Author: Liang Yu
Editor: Zhao Yidan
On December 1, 2025, the Hong Kong Stock Exchange disclosed that HashKey Holdings Limited has officially passed the main board listing hearing, with JPMorgan, Cathay Securities, and Guotai Junan International serving as joint sponsors. The announcement of this news is like a bright light shining in a winter night, illuminating the future path of Hong Kong's virtual asset industry.

This name, which has come a long way from the "regulatory pilot era," now stands for the first time in the spotlight of the capital market. It is not only the first listed company in Hong Kong with an exchange as its core business under the specialized regulatory framework for virtual assets but also a real test of whether compliance and innovation can coexist. At the crossroads of traditional finance and the accelerated integration of digital assets, how will HashKey's path to capitalization reshape the industry ecosystem? Can it find a sustainable business model amid continuous losses and strong cyclicality? The outcome of this experiment may determine the future landscape of Hong Kong as an international virtual asset center.
1. The exchange is just the entry point; it tells a bigger story
If HashKey is simply defined as an exchange, the core of its business logic will be missed. According to HashKey's prospectus, as of September 30, 2025, its cumulative spot trading volume reached HKD 13 trillion, firmly ranking first among regional onshore platforms in Asia. However, trading business is more like the entry point of an ecosystem, with real value hidden in its constructed "trading - on-chain - asset management" triangular closed loop.
From the perspective of business composition, HashKey Exchange adopts a unique dual-track operating model. Retail users can only trade five mainstream tokens such as BTC and ETH, while professional investors can access 80 digital assets, including SOL and LINK. This differentiated management, while limiting user growth, precisely aligns with Hong Kong's regulatory logic of "investor protection first." Its over-the-counter trading service adopts a commission model, primarily generating income through price differences, which is recorded as commission income on a net basis in financial statements, contrasting sharply with the market maker model of traditional exchanges.
In terms of technical architecture, HashKey has invested heavily in building an institutional-grade security assurance system. Its custody solution employs a multi-signature and cold-hot wallet separation design, seamlessly connecting with order book trading and OTC services. Notably, HashKey is one of the few exchanges that provide fully compliant deposit/withdrawal services around the clock, giving it a unique advantage in attracting traditional financial institution clients. In contrast, Coinbase primarily serves the North American market, with its technical architecture focusing more on standardized products, while HashKey deeply cultivates the Asian market, building a differentiated advantage in compliance and customized services.
2. On the chessboard of Hong Kong regulation, HashKey is ahead of the game
HashKey's development history is a microcosm of the evolution of virtual asset regulation in Hong Kong. From the Hong Kong Securities and Futures Commission's release of the conceptual document on virtual asset regulation in 2018 to HashKey becoming one of the first approved VATPs to provide services to both professional and retail investors in August 2023, this regulatory path has taken a full five years.
The trust endorsement brought by the licensed status is difficult to quantify but is crucial. According to Forbes' 2025 list of "The Most Trusted Cryptocurrency Exchanges in the World," HashKey Exchange ranks 14th globally and is the only platform from Hong Kong on the list. However, the cost of compliance is also enormous. Market analysis indicates that a single VASP license application fee could reach HKD 20 million to 50 million, and licensed institutions must be equipped with multiple responsible personnel, with an average annual salary of about HKD 2 million to 5 million. This is directly reflected in its financial performance: the prospectus shows that although revenue reached HKD 721 million in 2024, losses expanded to HKD 1.19 billion in the same year.

Comparing with major regulatory jurisdictions globally further illustrates the issue. In the United States, Coinbase follows a state-based money service provider licensing system; in Singapore, the MAS adopts a tiered licensing system; while Hong Kong's VASP license requires exchanges to fully comply with the Anti-Money Laundering Ordinance and the regulations of the Securities and Futures Commission. This comprehensiveness, while raising compliance costs, brings scarcity value to licensed institutions. In November 2025, the Hong Kong Securities and Futures Commission released new regulations allowing licensed platforms to share liquidity with overseas affiliated platforms, which directly benefits HashKey, which has established a network of exchanges in Hong Kong, Bermuda, and the Middle East, marking a shift in Hong Kong's regulation from conservative to open.
3. International benchmarking: three paths, three destinies
Looking at the capitalization paths of global cryptocurrency exchanges, HashKey has chosen a different route. Unlike Coinbase, which went public through a direct listing on NASDAQ in 2021, HashKey opted for a main board listing in Hong Kong; compared to OSL, which went public via a reverse merger as early as 2020, HashKey has built a more complete business ecosystem.
Coinbase's listing represents the American model—exchanging a large user base for valuation premiums in a relatively mature regulatory environment. However, the subsequent volatility in its stock price also exposed the vulnerability of excessive reliance on trading income. OSL, on the other hand, showcases the dilemma of early explorers—although it was the first to obtain a license from the Hong Kong Securities and Futures Commission, its single business model led to continuous losses and multiple rounds of layoffs in 2024-2025 (data source: OSL Group financial report). HashKey attempts to take the third path: through a "trading + on-chain + asset management" integrated structure, reducing dependence on trading fees, which has no successful precedent in the Asian market.

From a valuation logic perspective, Coinbase's price-to-earnings ratio has long been higher than that of traditional exchanges, reflecting the market's recognition of the growth potential of the digital asset industry. However, HashKey faces a different valuation environment—Hong Kong investors remain cautious about the concept of virtual assets, and its continuous loss status may make it difficult to obtain a valuation premium similar to Coinbase. This difference essentially reflects the varying levels of understanding of digital assets between the Asian and North American markets.
4. RWA is not a business; it is the backbone of HashKey's future narrative
In the historic wave of integration between traditional financial assets and blockchain, HashKey views the tokenization of real-world assets as its ultimate battlefield. This layout not only concerns business diversification but also determines whether it can break through the cyclical shackles of trading business.
HashKey Chain, designed as a compliant financial network specifically for RWA, employs a leading Layer 2 solution in its technical architecture. Its core innovation lies in the embedded compliance module, allowing issuers to set trading rules and permissions, enhancing asset circulation efficiency while meeting KYC/AML requirements. In June 2025, HashKey collaborated with GF Securities to issue Hong Kong's first daily redeemable tokenized security, achieving T+0 settlement and on-chain automatic dividends, showcasing the technical maturity of HashKey Chain. According to HashKey's prospectus, as of September 30, 2025, the total value of on-chain RWA has reached HKD 1.7 billion.
Hong Kong's forward-looking regulation on RWA provides HashKey with institutional advantages. Compared to the SEC's cautious attitude towards tokenized securities in the United States, the Hong Kong Securities and Futures Commission has adopted a more open regulatory framework, clearly defining the legal status and issuance requirements of tokenized securities. This institutional innovation places Hong Kong at the forefront of the global RWA field. The Boston Consulting Group predicts that by 2033, the scale of on-chain RWA will reach USD 18.9 trillion, with an annual growth rate of 53%. HashKey is attempting to occupy a core position in this trillion-dollar track through the dual advantages of technology and compliance.
5. The listing is a starting point and the beginning of a pressure test
Although HashKey has attracted market attention by passing the hearing, the challenges it faces are just beginning. The triple pressures of profitability issues, industry cycles, and intensified competition will test the resilience of this first-mover enterprise.
Financial data reveals a worrying trend. The prospectus shows that HashKey's revenue continued to grow from 2022 to 2024, but losses also expanded simultaneously. In the first half of 2025, revenue fell by 26% year-on-year, mainly due to a decline in retail trading volume caused by a sluggish market. This exposes the vulnerability of its revenue's high dependence on trading fees. Meanwhile, the gross profit margin dropped from 97.2% in 2022 to 65.0% in the first half of 2025, reflecting rising operating costs during the process of business diversification. Referring to OSL Group's operating conditions—after briefly turning a profit in 2024, it fell back into losses in 2025—it is evident that the profitability stability of virtual asset exchanges remains to be verified.
The strong cyclicality of the cryptocurrency market hangs over like the sword of Damocles. In the first half of 2025, trading volume fell by 38% year-on-year, directly leading to a decline in revenue. At the same time, the entry of traditional financial institutions is changing the competitive ecology—41 institutions have upgraded to "License 1" to support virtual asset trading, while tech giants like JD.com and Ant Group have also made progress in the tokenization field. Compared to these competitors with native scenarios, HashKey must continuously strengthen its compliance and technical advantages to maintain its leading position.
The prospectus indicates that the raised funds will primarily be used for technology iteration, market expansion, and risk management. If HashKey can establish standards in the RWA infrastructure field and successfully develop on-chain services into a second growth curve, it is expected to break through the current growth bottleneck. However, this path is full of uncertainties—can high compliance costs be diluted through scaling? Will traditional financial institutions choose to build rather than collaborate? The answers to these questions will determine whether HashKey can navigate this uncharted path.
Conclusion: The repositioning of Hong Kong's finance and the beginning of a new narrative
The story of HashKey goes far beyond the listing of a single company. It is a key move in Hong Kong's effort to reshape its status as an international financial center and an important experiment in the evolution of global virtual asset regulation.
From a broader perspective, Hong Kong is showcasing a new path of financial development that balances "stability and innovation" to the world through benchmark enterprises like HashKey. In the context of increasingly fierce competition among traditional international financial centers, virtual assets provide Hong Kong with a breakthrough for differentiated competition. HashKey's successful listing signifies that Hong Kong has taken the lead globally in the digital asset regulatory system, which is not only a victory for financial innovation but also a symbol of institutional innovation.
Whether this can truly become the "first stock of Hong Kong digital assets" will ultimately not be determined by regulation but by time. In the historical process of the accelerated integration of traditional finance and the crypto world, HashKey is both a participant and a pathfinder. Every step it takes is drawing a map for those who follow. Regardless of the outcome, this experiment that began in the winter of 2025 will leave a profound mark in the annals of Hong Kong's financial history.
Some sources of information:
· "HashKey Exchange retains its position as the 'Most Trusted Cryptocurrency Exchange in the World' by Forbes, ranking first in Hong Kong"
· "The 'first stock of Hong Kong's crypto assets' is here! HashKey passes the Hong Kong Stock Exchange hearing, becoming the largest licensed virtual asset exchange in Hong Kong"
· "HashKey passes the Hong Kong Stock Exchange hearing"
· "HashKey interprets the latest guidelines from the Hong Kong Securities and Futures Commission: Open interconnection, building a sustainable digital asset ecosystem"
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