# Hong Kong SAR

> Hong Kong SAR (SFC · HKMA · Privacy Commissioner for Personal Data): Retail exclusion by liquidity gate, not by anonymity rule. Region: Asia-Pacific. Privacy with disclosure: Confidentiality is workable so long as the regulated firm can identify parties and disclose on demand.

Part of the Soda Labs Privacy Hub regulation map, which reads the instruments
themselves rather than summarising the summaries: https://www.sodalabs.xyz/privacy-hub/regulation

## Key facts

- Entry type: Jurisdiction
- Region: Asia-Pacific
- Subject: Retail exclusion by liquidity gate, not by anonymity rule
- Authority: SFC · HKMA · Privacy Commissioner for Personal Data
- Stance on on-chain confidentiality: Privacy with disclosure. Confidentiality is workable so long as the regulated firm can identify parties and disclose on demand.
- Tags: large-cap gate, no explicit ban, Project Ensemble, silent on privacy
- Canonical page: https://www.sodalabs.xyz/privacy-hub/regulation/jur-hong-kong

## What it actually says

A good illustration of exclusion happening without a rule that mentions the thing being excluded. Hong Kong's platform guidelines say nothing about privacy coins, anonymity or mixers anywhere in the text. What they require is that any token offered to retail clients be an eligible large-cap virtual asset, present in at least two acceptable indices from two different providers. Monero and Zcash fail that liquidity test, so they are absent from retail without any policy against confidentiality ever being stated. The wider posture is expansionist on tokenisation and stablecoins, with the first licences granted in April 2026. The June 2025 policy statement setting the digital asset strategy is similarly silent: privacy is not argued against, it is simply never raised.

## The instruments that matter

- **VATP Guidelines, June 2023, paragraph 7.8**: retail tokens must be eligible large-cap virtual assets, included in at least two acceptable indices from two different providers, one of them IOSCO-compliant
- **No anonymity language at all**: the full text of the guidelines contains no mention of privacy coins, anonymity or mixers; paragraph 7.8 Note 3 allows case-by-case appeal to the SFC
- **Stablecoins Ordinance (Cap. 656), from 1 August 2025**: first two licences granted 10 April 2026, to Anchorpoint Financial and HSBC
- **Policy Statement 2.0, 26 June 2025**: sets the LEAP framework and endorses Project Ensemble; contains no reference to privacy, confidentiality or anonymity anywhere

## Sources

- [SFC virtual asset trading platform operators](https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators)
- [HKMA stablecoin licences, April 2026](https://www.hkma.gov.hk/eng/news-and-media/press-releases/2026/04/20260410-4/)

## Related entries

- [Australia](https://www.sodalabs.xyz/privacy-hub/regulation/jur-australia): Travel rule without a threshold, no coin ban
- [Singapore](https://www.sodalabs.xyz/privacy-hub/regulation/jur-singapore): Regulates anonymity by risk assessment, not prohibition
- [India](https://www.sodalabs.xyz/privacy-hub/regulation/jur-india): No crypto statute, regulated through AML and tax
- [Japan](https://www.sodalabs.xyz/privacy-hub/regulation/jur-japan): Untraceability barred by self-regulation, now moving into ordinance
- [South Korea](https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-korea): Identity-maximalist, and exporting the model
- [Taiwan](https://www.sodalabs.xyz/privacy-hub/regulation/jur-taiwan): The travel rule that has never come into force