Why did HashKey become Hong Kong's "first cryptocurrency stock"?

Authors | Guo Fangxin, Li Xiaobei

introduction

On December 1, 2025, a major news broke: according to the Hong Kong Stock Exchange, HashKey, as one of the first batch of licensed virtual asset service providers (VATP) in Hong Kong, officially passed the listing hearing of the Hong Kong Stock Exchange.

As early as one or two months ago, there were internal rumors in the market that HashKey was preparing for an IPO. On December 1, HashKey passed the hearing and released the "Post-Hearing Information Set". Many mainland readers will have questions: Where is HashKey's IPO at?

From a legal perspective, the Hong Kong Stock Exchange conducted a comprehensive due diligence and review of HashKey's basic information, including its underlying business architecture, complex compliance system, financial status, and corporate governance structure. This essentially recognized HashKey's entry into the mainstream capital market, bringing it one step closer to listing.

The Post Hearing Information Pack (PHIP) published by HashKey on the Hong Kong Stock Exchange's disclosure platform is very similar to the traditional prospectus, which is more familiar to mainland readers, in terms of content and information density, except for some sensitive information that is not disclosed.

In the PHIP, we can see HashKey's key financial data, equity and management structure, and other core information, which is an important document for understanding why HashKey is expected to become the "first crypto stock in Hong Kong".

Today, Crypto Law will provide a detailed legal analysis of this "prospectus," hoping to offer valuable insights for everyone.

Compliance Architecture Analysis

1. Regulatory approval in multiple jurisdictions

HashKey's core narrative lies in its globally built cross-jurisdictional compliance framework. Crypto Lawyer has previously stated that compliance is a relative concept; within a specific jurisdiction, continuous compliance with local regulations constitutes compliance. However, digital assets are liquid, and a single Hong Kong license is clearly insufficient, especially given Hong Kong's strict controls on exchange liquidity. While recent easing allows exchanges to access overseas liquidity, strict restrictions remain on overseas countries and exchange qualifications. For details, see Crypto Lawyer's article: "In-Depth Policy Interpretation by Web3 Lawyers | New Regulations for Hong Kong Virtual Asset Trading Platforms (Part 1): Circular Regarding the Sharing of Liquidity by Virtual Asset Trading Platforms."

Therefore, most platforms' compliance issues stem from the fact that they are required to provide services globally, yet only register a company and apply for a license in a specific region. HashKey's solution is to establish entities and hold local licenses in various financial centers worldwide to comply with local regulatory requirements. PHIP data shows that HashKey's business footprint covers major financial centers in Asia and globally, including Hong Kong, Singapore, Japan, Bermuda, the UAE, and Ireland, where it has obtained licenses. This is based on extremely high legal operating costs and governance capabilities, expanding its legal matrix globally, rather than simply "collecting" licenses in various locations.

2. Technology and internal control compliance come first.

According to PHIP, HashKey's arrangements for asset custody and platform operation are basically consistent with Hong Kong's regulatory system.

The documents show that HashKey has relatively strict measures for customer asset management, including repeatedly emphasizing that the customer asset custody structure is completely separated from the company's own assets and belongs to an independent system; customer digital assets are mainly stored in cold wallets, and as of September 30, 2025, 96.9% of the platform's assets were stored in cold wallets; other common compliance measures include adopting a multi-signature approval process and holding customer fiat currency assets in an independent trust account, etc.

Furthermore, unlike other licensed exchanges in Hong Kong, HashKey Group has built a "regulation-friendly" Ethereum Layer 2 extension network—HashKey Chain. It is not positioned as a public chain for retail users or general decentralized applications, but rather as an infrastructure specifically designed to provide compliance services for institutions. PHIP also mentioned that HashKey Chain has been selected by major financial institutions as the underlying system for tokenized securities.

The documents show that HashKey Chain considered compliance during the protocol design phase, which means that issuance, transfer and settlement on this chain must follow the preset rules. The transparency, auditability and transparency valued by the Hong Kong government are directly supported by the underlying infrastructure.

In this way, companies do not need to build complex systems from scratch, and HashKey Chain can meet regulatory requirements without requiring companies to bear the development costs of technical compliance, thus accelerating the adoption of compliant digital assets in the entire traditional financial industry.

3. Disclosure of Governance Structure

The full disclosure of HashKey's corporate governance structure in PHIP is a part that is rarely mentioned in other documents.

First, in terms of company structure, HashKey Holdings is an exempted limited company registered in the Cayman Islands. The documents list the applicable Cayman Companies Law, Hong Kong Companies Ordinance and Corporate Governance Code at the beginning, which means that it is benchmarked against the Hong Kong Stock Exchange’s standards for listed companies and has built its governance structure in full accordance with these standards.

For example, PHIP disclosed that its post-IPO board of directors will consist of one executive director, one non-executive director, and three independent directors, with the audit committee entirely composed of independent directors. This is a standard structure for listed companies, but not common among Web3 companies. While HashKey's governance structure may seem unremarkable, it has played a crucial role in its success from a legal perspective.

significance

The discussion surrounding HashKey's IPO is unique, partly due to its distinctive legal status. Crypto Law has noted that comparisons between HashKey and OSL are frequently made, debating who deserves the title of "Hong Kong's first crypto stock." From a legal perspective, OSL did not hold a VATP license at the time of its IPO, while HashKey was indeed the first company to attempt to enter the traditional capital market with a VATP license, thus carrying clear regulatory and industry implications.

According to CryptoSalt, HashKey's progress in Hong Kong is mainly due to strong external impetus and clear internal development goals.

The Hong Kong government is currently in a window of opportunity regarding its crypto policy. We believe that Hong Kong is undoubtedly a bridgehead for China's virtual asset pilot program, and the Hong Kong government may need a successful compliance case to showcase its achievements. HashKey, as a benchmark for Hong Kong's VATP, if it can successfully list, essentially demonstrates that Web3 and compliance are not contradictory and can be achieved through institutionalization.

Of course, compliance is crucial from a business perspective, but its costs are also substantial. Bearing legal obligations under multiple regulatory frameworks, including ongoing risk control, AML/KYC, network and technical security, and auditing costs, requires continuous financial support. The PHIP's risk factors section clearly states that the platform may face regulatory reviews, investigations, and enforcement proceedings during its operations, which can lead to significant time investment and substantial legal and compliance costs. HashKey's obligations are ongoing, not a one-time investment.

Moreover, the ability to gain institutional-level trust and global reputation through going public is far more attractive to traditional financial institutions seeking stable and secure partners than to a private exchange.