Hong Kong's stablecoin licensing delayed: Don't wait anxiously for VA dealing and VA custody

Hong Kong’s stablecoin licensing has been delayed for so long without any official rollout, and the market’s first reaction is usually two words: “missed deadlines.”

The image above is from the Hong Kong Monetary Authority’s website.

But in my view, what is truly worth discussing here is not just “why it was delayed,” but what this again highlights as a more realistic issue: Hong Kong’s approach to crypto-related licenses still follows the typical “cautious and incremental” playbook.

For stablecoin licensing—an item that has already been repeatedly laid out by officials and whose legislative timeline is relatively clear—if it still hasn’t landed smoothly as the market expected, then there’s even less reason for many payment institutions that are waiting for VA dealing (virtual asset dealing services) and VA custody (virtual asset custody services) licenses to cling to the fantasy that they’ll arrive “very soon.”

For people preparing to build crypto payments, stablecoin issuance and settlement, and on-chain clearing and settlement businesses, the most dangerous thing right now is not that the license is expensive, nor that compliance is hard—but that you bet the business launch timeline in the wrong place. If the license hasn’t been approved, you don’t dare move; meanwhile, the market window is moving forward. In the end, it’s very easy to end up with a situation where you’ve prepared everything—except you miss the timing.

Why is stablecoin licensing so sensitive to the market?

The reason this stablecoin licensing matter in Hong Kong has such a strong impact on the market isn’t only because it’s important in itself—it’s because many people treat it like a signal light.

The logic is simple. In Hong Kong, stablecoins are not a fringe topic; they’re one of the most core pieces in the Web3 regulatory setup over the past couple of years. It relates to payments, to the movement of funds, and to how future on-chain financial infrastructure will be built. If this license can be issued smoothly and clearly, the market will naturally draw a conclusion: Hong Kong’s regulatory implementation for crypto finance has truly started moving into the execution phase.

But the problem now is that this “light” hasn’t turned on the way everyone expected. The HKMA (Hong Kong Monetary Authority) is more likely to emphasize being prudent, steady, and requiring sufficient preparation—ensuring the quality of implementing the framework. This explanation in itself is entirely understandable. Because once stablecoins are formally brought under license-based regulation, regulators never look only at whether you can “issue” them. They look at a whole suite of issues: reserve assets, redemption mechanisms, segregation of funds, anti-money laundering (AML, anti-money laundering obligations), and systemic risk transmission. In other words, slow licensing doesn’t necessarily mean the system wasn’t prepared; it could also mean regulators are unwilling to leave any ambiguity at key junctures.

But the market won’t look at explanations only—it will also look at timing. Once the schedule gets pushed back, outsiders will inevitably start guessing: whether the applicants aren’t ready, whether the roster hasn’t been finalized, whether regulators’ internal yardsticks are still being calibrated, whether they need to wait for policy coordination at a higher level. Which of these guesses is actually true may not be important. What matters is that the market will recalibrate its understanding: for crypto-related licenses, Hong Kong still won’t be fast.

What you should understand from this “missed deadline” is not stablecoins themselves, but Hong Kong’s regulatory style

If you only interpret this延期 (delay) as a minor hiccup in the stablecoin licensing process, you’re looking too shallowly. What’s really worth understanding is Hong Kong’s consistent style in crypto regulation: it doesn’t do nothing—but it does things very slowly, very steadily, and with strong attention to sequence.

Many people have an instinctive filter about Hong Kong: they feel the financial market is mature, the system is transparent, and it’s highly internationalized—so once the direction is set, the downstream licenses and systems will roll out quickly. Reality isn’t like that. When it comes to financial infrastructure, payment systems, public funds, and cross-border fund flows, Hong Kong has never been a “race-to-launch” regulator. It’s a “confirmation-based” regulator. In other words: it would rather formally introduce the licensing framework when the market has already seen the direction, the risk boundaries are already largely clear, and the policy consequences can be controlled.

Stablecoin is a textbook example. Its direction was recognized by Hong Kong long ago; the framework is indeed being advanced; its policy posture has also been positive throughout. But when it comes to actually implementing the license, the pace will still slow down. Why? Because once licensing is issued, it’s not just granting a piece of paper to a handful of companies—it’s the regulator formally confirming that a new set of financial arrangements can move into operational status. That means any later licenses related to virtual-asset payments, trading, custody, and clearing and settlement will also, in all likelihood, be advanced along a similar path. It’s not about whether the market is eager or the industry is hopeful; it’s about whether regulators themselves believe it’s time to issue approvals.

Don’t expect VA dealing and VA custody to come out quickly

This is also the point I most want to remind the market about. Right now, many payment institutions, overseas-expansion projects, and stablecoin payment teams are actually watching two directions:

• VA dealing: virtual asset dealing services

• VA custody: virtual asset custody services

The rationale isn’t hard to understand. For many crypto payment businesses, the fit of these two license types is indeed very high. Especially teams that want to handle stablecoin receiving and payments, merchant settlement, on-chain fund pooling, and the linkage between wallets and clearing—naturally they feel: once Hong Kong releases these two licenses, their business will have a solid landing spot.

The issue is here: “fit” doesn’t equal “will come soon.” If even stablecoin licensing—already on the table for a long time and with a relatively mature system build-out—keeps getting postponed, then how could these other licenses that are more downstream and supporting, like VA dealing and VA custody, be faster than stablecoins? Judging by regulatory sequencing, these licenses likely won’t run ahead of stablecoin licensing. The reason is simple: stablecoins are a problem of underlying payments and units of value—at least to some extent, closer to “infrastructure.” Meanwhile, VA dealing and VA custody are more centered on licenses for virtual-asset services. They are important, but regulators typically roll them out after a more complete overarching main framework is in place.

So if there are still teams whose business plan reads like this—“Wait first; once Hong Kong’s VA dealing/VA custody comes out, we’ll start immediately”—then that scheduling risk is high. It’s not because these two licenses won’t come. It’s because you may not be able to wait long enough.

For people doing crypto payments, the biggest fear isn’t not having licenses—it’s waiting in the wrong place

Many people doing compliance planning have the habit of asking first: “What license would be ideal?” That question is correct, but it’s incomplete. What you should ask more is: “Which license is most suitable for me to run the business first at my current stage?” These are two completely different questions.

If you’re doing crypto payments, stablecoin receiving and payments, cross-border settlement, and on-chain clearing-related businesses, then in the long run, Hong Kong is definitely worth building in. Its brand effect, system credibility, and ability to radiate into the Asian market are strong. The problem is: being worth building long-term doesn’t automatically mean it’s suitable to fully bet your short-term business launch here.

Businesses have window periods. Especially in payments—after your license comes through, the market won’t stand still and wait for you. Customers won’t wait, partners won’t wait, and competitors definitely won’t wait. While you’re still anxiously waiting for some future license, others may already be running through merchant onboarding, channels, wallets, OTC (over-the-counter trading), and clearing and settlement links using licenses from other jurisdictions. By the time you finally get a license that is “theoretically more perfect,” the market landscape may already have been taken over by someone else. So commercially, the most dangerous compliance strategy isn’t “choosing the wrong license”—it’s standing still for a license you don’t even know when it will come, for the long term. This will directly delay business progress. In the end, it won’t be “more compliant and steadier”; instead, it’s the market that’s gone first.

If you truly want to do crypto payments, it’s better to see whether other jurisdictions can help your business start running first

This is also my more practical recommendation. If your goal right now is to launch crypto payment business as quickly as possible, rather than just producing a Hong Kong license story, then instead of waiting endlessly for VA dealing and VA custody, you should seriously look at several more realistic paths: U.S. MSB, U.S. MTL, Canada MSB, Australia DCE, and so on.

Each of these jurisdictions has its own issues and its own costs—there is no such thing as a “universal license.” But they share a common advantage: at least they can let you move first under clear rules. For many payment businesses, the most important thing isn’t to assemble the most beautiful global regulatory architecture from the start—it’s to find a starting point that allows legal launch, sustainable iteration, and seamless integration with customers and partners. As long as the business starts running first, then whether you later “patch Hong Kong,” “patch Europe,” “patch the Middle East,” or build a multi-jurisdiction structure, you’re upgrading in a way that rides the momentum—seamlessly. Conversely, if your very first step can’t be taken for a long time, even a beautiful license design later on might end up only as a PPT. So the realistic strategy usually isn’t “wait only for Hong Kong,” but: Hong Kong continues to be monitored, while business launch shouldn’t rely on Hong Kong alone.

What’s truly worth fighting for isn’t the license that hasn’t come out yet—it’s your market position

In the final analysis, the anxiety many teams have right now isn’t about the license itself—it’s fear of missing the next window for crypto payments. That anxiety is justified. But the solution may not be to keep waiting. Stablecoin licensing delays have already given the market a very clear warning: Hong Kong will keep doing it, but Hong Kong won’t speed up just because the market is anxious. Given that, a truly mature strategy shouldn’t be passive waiting—it should be proactive positioning.

Whoever lays out the license path, the funds path, the partnership path, and the customer path first has a better chance to secure market share first. By then, once Hong Kong’s subsequent licenses are actually issued, you’re filling in licenses, upgrading structures, and scaling up—not starting from zero and scrambling to catch up. So if you’re looking at crypto payments, stablecoin receiving and payment, and Web3 cross-border settlement, my recommendation is clear: don’t put all your hopes on Hong Kong’s next license.

Since stablecoins can get “missed deadlines,” there’s even less reason to wait painfully for VA dealing and VA custody. What you should do isn’t to keep guessing when they’ll come out—it’s to find jurisdictions and structures that can get your business running first, as soon as possible.