Hong Kong unveils ASPIRe roadmap for crypto assets

On February 19, 2025, the Hong Kong Securities and Futures Commission presented its ASPIRe roadmap. The document grouped twelve initiatives under five axes—access, safeguards, products, infrastructure and relationships—to develop the local virtual asset market without abandoning investor protection.

What the ASPIRe roadmap proposes

ASPIRe was not a law or an automatic authorization of new services. It was a regulatory program that anticipated consultations, license adjustments and supervisory measures. Its value consisted of indicating the direction of travel: more activities within the regulated perimeter, more variety of products and comparable controls between operators performing similar functions.

In the access axis, the SFC proposed reviewing who could participate and how to connect local and international liquidity. Hong Kong already allowed authorized virtual asset trading platforms, but the available catalog and cross-border operations remained conditional. Any extension would depend on subsequent rules and the specific license of each entity.

Safeguards took center stage. Key custody, asset segregation, conflicts of interest and operational continuity are risks separate from price movement. ASPIRe aimed to reinforce standards for custodians and reduce gaps between the platform that executes an order and the entity that holds the client’s assets.

The reference to products also did not mean that every token could be offered to the public. The regulator was considering expanding alternatives under conditions, including lending, debt or performance functions. Before marketing them, an entity had to analyze legal nature, disclosure, suitability, liquidity and counterparty exposure.

OTC, custody and a broader scope

A priority was to study regimes for over-the-counter trading and custody. These activities can be left out of focus when the license is designed around a centralized exchange. However, an OTC desk can channel large amounts and a custodian can concentrate the operational risk of many intermediaries, even if none manages an order book.

Incorporating them into the perimeter allows us to demand identifiable responsible parties, financial resources, AML policies and auditable records. It also forces us to define boundaries: advising is not equivalent to executing, custody is not equivalent to taking deposits, and facilitating a transfer does not always make the provider a counterparty. The appropriate license depends on the actual function, not the marketing label.

The infrastructure axis included technological supervision, data and mechanisms to detect market abuse. In assets traded continuously and in multiple jurisdictions, surveillance needs to link accounts, addresses and orders. The traceability of a blockchain helps, but it does not replace information about the owner nor does it alone prove the economic purpose of a transfer.

The last piece, relations, reflected that the market could not be regulated by isolated circulars. The SFC proposed dialogue with industry, investors and foreign authorities. Such cooperation is especially relevant when the platform is licensed in Hong Kong, the custodian operates from another territory and the issuer of the asset lacks a local presence.

What should a company do?

For one supplier, the prudent response was not to wait for the final standard. It was advisable to prepare a map of activities, identify which group entity provided each service and document assets, jurisdictions and admitted clients. This inventory allows you to measure which queries may require an additional license or contractual changes.

It was also necessary to separate commercial promise and effective authorization. Announcing that Hong Kong wanted to become a virtual asset hub did not allow one to claim that a product was approved. The communication to the client had to specify restrictions, risks of loss, custody regime and absence of public guarantee.

Outlook from 2026

As of August 2026, ASPIRe is better understood as a sequence rather than a single act. The SFC advanced platform products and services and published conclusions or consultations on advice, management, trading and custody of virtual assets. Each development maintains its own schedule and requirements.

Legal education is methodological: a roadmap provides predictability, but does not replace the rule applicable on the day of the operation. Companies and investors should check whether an initiative has already become a current regime, is still under consultation or requires legislation. Confusing these stages can transform a reasonable expectation into an unauthorized offer.