Understanding Stored Value Facility (SVF) Licences in Hong Kong

A Stored Value Facility (SVF) licence is mandatory in Hong Kong for any person issuing a facility that stores value and can be used to pay for goods or services. The licence is granted by the Hong Kong Monetary Authority (HKMA) under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). Operating without one is a criminal offence.

What Is a Stored Value Facility Under Cap. 584?

A Stored Value Facility is defined in section 2 of the Payment Systems and Stored Value Facilities Ordinance (Cap. 584) as a facility (other than a specified facility) that stores value and may be used to pay for goods or services, where the value is stored in the facility and the facility is not a "single-purpose" facility tied to one merchant group.

The Ordinance commenced on 13 November 2015 and replaced the earlier regulatory regime under the Banking Ordinance (Cap. 155). The HKMA is the sole licensing authority.

Two categories of SVF exist:

• Single-purpose SVF: usable only to pay for goods or services of one person or a group of persons under common control. Generally exempt from licensing.
• Multi-purpose SVF: usable to pay multiple unrelated merchants. This is the category that triggers the licensing requirement.

Under section 5(1) of the Payment Systems and Stored Value Facilities Ordinance (Cap. 584), "a person shall not issue a stored value facility in Hong Kong" unless licensed by the Monetary Authority or exempt under the Ordinance.

Common Examples of Licensed SVFs

Ongoing Compliance Execution

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Eligibility: Who Qualifies for an SVF Licence?

Any company incorporated in Hong Kong may apply, but the HKMA applies a fit-and-proper test to the applicant, its directors, chief executive, and controllers. Non-Hong Kong companies must establish a local subsidiary or branch. The applicant must meet minimum capital, governance, and risk-management standards before a licence is granted.

The HKMA's Guide to Application for a Stored Value Facility Licence sets out the assessment criteria. Key eligibility conditions include:

• Legal form: the applicant must be a body corporate. Sole proprietors and partnerships are not eligible.
• Minimum capital: the applicant must maintain a minimum capital of HKD 25 million (or an equivalent amount in another currency) at all times. This figure is set out in the Ordinance and should be confirmed against the latest HKMA guidance.
• Fit and proper: directors, the chief executive, and controllers must satisfy the HKMA's fit-and-proper criteria, including no relevant criminal convictions and no history of regulatory breaches.
• Substantial link: the HKMA must be satisfied that a substantial link exists between the applicant and Hong Kong.
• Risk management: the applicant must have adequate systems for float management, cybersecurity, anti-money laundering (AML), and counter-financing of terrorism (CFT).

Directors and Controllers

The HKMA assesses each director, the chief executive, and every controller (any person holding 10% or more of shares or voting power, or able to exercise significant influence). Changes to these roles after licensing require prior HKMA approval.

Timelines: How Long Does an SVF Licence Take?

The HKMA does not guarantee a fixed processing period. In practice, a complete application takes several months from submission to decision, and the HKMA's published guidance indicates that applicants should allow ample time for review, clarification, and possible revision of business plans. There is no statutory deadline for the HKMA to decide.

1. Pre-application engagement: Discuss the proposed business model with the HKMA before formal submission. This stage has no fixed duration and depends on the complexity of the model.
2. Formal application submission: Submit the completed application form, business plan, capital evidence, governance documents, and AML/CFT policies to the HKMA.
3. HKMA review and queries: The HKMA reviews the application and issues follow-up questions. Applicants must respond fully; delays here extend the overall timeline.
4. Assessment against criteria: The HKMA assesses capital, fit-and-proper status, risk management, and the substantial link to Hong Kong.
5. Decision: The HKMA grants or refuses the licence. A refusal must be communicated with reasons.
6. Post-licence conditions: The licensee must comply with ongoing conditions, including reporting and float management requirements. Applicants should confirm current processing expectations directly with the HKMA, as the authority does not publish a guaranteed turnaround figure.

Cost Metrics: What Does an SVF Licence Cost?

The application fee is set out in the Payment Systems and Stored Value Facilities Ordinance (Cap. 584) and its subsidiary legislation. The minimum capital requirement of HKD 25 million is the dominant cost, not the application fee itself. Applicants should verify the current fee schedule with the HKMA before budgeting.

The HKD 25 million minimum capital must be maintained on an ongoing basis, not merely at the point of application. This is a continuing obligation, not a one-off cost.

Transparent Cost Framework

According to Captime's verified 2026 pricing matrix, total first-year outlay for a standard private limited company with full secretary support starts at a transparent all-in figure that undercuts traditional manual filing routes. View the full breakdown on the Captime HK incorporation pricing page.

Suitability: Who Should Apply and Who Should Not?

An SVF licence suits established companies with at least HKD 25 million in capital, a credible multi-merchant payment model, and the compliance infrastructure to manage float and AML obligations. It is not suitable for single-merchant loyalty schemes, small prepaid gift card issuers, or startups without capital and governance capacity.

Apply for an SVF Licence If:

• You issue a prepaid wallet or card usable at multiple unrelated merchants.
• You hold customer funds as stored value and settle with merchants.
• You can maintain HKD 25 million in capital and meet HKMA governance standards.
• You have AML/CFT systems proportionate to your transaction volume.

Do Not Apply If:

• Your facility is single-purpose and usable only at your own outlets.
• You are a small issuer without the capital or compliance capacity.
• Your model is a pure payment gateway that does not store value (this may fall under different rules — check with the HKMA).
• You are unsure whether your facility stores value; seek legal advice before assuming exemption.

Ongoing Compliance Obligations After Licensing

A licensed SVF issuer must comply with continuing obligations under Cap. 584 and HKMA guidelines. These include float management, safeguarding of stored value, reporting, and notification of changes to controllers or directors.

Key ongoing duties:

• Float management: stored value must be backed by adequate safeguarding arrangements as specified by the HKMA.
• Reporting: submit periodic returns and notify the HKMA of material changes.
• AML/CFT: maintain and update AML/CFT policies in line with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
• Cybersecurity: maintain systems proportionate to the risk profile of the business.
• Change notifications: obtain prior HKMA approval for changes to directors, chief executive, or controllers.

How SVF Licensing Interacts with Other Regimes

An SVF licence does not replace other regulatory requirements. Depending on the business model, an issuer may also need to consider the Banking Ordinance (Cap. 155), the Securities and Futures Ordinance (Cap. 571), and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

If your facility also involves stored value in virtual assets, separate licensing under the AMLO regime for virtual asset service providers may apply. Confirm the overlap with the HKMA and the Securities and Futures Commission before launch.

HSIC Classification for SVF Businesses

When registering a company or filing business registration, the correct industry code matters for statistics and some licensing forms. SVF and payment-related activities typically fall under financial service codes in HSIC Version 2.0 (Census and Statistics Department).

Confirm the most appropriate code for your specific activity with the Companies Registry and the Census and Statistics Department, as classification depends on the precise nature of the business.

Q: Is an SVF licence the same as a money service operator (MSO) licence? A: No. An MSO licence covers money changing and remittance under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). An SVF licence covers the issuance of stored value and is granted by the HKMA under Cap. 584. A business may need both.

Q: Can a non-Hong Kong company hold an SVF licence? A: The applicant must be a body corporate with a substantial link to Hong Kong. In practice, overseas companies establish a Hong Kong subsidiary or branch. The HKMA assesses the substantial link as part of the application.

Q: What happens if I issue an SVF without a licence? A: Issuing a stored value facility without a licence or exemption is a criminal offence under Cap. 584. Penalties include fines and imprisonment. The HKMA may also take enforcement action.

Q: Is the HKD 25 million capital requirement a one-off payment? A: No. It is a minimum capital requirement that must be maintained on an ongoing basis. Falling below it may trigger regulatory consequences.

Q: Do single-merchant gift cards need an SVF licence? A: Generally no, if the facility is single-purpose and usable only for that merchant's goods or services. The exemption depends on the specific facts; confirm with the HKMA or legal counsel.

Summary

An SVF licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584) is required to issue multi-purpose stored value in Hong Kong. Eligibility requires a body corporate, HKD 25 million minimum capital, fit-and-proper directors and controllers, and robust AML/CFT and float management systems. The HKMA does not publish a guaranteed processing timeline, so applicants should engage the authority early and budget for several months. Single-purpose facilities are generally exempt, but the boundary depends on the facts. Verify all fees and current requirements directly with the HKMA before applying.

-> Use the HSIC Code Finder at /hsic-finder to look up your specific code.