A detailed explanation of Hong Kong’s virtual asset roadmap

Author: Bitke

The Securities and Futures Commission (SFC) of Hong Kong officially released the newly formulated "ASPIRe" roadmap, which is undoubtedly the "highlight" during this year's Consensus Conference. The roadmap details the regulatory plan for Hong Kong's virtual asset market, aiming to promote Hong Kong to become the world's leading virtual asset center through five core pillars. Bitkoala Finance will interpret this roadmap in detail in this article.

The five pillars of the "ASPIRe" roadmap are: Access, Safeguards, Products, Infrastructure and Relationships.

Access

Against the backdrop of the growing prosperity of the global virtual asset market, Hong Kong is actively seeking to establish itself as an international digital asset hub. With the market size exceeding US$3 trillion in 2024, global liquidity has shown a distinctly fragmented feature, and regulatory policies vary from country to country, forming a diverse and complex ecosystem. The first pillar, "Access", was established to address this problem. Its core goal is to open up the connection channel between Hong Kong and the international market by simplifying market access, optimizing the licensing framework and attracting global participation.

The core objectives of "Access" are as follows:

1. Simplify market access

Clarify the licensing system: SFC aims to establish a clear and transparent licensing framework covering virtual asset trading platforms (VATPs), over-the-counter transactions (OTC) and custody services. Through the principle of "same industry, same risk, same rules", reduce the uncertainty faced by market participants when entering the Hong Kong market.

Lower administrative barriers: Under the premise of ensuring regulatory requirements, simplify the application process as much as possible to allow compliant companies to enter the market quickly and avoid missing market opportunities due to cumbersome procedures.

2. Attract global platforms and liquidity

International standard docking: Through communication and coordination with international regulators, ensure that Hong Kong's licensing and regulatory standards are consistent with the global mainstream market, so as to attract leading foreign platforms to expand their business to Hong Kong.

Introducing global order flows: When global platforms and institutional investors can operate in an environment with clear rules, Hong Kong can use this to attract cross-border order flows and institutional liquidity, and improve the liquidity and price discovery efficiency of the local market.

Third, expand investor participation channels

Diversify market players: In addition to existing licensed trading platforms, the SFC hopes to attract more types of participants (such as OTC dealers, custodians, liquidity providers, etc.) to enter the market through access measures to form a more diversified virtual asset ecosystem.

Promote cross-border capital flows: Connecting to global markets not only helps to introduce foreign capital, but also provides local investors with more international investment options, thereby promoting the maturity and stable development of the market.

Fourth, the establishment of licenses and standards

Formulate unified access standards: formulate targeted and differentiated access requirements for different types of virtual asset service providers (such as trading platforms, OTC dealers, custodians, etc.), which not only ensure market security but also do not inhibit innovation.

Strengthen the principle of "same industry, same risk, same rules": ensure that all participants entering the market, regardless of their business model, follow unified regulatory requirements to create a fair environment for market competition.

Five, attract international platforms

Optimize the foreign investment process: reduce the time and cost of foreign-funded enterprises entering the Hong Kong market by simplifying the registration and application procedures and providing clear guidance.

Establish a global cooperation mechanism: conduct regulatory dialogue and cooperation with other major financial centers (such as Singapore, the European Union, etc.), promote cross-border regulatory coordination, prevent regulatory arbitrage, and thus attract more international participants.

Sixth, promote market diversification

Expand market coverage: In addition to traditional licensed trading platforms, encourage new businesses such as OTC and custody services to enter the regulatory field of vision to increase market levels and service diversity.

Improve market transparency: Through information disclosure and data sharing mechanisms, ensure that all market participants can obtain fully transparent market information and reduce the risks brought by information asymmetry.

So, what are the expected effects? In fact, by establishing a clear, inclusive and internationally qualified market access mechanism, Hong Kong will be able to attract more world-leading virtual asset platforms to settle in, further consolidating its position as a regional and global virtual asset hub. Attracting international order flows and institutional funds will greatly improve local market liquidity, promote the optimization of price discovery mechanisms, and provide investors with more diversified and efficient trading opportunities.

Through international regulatory standards and cross-border cooperation mechanisms, Hong Kong can not only attract foreign investment, but also provide local investors with a broader international market perspective and help the long-term development of the market. Clear and specific licensing processes and regulatory requirements will help lower the barriers for emerging companies and international platforms to enter the Hong Kong market, stimulate market vitality, and promote continuous innovation in technology and business models.

Safeguards

In recent years, the global virtual asset market has experienced a number of market-shaking risk events (such as the collapse of the FTX exchange and the depegging of the Terra stablecoin), exposing the problems of lack of supervision and insufficient risk control. As an international financial center, Hong Kong has been committed to ensuring market security and investor interests while promoting innovation. The "Safeguards" pillar was proposed in this context. Its core is to reduce the compliance burden while ensuring system security through risk-proportional supervision and technology-neutral regulatory measures, and to build a solid protection network for all market participants.

The core objectives of "Safeguards" are as follows:

1. Ensure market security and investor protection

By establishing unified and flexible regulatory requirements, ensure that trading platforms, custodians and other virtual asset service providers can effectively prevent risks such as fraud and market manipulation during their operations.

Strengthen investor protection measures to reduce the risk of capital loss due to regulatory loopholes or insufficient internal risk control.

2. Achieve risk-proportional supervision

Implement differentiated regulatory strategies based on the risk attributes of virtual asset products or services to ensure that high-risk businesses are subject to stricter monitoring, while low-risk businesses enjoy moderately relaxed compliance requirements.

Be results-oriented, avoid overly rigid rules, and encourage the market to strike a balance between security and innovation.

3. Promote the integration of technology and regulation

Encourage the adoption of technology-neutral regulatory standards, promote the industry to adopt advanced scientific and technological means in asset custody, fund isolation, real-time monitoring, etc., and improve regulatory transparency and efficiency.

4. Risk-proportional regulatory framework

Classification supervision: Different regulatory standards will be formulated for trading platforms, custody services, etc. according to the types of virtual assets, business models and risk levels.

Flexible adjustment: Regulators will regularly assess market risks and adjust regulatory measures in a timely manner to ensure that they do not overly restrict innovation and can prevent and control systemic risks.

5. Technology-neutral custody and fund isolation requirements

Custody standards: Promote the formulation of result-oriented custody requirements to ensure that user funds are strictly isolated from the platform's own assets.

Technical innovation support: encourage platforms to innovate in the use of cold/hot wallet combination storage, real-time monitoring and independent auditing, so as to ensure asset security and improve operational efficiency.

Sixth, market monitoring and risk early warning mechanism

Data-driven monitoring: deploy blockchain analysis and big data tools to monitor on-chain transactions in real time and quickly discover abnormal trading behaviors and potential risks.

Cross-institutional cooperation: strengthen information sharing and collaboration with other regulatory agencies and law enforcement agencies, form a cross-border regulatory linkage mechanism, and jointly combat market manipulation, money laundering and other illegal activities.

Seventh, insurance and compensation mechanism construction

Risk transfer tools: explore the establishment of a virtual asset compensation fund or insurance mechanism to compensate investors for losses caused by unexpected risks such as accidents and hacker attacks.

Accountability: Severe penalties will be imposed on violations or internal management errors, and the sense of responsibility of platforms and practitioners will be strengthened to enhance the security of the overall market.

Under the "security" pillar, through comprehensive and flexible security supervision measures, investors will gain greater confidence, thereby attracting more institutional and retail investors to participate. In the global virtual asset market competition, having a sound security system will make Hong Kong more attractive, help Hong Kong become an international virtual asset center, promote technological innovation in asset custody and risk monitoring in the blockchain and financial technology fields, and achieve the organic integration of traditional financial protection and digital asset security.

However, although risk-proportional supervision can reduce the compliance burden of some companies, full implementation still requires a lot of resource investment and technical support. Excessive supervision may inhibit market innovation. How to ensure safety without stifling the driving force of innovation is an issue that regulators need to continue to explore. The virtual asset market is highly globalized. Regulatory differences in different jurisdictions may lead to regulatory arbitrage and cross-border risks, which require international cooperation and coordination.

Products

With the continuous maturity of the global virtual asset market and the diversification of investor needs, the Hong Kong virtual asset market faces the problems of single products and insufficient innovation. The existing regulatory framework mainly covers basic services such as virtual asset trading platforms (VATPs), but there are still large gaps in new coin listings, derivatives trading, pledges, lending, etc. In order to meet the needs of different investors (including institutions and retail investors) and promote the market to develop in a multi-level and professional direction, the Hong Kong Securities and Futures Commission proposed the "Products" pillar in the "ASPIRe" blueprint. Its core goal is to broaden the product line and promote the emergence of new investment tools and financial services, so as to achieve a dual balance between regulation and innovation.

The core objectives of "Products" are as follows:

1. Expand investment options and meet diverse needs

Provide risk-matched products and services for investors with different risk preferences and investment experience.

Introduce more complex products for professional investors, such as new currency issuance, derivatives trading, and margin financing tools.

2. Promote product innovation and diversification

Encourage financial technology innovation, combine traditional financial products (such as ETFs, bonds, securities, etc.) with blockchain technology, and promote product "tokenization".

Break the restrictions of existing products, explore new business models such as pledge, lending and derivatives trading, and innovate product functions under a strict risk management framework.

3. Establish clear product classification and regulatory standards

By "seeing through" the product classification framework, determine regulatory standards based on actual business and risk attributes to avoid regulatory gaps.

Establish appropriate thresholds and compliance requirements for new products to protect the interests of investors without suppressing market vitality.

4. Products and derivatives trading exclusively for professional investors

New coin listing: Explore allowing new coins to be listed in a regulated environment designed for professional investors, ensuring that the project undergoes strict due diligence and information disclosure.

Derivatives trading: Research the introduction of virtual asset derivatives trading mechanisms, provide hedging, leverage and other trading functions, enable institutional investors to manage risks more effectively, and improve market liquidity.

V. Risk-adapted margin financing and leverage services

Formulate margin financing requirements similar to those in the traditional securities market, including initial margin, variable margin and volatility adjustment measures, to ensure that the market has effective risk control measures when introducing leveraged trading.

Promote cooperation between regulatory authorities and market participants to formulate risk management standards applicable to the virtual asset sector.

Sixth, explore pledge, lending and other innovative financial services

Pledge services: Allow compliant platforms to provide digital asset pledge services on the premise of ensuring the security of fund custody, giving investors profit opportunities.

Lending business: Explore the introduction of lending services under strict operating and risk management rules, balance returns and risks, and provide the market with more financing channels.

VII. Establish a "Perspective" Product Classification Framework

Clearly define the regulatory attributes of various virtual asset products, classify them according to actual business models and risk characteristics, and ensure that regulatory measures are accurately implemented.

Through the classification standards, regulators, market participants and investors can reach a consensus on product risk identification and prevention and control, and reduce regulatory blind spots.

The expansion of product lines will enrich the investment tools of the Hong Kong market, meet the investment needs of institutions and retail investors at different levels, and further enhance market activity and liquidity. Diversified products and services can attract global high-quality projects and international institutions to enter the market, and consolidate Hong Kong's position as a regional virtual asset center. By clarifying product classification and establishing professional regulatory standards, it will help reduce investor risks and promote the healthy and sustainable development of the market.

Of course, the introduction of new products and derivative businesses is likely to bring higher risks. How to ensure strict risk control while stimulating market innovation is an issue that regulators need to continue to pay attention to. The launch of diversified products may increase the compliance burden of platforms and institutions. How to reduce unnecessary costs while ensuring regulatory effectiveness will test the wisdom of policymakers. The launch of complex products requires investors to have a high level of risk identification ability. Therefore, investor education must be strengthened simultaneously to ensure that all parties in the market have a full understanding of product characteristics and risks.

Infrastructure

Against the backdrop of the rapid development of the virtual asset market, regulators are faced with the huge challenge of how to grasp market dynamics in real time, prevent risks, and combat cross-border illegal activities. Traditional regulatory models often rely on post-event investigations, while the decentralization, cross-border nature, and anonymity of virtual asset transactions make regulation even more difficult. To this end, the Hong Kong Securities and Futures Commission (SFC) proposed the "Infrastructure" pillar in the "ASPIRe" regulatory blueprint. The core of the pillar is to use advanced technical means and cross-institutional collaboration to build a real-time, accurate and intelligent regulatory system to improve regulatory efficiency and market transparency.

The core goals of "Infrastructure" are as follows:

1. Improve regulatory technical capabilities

Through modern information technology and data analysis tools, real-time monitoring and early warning of market activities are achieved.

Establish a direct regulatory reporting system to ensure that regulators can obtain complete and accurate market data in a timely manner.

2. Build a cross-institutional collaboration mechanism

Strengthen information sharing and coordination between local regulators, law enforcement agencies and international regulators to form a regulatory network that works together to combat illegal activities.

Promote cross-border regulatory cooperation to address the globalization characteristics and cross-border risks of the virtual asset market.

Third, realize intelligent risk warning and data-driven decision-making

Deploy blockchain monitoring tools and big data analysis systems to timely capture potential risk signals such as abnormal transactions and abnormal capital flows.

Use advanced monitoring technology to improve the scientificity and foresight of regulatory decisions, and achieve "pre-warning, in-process disposal, and post-event accountability".

Fourth, establish a straight-through regulatory reporting system

Real-time data collection: Promote virtual asset service providers (VASPs) to adopt standardized and electronic data reporting systems to achieve automatic reporting and rapid integration of information.

Transparent information disclosure: Strengthen the collation and disclosure of market data, improve market transparency, and facilitate regulatory authorities and investors to understand market dynamics in real time.

V. Deploy advanced monitoring and early warning tools

Blockchain and big data analysis: Use blockchain technology to monitor transactions on the chain in real time, and identify abnormal trading patterns and potential illegal behaviors through big data analysis technology.

Intelligent early warning system: Establish an early warning system based on machine learning and artificial intelligence algorithms to automatically detect market anomalies and issue risk warnings and disposal suggestions in a timely manner.

VI. Strengthen cross-institutional and cross-border collaboration

Local collaboration: Realize data interconnection and interoperability with other financial regulatory agencies and law enforcement agencies in Hong Kong to form a comprehensive risk prevention and control network.

International cooperation: Actively participate in international regulatory organizations and transnational regulatory alliances, promote the formulation of globally unified or mutually recognized regulatory standards, and prevent regulatory arbitrage and cross-border risk contagion.

VII. Build a dynamic data analysis platform

Data integration platform: Build a dynamic data platform that integrates various market data, regulatory reports and risk indicators for real-time query and decision-making reference by regulatory authorities.

Trend and forecast analysis: Use historical data and real-time data to conduct trend analysis and risk forecasting to help regulatory authorities formulate response measures in advance.

Modernized information systems and intelligent early warning tools will significantly shorten the time from risk discovery to emergency response, reduce the impact of market fluctuations on investors, and real-time data sharing and public information disclosure will help build a transparent and fair market environment and enhance investor confidence. Cross-institutional and cross-border collaboration mechanisms will help form a unified global regulatory landscape and enhance Hong Kong's voice and influence in global virtual asset regulation.

However, the information systems and data formats of different market participants may differ, and how to unify standards and interfaces is a key issue. In the process of information sharing and data integration, it is necessary to balance regulatory needs with data privacy protection to ensure that sensitive information is not abused. Collaboration between different regulatory agencies and international organizations involves many issues at the legal, policy and operational levels, and requires the establishment of effective communication mechanisms and coordination platforms.

Although there are certain challenges in terms of technical standard unification, data security and cross-border collaboration, with the continuous advancement of regulatory technology and the deepening of international cooperation, the "infrastructure" pillar is expected to build a forward-looking and intelligent virtual asset regulatory system for Hong Kong, further consolidating its position as a global hub for digital economic transformation.

Relationships

The virtual asset market is highly dynamic and globalized, with not only rapid technological development, but also diversified market participants. At the same time, the importance of investor education, market information transparency and communication and coordination among all parties has become increasingly prominent. In traditional financial markets, regulators often adjust policies in a timely manner by maintaining close interaction with market players. In the field of virtual assets, due to information asymmetry and regulatory gaps, investors are easily misled and market risks increase. To this end, the Hong Kong Securities and Futures Commission (SFC) proposed the "Relationships" pillar in the "ASPIRe" regulatory blueprint. Its core is to bridge the information gap between regulators, markets and investors by building a multi-level, all-round communication and collaboration mechanism, and promote market participants to jointly build a healthy, transparent and sustainable virtual asset ecosystem.

The core goals of "Relationships" are as follows:

1. Strengthen investor education and information transparency

The goal is to enhance the public's understanding of the characteristics, risks and regulatory policies of virtual assets and help investors make more informed decisions.

Through systematic education programs and information disclosure, reduce investment risks caused by information asymmetry.

Second, promote interaction between regulators and market players

Build a sound communication platform to ensure that regulatory policies can reflect market feedback in a timely manner, and at the same time enable market participants to understand and comply with regulatory requirements.

Through regular seminars, workshops and advisory groups (such as the Virtual Asset Advisory Group VACP), strengthen exchanges between regulators and exchanges, custodians, and financial service providers.

Third, guide the responsible behavior of financial opinion leaders

For emerging social media communication channels, formulate corresponding regulatory and industry self-discipline standards to guide financial opinion leaders to convey true and objective information and prevent the spread of false propaganda and misleading information.

Fourth, promote cross-sector talent training and continuous learning

Establish a continuous training and talent training mechanism to enhance the professional quality of practitioners, investors and other relevant personnel in the virtual asset industry, and promote the continuous updating and sharing of regulatory and industry knowledge.

V. Systematized investor education plan

Popularize basic knowledge: formulate educational courses for retail and institutional investors, covering blockchain technology, virtual asset risks, market operations and regulatory rules.

Multi-channel communication: use online platforms, seminars, public lectures and media cooperation to ensure that educational information can reach a wider audience.

Risk warnings and investor guides: regularly issue risk warnings and investor guides to help investors identify market risks and prevent fraud and misleading information.

Sixth, establish and improve the communication platform and consultation mechanism

Virtual Asset Advisory Panel (VACP): Regularly organize industry seminars, invite trading platforms, custodians, technology suppliers and scholars to jointly discuss the current regulatory situation and future development direction.

Online interactive platform: Build an official interactive platform to collect market feedback and questions in a timely manner, and convey regulatory information and policy explanations to the market through announcements, Q&A and other means.

Inter-institutional dialogue mechanism: Strengthen regular dialogue between the SFC and other local financial regulatory agencies and law enforcement agencies to form a working pattern of information sharing and risk joint prevention.

Seventh, regulate the behavior of financial opinion leaders

Develop a responsibility framework: For financial opinion leaders who post information on social media and other digital platforms, clarify the authenticity and transparency requirements of their published content.

Advocate industry self-discipline: Encourage the establishment of self-discipline organizations in the industry, formulate codes of conduct, and promote financial opinion leaders to follow the principle of integrity and avoid speculation and misleading investors.

VIII. Promote talent training and industry cooperation

Cross-border training projects: Cooperate with universities, research institutions and industry associations to carry out special training and certification on virtual assets and blockchain technology to improve the overall industry level.

Knowledge sharing and case exchange: Establish a virtual asset supervision and practice case library, regularly share successful experiences and failure lessons, and help all parties in the market to continuously learn and improve.

The "Relationships" pillar plays a vital role in the ASPIRe regulatory blueprint. Through systematic investor education, a sound communication platform, standardized behavior of financial opinion leaders and cross-border talent training, the Hong Kong Securities and Futures Commission is committed to building a transparent, interactive and win-win virtual asset ecosystem. This move will not only enhance market transparency and investor confidence, but will also promote a closer cooperation mechanism between regulators and market players, thus laying a solid foundation for the healthy, stable and sustainable development of Hong Kong's virtual asset market. Although there are challenges such as information asymmetry, cross-institutional coordination and new media supervision in the implementation process, as long as all parties work together, Hong Kong is expected to set a good example of communication and cooperation in the global virtual asset market in the future and become an important fulcrum for the transformation of the global digital economy.

Conclusion

The "ASPIRe" regulatory blueprint launched by the Hong Kong Securities and Futures Commission not only protects investor rights and market security, but also promotes innovation and global interconnection in the context of the rapid evolution of the virtual asset market. Through the five pillars of "connection", "security", "products", "infrastructure" and "connection", the SFC not only provides clear rules and paths for market participants, but also actively responds to global market competition and cross-border regulatory challenges driven by technology and collaboration.

In the future, with the continuous improvement of regulatory mechanisms, continuous innovation of products and technologies, and increasingly close communication among all parties, Hong Kong is expected to become the world's most transparent and trusted virtual asset hub, providing solid support for the transformation of the global digital economy.