據明報，香港證監會及財庫局公布諮詢文件顯示，無論是小如虛幣交易、提款、兌換法幣，複雜如經紀活動、大手交易都要向證監申領牌照，等於將虛產場外交易（OTC）平台納入監管，且要求遠較去年諮詢時有關 OTC 平台向海關申領牌照的要求嚴格。包括交易服務商最低繳足股本交易服務商 500 萬元，託管商為 1000 萬元，同時須具備兩位獲證監核準的負責人員。

According to *Ming Pao*, the consultation paper jointly released by the Hong Kong SFC and the Treasury Bureau states that all activities—from minor operations like virtual currency trading, withdrawals, and fiat currency exchange to complex activities like brokerage services and large-lot transactions—must apply for licenses from the SFC. This effectively brings over-the-counter (OTC) virtual asset trading platforms under regulation, with requirements significantly stricter than last year’s consultation proposal that OTC platforms should apply for licenses from the Customs. Key provisions include a minimum paid-up capital of HK$5 million for trading service providers and HK$10 million for custodians, along with the requirement to have two SFC-approved responsible officers.