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The Payment Systems and Stored Value Facilities Ordinance (PSSVFO, Cap. 584) remains the legal basis for HKMA licensing and supervision of SVFs and RPS designation/oversight; Q1-2026 statistics show 88.78 million SVF accounts in use and HK$264.6 billion transaction value.
The structural distinction to carry forward is that Hong Kong has no EU/UK-style separate EMI or PI regime. The SVF licence is the functional non-bank route to issue multi-purpose stored value, and it is the structural gate for e-wallet operators. The bank/non-bank split is explicit in the deemed-licensed treatment of banks alongside the standalone SVF requirement for non-bank issuers. Closed-loop and bank-partnership arrangements sit outside the licensing perimeter as exemptions.
Outlook
This is an established perimeter rather than a moving one; the SVF licence remains the defining gate for non-bank multi-purpose stored value, and no separate EMI/PI track is in prospect.
Licensing, Authorisation & Market Access
Hong Kong's core payments licensing regime, the Payment Systems and Stored Value Facilities Ordinance (Cap. 584) framework, continues to operate at significant scale. The Hong Kong Monetary Authority's first-quarter 2026 statistics recorded 88.78 million stored-value-facility accounts in use, up 2.7 percent quarter-on-quarter and 9.7 percent year-on-year, with approximately 2.2 billion transactions processed for a total transaction value of HK$264.6 billion. This scale sits on a standing statutory foundation: a stored-value-facility licence is granted only where all PSSVFO minimum criteria are satisfied, and continue to be satisfied on an ongoing basis, an ongoing-fitness test rather than a one-time approval gate. The HKMA's parallel release of first-quarter 2026 payment-card statistics, covering the Faster Payment System, e-CNY wallet activity, e-wallets, credit cards, cross-boundary remittance and Payment Connect, continues the regulator's practice of quarterly disclosure that gives the market a consistent scale baseline.
Alongside this established SVF regime, Hong Kong is actively extending its licensing perimeter into virtual-asset services. The Financial Services and the Treasury Bureau and the Securities and Futures Commission published consultation conclusions on virtual-asset dealing and custodian licensing proposals on 24 December 2025, following an August 2025 consultation that drew more than 190 responses. Consultation conclusions on a related but distinct proposal — licensing for virtual-asset advisory and management services, following a consultation that closed 23 January 2026 — followed on 26 May 2026. Both processes are feeding into a single AMLO Amendment Bill intended for introduction to the Legislative Council in 2026, which would create a new licensing perimeter for virtual-asset dealing, custody, advisory and management services. Notably, no transitional deeming arrangement is currently planned, meaning existing unlicensed participants offering these services will need to obtain new licences once the bill is enacted, without a grandfathering safe harbour — a meaningful compliance-timeline risk for any non-bank virtual-asset service provider currently operating in this space.
The bank-versus-non-bank distinction is structurally significant across this regime: the SVF licensing criteria under PSSVFO apply to non-bank stored-value-facility issuers specifically, while banks conducting equivalent payment-account functions operate under their banking licence rather than a standalone SVF licence, and the Q1-2026 statistics themselves span both bank and non-bank issuers without disaggregating between the two categories in the figures cited here. The proposed virtual-asset dealing, custodian, advisory and management licensing regime under the AMLO Amendment Bill is, by contrast, framed as a non-bank licensing perimeter, targeting virtual-asset-sector participants that do not otherwise hold a banking licence.
Outlook
The AMLO Amendment Bill's actual introduction to the Legislative Council is the item to track most closely, given both the compliance-deadline implications of the no-deeming-arrangement design and the fact that current sourcing rests on legal-commentary rather than a primary LegCo filing. The SVF regime's scale metrics should be expected to continue their steady growth trajectory absent any signalled licensing change; the more consequential near-term shift is the virtual-asset licensing build-out rather than the established SVF framework.
Sources and findings (4)
- T1https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/
- T1HKMA — Stored Value Facilities under PSSVFO Cap. 584 (hkma.gov.hk)
- T1https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stored-value-facilities-and-retail-payment-systems/regulatory-regime-for-stored-value-facilities/
- T1HKMA — SVF licensing & retail payment systems; PSSVFO Cap. 584 (hkma.gov.hk)