Singapore vs Hong Kong Crypto Regulation (2026 Comparison)

Side by side

	Singapore	Hong Kong
Main regulators	MAS	SFC (trading, custody); HKMA (stablecoins, banks)
Exchange licence	Payment Services Act (Major Payment Institution with DPT services)	SFC virtual asset trading platform (VATP) licence, since June 2023
Offshore-only firms	DTSP licence needed since 30 Jun 2025; "generally" not granted	Licence needed to serve Hong Kong investors
Retail trading	Yes, with risk-awareness checks and conduct rules	Yes, on licensed platforms with suitability rules
Retail staking	No (2023 measures)	Yes, on licensed platforms with SFC approval per protocol (since April 2025)
Stablecoin law	Framework since 2023; PS Act amendments consulted Sep-Oct 2026	Stablecoins Ordinance in force 1 Aug 2025
First licensed issuers	Statute not yet in force	HSBC and Anchorpoint Financial, 10 Apr 2026
Flagship program	Project Guardian (tokenisation)	ASPIRe roadmap (SFC), Project Ensemble (HKMA)

Exchange licensing

In Singapore, a crypto exchange needs a Major Payment Institution licence with digital payment token services from MAS. In Hong Kong, it needs a virtual asset trading platform licence from the Securities and Futures Commission, under a regime that opened to retail in June 2023.

Both lists are public: the MAS Financial Institutions Directory and the SFC's list of licensed virtual asset trading platforms. Counts quoted in the press vary, so check the registers directly. The bigger difference is reach. Since 30 June 2025 Singapore requires a DTSP licence for firms in Singapore that serve only overseas customers, and MAS said it would generally not grant one (see Singapore crypto regulation in 2026). Hong Kong's regime is about who serves Hong Kong investors.

Retail access and staking

The sharpest difference is staking. Singapore bars licensed providers from facilitating staking or lending of retail customers' tokens. Hong Kong's SFC allowed licensed platforms to offer staking from April 2025, with prior written approval for each blockchain protocol offered to retail.

Hong Kong has gone further on other products too. Its ASPIRe roadmap, published in February 2025, sets five pillars (Access, Safeguards, Products, Infrastructure, Relationships) and 12 initiatives, including shared order books with overseas platforms and, for professional investors, derivatives and new-token listings. Singapore's retail stance comes from the 2022 collapses of Celsius and Voyager, and MAS has said it will keep its measures under review rather than loosen them on a timetable.

Stablecoins: Hong Kong first, Singapore next

Hong Kong's Stablecoins Ordinance came into force on 1 August 2025. Issuers of fiat-referenced stablecoins need an HKMA licence, at least HK$25 million of paid-up capital and reserves at least equal to the coins in circulation. The first two licences went to HSBC and Anchorpoint Financial on 10 April 2026.

Anchorpoint is a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands. Both licensees plan Hong Kong dollar coins. Reports put the number of formal applications at 36 by the end of September 2025, so two licences in the first round signalled a selective approach. Singapore's equivalent, the MAS stablecoin framework, has existed as policy since 2023; draft legislation was consulted on in September and October 2026, adding a "MAS-recognised" label for some foreign coins. Details in Singapore's stablecoin framework.

	Singapore (proposed statute)	Hong Kong (in force)
Currencies	SGD or a G10 currency	Any fiat reference, licence-dependent
Reserves	At least 100% of par, segregated	At least equal to par value in circulation
Foreign coins	"MAS-recognised" case by case	Licence needed to issue in or target Hong Kong
Interest to holders	Open question in consultation	Not permitted

Tokenisation programs

Both hubs back institutional tokenisation. Singapore's Project Guardian has run since 2022 with 28 financial institutions and nine regulators, and is moving toward settlement of tokenised assets in wholesale central bank money. Hong Kong's HKMA runs Project Ensemble on tokenised deposits and settlement. For tokenised funds and treasuries, both are building toward the same thing: regulated assets and regulated money on shared ledgers. See tokenized money market funds.

What the two regimes share

Under the differences, both regimes rest on the same foundations: FATF standards on anti-money laundering, segregated custody of client assets, fit-and-proper tests for management, and supervisors that expect firms to know their customers and their counterparties.

• Travel Rule: both apply FATF's rule to token transfers between providers.
• Custody: Singapore requires a statutory trust over customer assets; Hong Kong requires platforms to hold most client assets in cold storage through an associated entity, and has consulted on a separate custodian licence.
• Token admission: both expect platforms to vet what they list, with stricter standards for products offered to retail.
• Marketing: both restrict how crypto is promoted to the public.

What to watch next

• Singapore: the stablecoin bill and its subsidiary rules; any first "MAS-recognised" coins; tokenised MAS Bills settled in wholesale CBDC; announcements at the Singapore FinTech Festival, 18-20 November 2026.
• Hong Kong: further stablecoin licences beyond the first two; the custodian licensing bill; how far ASPIRe opens products to retail.

Which hub fits which business

• Retail exchange with staking: Hong Kong's rules allow it; Singapore's do not.
• Stablecoin issuer: Hong Kong has a working licence today; Singapore's statute is close and offers a recognition route for foreign coins.
• Institutional tokenisation: both, with Singapore's Guardian frameworks the most widely referenced.
• Global business run from Asia: Singapore no longer suits offshore-only models after the DTSP regime.

Either way, the compliance basics are the same: verified customers, sanctions screening, monitoring and the Travel Rule, usually built on identity-verification platforms such as iDenfy plus analytics and Travel Rule messaging. More in the crypto Travel Rule.