Thirty-six companies formally applied to issue stablecoins in Hong Kong during the initial application window. As of late September 2026, two hold licences. The HKMA granted the first pair on 10 April 2026, to Anchorpoint Financial and HSBC, and the register hasn't grown since. When legislators asked about the pipeline, the answer was blunt: however many more get granted, the overall number "will remain very limited."
It's tempting to read that as a story about capital or connections, since both licensees are bank-grade names. But sit with the HKMA's own supervision guideline for an hour and a different filter emerges. The licence is, before anything else, a commitment to run a reporting operation most crypto ventures have never built. The technology mints the coin. The back office keeps the licence.
What the licence asks your ledger to do
The Stablecoins Ordinance took effect on 1 August 2025 and covers fiat-referenced stablecoins, coins that hold their value against official currencies. Anyone issuing one in Hong Kong, or issuing an HKD-referenced one anywhere, needs the licence. The supervision guideline then spells out what a licensee's finance function owes, and the list reads like a fund administration manual.
Reserves come first. The pool backing each stablecoin type must hold market value at least equal to the par value of every coin in circulation, at all times, with over-collateralisation expected on top. Those reserves must be segregated per stablecoin type, protected from the issuer's other creditors, placed under effective trust arrangements, and kept with a qualified custodian. Quality rules bind the portfolio to cash, bank deposits of three months or less, and short government paper. Holders can redeem at par, and valid requests get processed within one business day.
Then the reporting cadence. Daily statements of par value and reserve composition. A weekly report to the HKMA, with the same information updated on the issuer's own website. Independent attestations from an auditor acceptable to the HKMA, submitted within a month and published. And the annual financial audit must cover the reserve assets themselves. There's a HK$25 million minimum paid-up capital floor too, though banks as authorized institutions sit outside it, which tells you who the regime was sized for.
The random day is the tell
Buried in the attestation requirement is the detail that gives the game away. The auditor doesn't just test the reserve position at period end. The guideline requires testing "at least one randomly selected business day" in each period. Quarter-end window dressing, the oldest trick in reserve reporting, is designed out. If any given Tuesday has to survive an attestation, then every day's books have to be right.
That's what makes this an accounting project rather than a compliance checkbox. A daily par-value statement means someone reconciles coins outstanding on the chain against a marked reserve portfolio in the ledger, every business day, per stablecoin type, inside a trust structure. Weekly public disclosure means those numbers leave the building. The tolerance for "we'll true it up at month end" is zero.
The entity comes with the licence
The regime also manufactures a company. An applicant must be incorporated in Hong Kong, and an overseas firm that wants in has to incorporate a local subsidiary to hold the licence. Anchorpoint itself is exactly that, a new Hong Kong company built by Standard Chartered, HKT, and Animoca Brands for this purpose. So from day one there's at least one fresh entity carrying a statutory audit and, in a group, a consolidation obligation, layered under the HKMA's daily and weekly duties.
Getting it wrong is expensive in the other direction. Law firm summaries of the Ordinance put unlicensed issuance at a fine of HK$5 million and seven years' imprisonment on indictment, plus HK$100,000 for each day the offence continues. The regime is narrow at the front door and unforgiving outside it.
What to build before you apply
If a licence is on your roadmap, the accounting infrastructure belongs in the application phase, not the aftermath. The register holding two names and the HKMA promising to keep it "very limited" means operational readiness is part of the case you're making. Concretely, that means a reserve ledger segregated per stablecoin type under trust, a daily par-value process fed by live balances instead of exports, the redemption obligation carried at par as the liability it behaves like, and attestation evidence that accumulates continuously instead of being assembled the week the auditor asks.
A crypto sub-ledger watches the chain and prices the portfolio. What sits behind it has to be a general ledger that closes clean every day across every entity in the structure. Our digital assets industry page covers how we configure NetSuite for Hong Kong stablecoin issuers and licensed platforms, and our implementation page walks through what a project involves. Thirty-six applied. Two got in. The ledger is a real part of the difference.
