Two Years of Sandbox Experiment

● On December 24, 2025, the Hong Kong Financial Services and the Treasury Bureau and the Securities and Futures Commission jointly released a consultation summary on the licensing system for virtual asset trading and custody services, marking a new phase in the exploration of crypto regulation in this Eastern financial hub.
● Since the implementation of the virtual asset trading platform licensing system in June 2023, Hong Kong has completed the first round of regulatory sandbox experiments. The 101 trading service opinion letters and 93 custody service opinion letters received have exposed profound contradictions between the traditional securities regulatory framework and the native characteristics of blockchain.

The Offensive and Defensive Battle of Custody Security

● The consultation document shows that private key management has become the most concerning risk control node. Some institutions proposed adopting a cold and hot wallet separation scheme similar to that of Switzerland's FINMA, but this was strongly opposed by crypto-native service providers.
● The regulatory authorities insist on the principle of "same risk, same regulation," requiring custody service providers to meet the same capital adequacy and auditing standards as traditional financial institutions.

Adaptability of the Securities Framework

● The new system clearly states that it will reference the existing securities regulatory system, raising doubts in the market about whether "securitization regulation" can adapt to the characteristics of crypto assets. In particular, the regulatory gaps regarding DeFi protocols, cross-chain bridges, and other on-chain native structures may become focal points of future controversy.
● Interestingly, during the consultation process, traditional institutions like Goldman Sachs supported comprehensive regulation, while Web3 giants like Animoca called for the preservation of innovation space.

New Financial Order Testing Ground

● The deeper significance of this regulatory experiment in Hong Kong lies in exploring a coexistence model between traditional financial jurisdiction and decentralized networks. Its success or failure will directly impact the policy directions of competitors like Singapore and Dubai.
● Currently, specific implementation details have not been disclosed, but the market generally expects the first batch of compliant exchange lists to be announced in Q1 2026.

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