Telephone Numbers
Telephone Numbers
For detailed information +90 542 381 3868'Call.
Asia's two financial powerhouses, Hong Kong and Singapore, are among the most sought-after hubs in the digital asset world. With clear regulatory frameworks, robust banking infrastructure and ecosystems open to international investors, both centres offer serious opportunities for crypto ventures. Licensing types, company setup steps, tax advantages and the key differences between the two jurisdictions are compared below, drawing on current official sources from the SFC, MAS, IRD and IRAS.
Table of Contents
Hong Kong and Singapore sit at the heart of capital markets in the Asia-Pacific region. Both centres offer a predictable legal system rooted in English common law, low and competitive tax rates, advanced banking networks and structures open to international investors. For crypto and blockchain ventures, the real differentiator is regulatory clarity: both jurisdictions have tied digital asset activities to specific licensing regimes, strengthening investor confidence and corporate reputation alike.
Hong Kong serves as a direct gateway to Mainland China and the wider Asian market, while Singapore positions itself as Southeast Asia's fintech hub. Choosing the right centre for a crypto venture depends on the target market, the product type (exchange, custody, payments, token issuance) and the growth strategy.
In Hong Kong, virtual asset activities are regulated by the Securities and Futures Commission (SFC). The VATP (Virtual Asset Trading Platform) licensing regime, established for virtual asset trading platforms, is mandatory for businesses offering exchange services. The SFC operates on a "same activity, same risk, same regulation" principle and places investor protection at its core.
Under the SFC's VATP Licensing Handbook, platforms are expected to ensure secure custody of client assets, strong anti-money-laundering (AML/CFT) procedures, cybersecurity standards and a qualified management team. Throughout 2025–2026, the SFC has continued to advance its "ASPIRe" roadmap and new frameworks for virtual asset derivatives and perpetual contracts.
All platforms offering virtual asset trading services to the public in Hong Kong are subject to the VATP licence. Additional activities such as custody, brokerage and fund management may also engage the SFC's relevant licence types (for example Type 1 and Type 9).
In Singapore, the regulator for crypto activities is the Monetary Authority of Singapore (MAS). The core legal framework is the Payment Services Act (PS Act), which came into force on 28 January 2020. Under this act, MAS regulates seven types of payment services; the critical category for crypto businesses is the Digital Payment Token (DPT) service.
Under the PS Act, businesses may apply for different licence categories according to their transaction volume (for example Standard Payment Institution and Major Payment Institution). In addition, on 30 May 2025 MAS published guidelines on the Digital Token Service Provider (DTSP) licensing framework under the Financial Services and Markets Act (FSMA), bringing digital token providers serving overseas markets into scope.
Companies providing DPT services must fully comply with AML/CFT rules, protect client assets and observe MAS's marketing restrictions towards retail investors. MAS clearly expects that digital payment token services should not be aggressively promoted to the general public.
The tax regime is one of the decisive factors in choosing a hub. The table below summarises the core corporate tax structure of the two centres.
| Criteria | Hong Kong | Singapore |
|---|---|---|
| Corporate Tax | Two-tiered: 8.25% on first HKD 2 million of profits; 16.5% above | 17% (effective rate may fall with new start-up exemption schemes) |
| Capital Gains Tax | None | None |
| Crypto Regulator | SFC (VATP regime) | MAS (PS Act – DPT / FSMA – DTSP) |
| Tax System | Territorial | Territorial + foreign income exemptions |
Both hubs are moving fast to bring stablecoins under formal rules. In Hong Kong, the Stablecoins Ordinance took effect on 1 August 2025, making an HKMA licence mandatory for issuers of fiat-referenced stablecoins. In Singapore, MAS runs a dedicated framework for single-currency stablecoins and, since 30 June 2025, has extended licensing to digital token providers serving only overseas markets under the DTSP regime. Ventures planning issuance or stablecoin integrations should shape their business model around these new frameworks.
Banking is the second threshold after licensing. In both hubs, banks apply enhanced due diligence to crypto companies, expecting documented business plans, source of funds and AML policies. Virtual banks and crypto-friendly intermediaries in Hong Kong, and digital banks plus licensed payment institutions in Singapore, offer practical alternatives. Planning the account strategy in parallel with the licence application shortens the path to going live considerably.
Incorporation itself takes only days in either hub; the licence sets the real calendar. Preparing and clearing an SFC VATP application in Hong Kong is typically measured in months, and MAS licensing in Singapore involves similarly thorough review. Beyond formation and annual secretarial fees, the main budget lines are mandatory local personnel, compliance officers, audits and capital requirements. As exact figures depend on the activity scope, itemised quotes after the category is settled are the sound approach.
Two items drive the licensing budget: the minimum capital regulators expect and the application and annual fees. In Hong Kong, a platform applying for a VATP licence must maintain at least HKD 5 million in paid-up share capital and at least HKD 3 million in liquid capital. The SFC also expects applicants to hold cash and cash-equivalent assets covering 12 months of actual operating expenses; crypto assets do not count towards liquid capital. In Singapore, base capital depends on the licence class: SGD 100,000 for a Standard Payment Institution (SPI) and SGD 250,000 for a Major Payment Institution (MPI). In practice, MAS expects financial strength well above these floors, scaled to the business plan and transaction volumes.
The current fee and capital requirements of both hubs can be summarised as follows:
| Item | Hong Kong (SFC – VATP) | Singapore (MAS – DPT) |
|---|---|---|
| Minimum paid-up capital | HKD 5,000,000 | SPI: SGD 100,000 · MPI: SGD 250,000 (base capital) |
| Liquid capital / extras | At least HKD 3,000,000 + 12 months of operating expenses | MAS may require additional financial strength based on the business plan |
| Application fee | Licensed corporation applications from HKD 4,740 | SPI: SGD 1,000 · MPI: SGD 1,500 |
| Annual fee | SFC tariff applies by activity type | SPI: SGD 5,000 · MPI: SGD 10,000 |
| Custody rule | At least 98% of client assets in cold storage | Asset segregation + Travel Rule obligations |
Fee levels shift with exchange rates and regulatory updates, so the official SFC and MAS fee schedules should be checked before an application file is prepared.
Under the SFC regime, at least 98% of client crypto assets must be held offline in cold wallets. The 2% held in hot wallets must be fully covered by insurance or an equivalent compensation arrangement, and at least half of the assets in cold storage must be covered as well. A platform must appoint at least two Responsible Officers and designate Managers-in-Charge for core functions such as risk management, compliance, information technology and AML/CFT. On the Singapore side, MAS enforces a strict AML/CFT framework covering segregation of client assets from company assets, transmission of transfer data under the Travel Rule, annual independent audits and suspicious transaction reporting.
Licensed platforms in Hong Kong have been able to serve retail investors since August 2023, subject to knowledge tests and risk profiling. The SFC publishes an up-to-date public register of licensed VATPs on its website; checking that register before choosing a partner or custody provider is a simple but effective safeguard. In Singapore, MAS restricts incentives and promotions aimed at retail customers and expects DPT providers to assess each customer’s risk awareness. For institution-focused business models these differences rarely affect day-to-day operations, but they do shape the marketing strategy.
In both centres, setting up a crypto-focused company combines standard company registration with a licensing process. The general flow is as follows:
For ventures aiming to scale internationally and valuing institutional investors and banking relationships, both centres provide a strong foundation. Choosing the right centre is decisive in terms of long-term cost and reputation.
In Hong Kong, companies are incorporated with the Companies Registry. At least one individual director, a registered office address in Hong Kong and a resident company secretary are required; shareholders do not need to live in Hong Kong. Incorporation completes within a few business days, and for licensable activities the SFC application follows this step. The scope of the process is set out on the company formation in Hong Kong page.
In Singapore, registration is handled through ACRA. At least one locally resident director, a company secretary appointed within six months, a local registered address and paid-up capital starting from 1 SGD are sufficient. Ventures planning crypto activity are expected to have AML/CFT policies and a compliance team in place before approaching MAS. The company formation in Singapore page covers all of these stages.
Ecosystem support also plays a role in the decision: Cyberport in Hong Kong runs incubation programmes for Web3 ventures, while the MAS fintech regulatory sandbox in Singapore allows new business models to be tested in a controlled environment.
Hong Kong stands out with access to China and Northeast Asia and its strong capital market infrastructure. Singapore offers advantages in terms of its fintech ecosystem, legal stability and gateway to Southeast Asia. The decision should be shaped by your target market, product model and regulatory preferences. A proper feasibility and advisory process clarifies this choice.
For end-to-end support in setting up a crypto company, you can get in touch with us or quickly request a free quote.
Contact our expert team for a tailored preliminary assessment of the process, costs and required documents. Fill in the form and we will get back to you within 24 hours.
Licence strategy, incorporation, banking and compliance planned from a single point. Our team works with local partners in both hubs.
Platforms offering virtual asset trading to the public fall under the SFC's VATP (Virtual Asset Trading Platform) licensing regime. Activities such as custody, brokerage and fund management may require additional SFC licences.
Crypto businesses apply for the Digital Payment Token (DPT) service licence under the Payment Services Act. Since 30 May 2025, the DTSP framework under the FSMA also covers providers serving overseas markets.
Hong Kong applies a two-tiered system: 8.25% on the first HKD 2 million of profits and 16.5% above. Singapore's standard corporate tax is 17%, and start-up exemption schemes may lower the effective rate. Rates may change; verify with official sources.
Neither Hong Kong nor Singapore levies a general capital gains tax. However, income of a trading nature may be subject to corporate tax; a case-by-case professional assessment is important.
Hong Kong is advantageous for access to China and Northeast Asia, while Singapore excels in its fintech ecosystem and gateway to Southeast Asia. The right choice depends on your target market, product model and regulatory preferences.
Yes. Under the Stablecoins Ordinance, in force since 1 August 2025, issuers of fiat-referenced stablecoins must obtain an HKMA licence.
Banks apply enhanced due diligence; with a documented business plan, source of funds and AML policies, accounts are achievable through virtual banks and licensed payment institutions.
The SFC requires at least HKD 5 million in paid-up share capital and at least HKD 3 million in liquid capital. Applicants must also hold cash-like assets covering 12 months of actual operating expenses; crypto assets do not count towards liquid capital.
Under Part 9 of the FSMA, in force since 30 June 2025, companies operating from Singapore that provide digital token services solely to overseas customers must also obtain a DTSP licence from MAS. Operating without a licence is a criminal offence.
+90 542 381 3868
+971 58 5204103