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On 7 April 2025, the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) issued guidance for authorized institutions (and subsidiaries of locally incorporated authorized institutions) and SFC-licensed virtual asset trading platforms respectively, who are interested in providing Staking Services. The guidance outlines the regulatory framework and expected standards for providing Staking Services.
On the same day, the SFC revised its “Circular on SFC-authorized funds with exposure to virtual assets” issued on 22 December 2023 to facilitate SFC-authorized virtual asset funds (SFC-authorized VA Funds) which wish to engage in staking and other virtual asset-related activities.

On 19 March 2025, Hong Kong’s Legislative Council enacted the Protection of Critical Infrastructures (Computer Systems) Bill, which was gazetted as the Protection of Critical Infrastructures (Computer Systems) Ordinance (Cap. 653) on 28 March 2025. The Ordinance, which is set to take effect on 1 January 2026, aims to enhance cybersecurity standards in relation to the providers of essential services in eight sectors deemed crucial to the normal functioning of the society, namely energy, information technology, banking and financial services, air transport, land transport, maritime transport, healthcare services, and telecommunications and broadcasting services, as well as critical societal or economic activities (such as those managing major sports and performance venues, as well as research and development parks) in Hong Kong.

On 19 February 2025, the Securities and Futures Commission (SFC) issued a regulatory roadmap for Hong Kong’s virtual asset market. Entitled “‘A-S-P-I-Re’ Roadmap for a Resilient Virtual Asset Ecosystem”, it sets out a five-pillar framework (Access, Safeguards, Products, Infrastructure, and Relationships) that is intended to serve as a strategic action plan for addressing emerging new priorities in the virtual asset space (e.g., managing liquidity fragmentation and ensuring investor protection across decentralized and centralized platforms) and, in the SFC’s words, “future-proof[ing] Hong Kong’s VA ecosystem”.

On 20 December 2024, the Hong Kong government gazetted the Companies (Amendment) (No.2) Bill 2024 (“Bill”) which introduces Hong Kong’s long awaited inward re-domiciliation regime. The Bill was introduced to the Legislative Council on 8 January 2025 and once enacted, will enable non-Hong Kong incorporated companies to relocate their domicile to Hong Kong, while maintaining their legal identity and business continuity.

The Hong Kong Government has published on 6 December 2024 a draft of the Protection of Critical Infrastructures (Computer Systems) Bill (“Bill”), marking a significant step towards enhancing cybersecurity standards in relation to essential services and critical societal or economic activities in Hong Kong. This Bill aims to protect the security of the critical computer systems (CCSs) of critical infrastructures (CIs), to regulate operators of CIs (i.e., critical infrastructure operators (CIOs)) and to provide for the investigation into, and response to, computer-system security threats and incidents.

On 6 December 2024, the Hong Kong government gazetted the Stablecoins Bill, which aims to establish a regulatory regime for issuers of fiat-referenced stablecoins in Hong Kong. This follows public consultations by the Financial Services and the Treasury Bureau and the Hong Kong Monetary Authority. The Bill aims to introduce a licensing and regulatory framework for FRS issuers and those involved in offering FRS.

While this article was published, the Security Bureau of the Hong Kong Government announced that the Protection of Critical Infrastructure (Computer System) Bill will be gazetted on Friday, 6 December 2024, and will be introduced into the Legislative Council for First Reading and Second Reading on 11 December 2024. We will provide an update on further developments.

On 26 November 2024, The Stock Exchange of Hong Kong Limited (SEHK) issued a new guidance letter (GL120-24) to inform the market of its expectations on investigations conducted by suspended issuers and the roles of the directors and the independent investigation committees (IIC). According to the latest monthly prolonged suspension status report published by the SEHK, as at 29 November 2024, there were 57 Main Board and eight GEM issuers which have been suspended for three months or more.

On 25 June 2024, the Government proposed to enact a new piece of cybersecurity legislation, tentatively entitled the Protection of Critical Infrastructure (Computer System) Bill, to enhance the protection of computer systems of critical infrastructures (CIs). On 2 July 2024, the proposed legislative framework was tabled to the Legislative Council Panel on Security for consultation. The proposed legislation would require CI operators to fulfill certain statutory obligations and take appropriate measures to strengthen the security of their critical computer systems and minimize the chance of essential services being disrupted or compromised due to cyberattacks.

On 25 June 2024, the Government proposed to enact a new piece of cybersecurity legislation, tentatively entitled the Protection of Critical Infrastructure (Computer System) Bill, to enhance the protection of computer systems of critical infrastructures (CIs). On 2 July 2024, the proposed legislative framework was tabled to the Legislative Council Panel on Security for consultation. The proposed legislation would require CI operators to fulfill certain statutory obligations and take appropriate measures to strengthen the security of their critical computer systems and minimize the chance of essential services being disrupted or compromised due to cyberattacks. It is proposed that a new Commissioner’s Office is to be established under the Government’s Security Bureau for the implementation of the proposed legislation.