Same Activity Same Risk Same Regulation (Hong Kong)

Hong Kong’s regulatory principle ensuring uniform oversight for financial activities with equivalent risks, applied to stablecoin issuance under the Stablecoins Ordinance effective August 2025.

What is Same Activity Same Risk Same Regulation (Hong Kong)?

The “Same Activity, Same Risk, Same Regulation” principle is a core guideline adopted by Hong Kong’s financial regulators, including the Hong Kong Monetary Authority (HKMA) and the Financial Services and the Treasury Bureau (FSTB), to apply consistent rules to virtual asset activities mirroring traditional finance. Introduced in policy statements as early as 2022 and reinforced in 2025, it ensures that stablecoin issuers face requirements similar to those for banks or e-money institutions, focusing on reserve management, AML compliance, and consumer protection. Under this principle, the Stablecoins Ordinance, effective August 1, 2025, mandates licensing for issuers of fiat-referenced stablecoins (FRS), with reserves held in segregated accounts and regular audits.

In May 2025, the HKMA issued a consultation paper on AML/CFT requirements for regulated stablecoin activities, emphasizing the principle to mitigate risks like money laundering while fostering innovation. By September 2025, this approach had led to the approval of initial stablecoin licenses, promoting fair competition and reducing regulatory arbitrage in Hong Kong’s virtual asset ecosystem. The principle aligns with global standards, such as those from the Financial Action Task Force (FATF), and supports Hong Kong’s goal of becoming a hub for stablecoin issuance, with over 10 applications processed by mid-2025.