope of any further independent assessments. Assessments must also be arranged in accordance with regulatory requirements before a new service or material enhancement goes live. Do not misstate this as requiring all six full external assessments to be repeated every year in every case.
• Continue to conduct customer due diligence, risk classification, sanctions screening and transaction monitoring. Internally analyse suspicious circumstances and report to the Joint Financial Intelligence Unit as required by law. Reporting does not replace the management of account risks, and care must also be taken not to disclose to customers information that could prejudice an investigation.
• Under the current SVF anti-money laundering guidelines, customer due diligence information must be retained during the business relationship and for at least five years after it ends. Transaction records must be retained for at least five years after the transaction is completed. Any extended retention requirement must be observed; these periods should not be conflated with the retention period for company accounting records.
• Submit regulatory returns, financial and management information in the formats and within the time limits specified by the HKMA, and cooperate with on-site examinations, off-site analysis and auditor reports. Establish responsible persons and review procedures for submissions; missing regulatory documents cannot be explained away solely by having completed annual company filings.
• Maintain payment security and technology controls, and regularly test backup recovery, business continuity and incident response. Report material operational, system or reputational risks promptly as required by the relevant notices. Requirements differ by incident, so a uniform 24-hour reporting deadline should not be invented.
• Before outsourcing and throughout the engagement, assess the provider's capabilities, confidentiality, service levels, audit access, and exit and replacement arrangements. Even where the parent group handles technology or customer service, the licensee must retain ultimate control and the ability to discharge its responsibilities; regulatory responsibility cannot also be outsourced.
• Keep user terms, fees, redemption arrangements and complaint channels clear and readily accessible. Online tools should disclose the licence number; for device-based products, disclose it on the tool or packaging where practicable. Analyse the causes of complaints and fraud incidents rather than measuring customer protection solely by the customer service case-closure rate.
• Maintain an approved exit plan, retain sufficient funds to support orderly refunds and administrative expenses, and test whether the notification and refund procedures are operational. Ceasing business or having a licence revoked does not extinguish outstanding obligations to users and merchants; arrangements must be made in accordance with the HKMA’s requirements.

09 / FREQUENTLY ASKED

Frequently asked questions

10 / OFFICIAL REFERENCES

Official references and information verification

Information compilation date:3 November 2026The regulatory websites below are used to verify applicable laws, the latest forms, fees and registration status. Primary legislation, current requirements of the competent authorities and case-specific decisions take precedence.

Prepared by Rengangyongsheng (Hong Kong) Limited; professional explanation provided by Business Manager Tang Shangyong (Drew). This does not constitute legal, tax or investment advice for any specific case.