I. Introduction
On December 1, 2025, a significant piece of news broke: according to the Hong Kong Stock Exchange, HashKey, as one of the first licensed virtual asset service providers (VATP) in Hong Kong, has officially passed the listing hearing of the Hong Kong Stock Exchange.
As early as a month or two prior, there were internal rumors in the market about HashKey preparing for an IPO. On December 1, HashKey passed the hearing and released the "Post Hearing Information Pack" (PHIP), leading many mainland readers to wonder: What stage is HashKey's listing 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 structure, complex compliance system, financial status, and corporate governance structure, effectively recognizing HashKey's entry into the mainstream capital market, with only one step left to go before listing.
The PHIP released by HashKey on the Hong Kong Stock Exchange's disclosure platform is highly similar in content and information density to the traditional "Prospectus" that mainland readers are more familiar with, except for certain sensitive information that is not disclosed.
In the PHIP, we can see HashKey's key financial data, equity, and management structure, among other core information, which is an important document for understanding why HashKey is expected to become the "first cryptocurrency stock in Hong Kong."
Today, Crypto Salad will provide a detailed legal interpretation of this "quasi-prospectus," hoping to bring reference value to everyone.
II. Compliance Structure Analysis
1. Regulatory Recognition Across Multiple Jurisdictions
HashKey's core narrative lies in its cross-jurisdictional compliance framework built globally. Crypto Salad has previously stated that compliance is a relative concept; within a specific jurisdiction, business operations that continuously comply with local regulatory requirements are considered compliant. Digital assets are fluid, and having only one license in Hong Kong is clearly insufficient, especially since Hong Kong has strict liquidity controls for exchanges. Recently, there has been some relaxation, allowing exchanges to connect with overseas liquidity, but there are still strict restrictions on overseas countries and exchange qualifications. For more details, see Crypto Salad: “Web3 Lawyer's In-Depth Policy Interpretation | New Regulations for Virtual Asset Trading Platforms in Hong Kong (Part 1): Circular on Sharing Liquidity by Virtual Asset Trading Platforms.”
Therefore, most platforms' compliance issues arise from the fact that they must provide services globally but only register a company and apply for a license in a specific region. In response, HashKey's solution is to establish entities in various global financial centers and hold local licenses to meet regulatory requirements. The PHIP shows that HashKey's business footprint covers major financial centers in Asia and globally, including Hong Kong, Singapore, Japan, Bermuda, the UAE, and Ireland, and it has obtained licenses in these locations. This is based on extremely high legal operational costs and governance capabilities, expanding the legal matrix globally rather than simply "collecting stamps" by applying for licenses in various places.
2. Proactive Compliance in Technology and Internal Controls
The PHIP indicates that HashKey's arrangements for asset custody and platform operations are largely consistent with Hong Kong's regulatory system.
The document shows that HashKey has relatively strict measures in customer asset management, repeatedly emphasizing that the customer asset custody structure is completely separate from the company's own assets and is an independent system; customer digital assets are primarily stored in cold wallets, with 96.9% of platform assets stored in cold wallets as of September 30, 2025; other common compliance measures include using a multi-signature approval process and holding customer fiat assets in independent trust accounts, among others.
Additionally, unlike other licensed exchanges in Hong Kong, HashKey Group has created a "regulatory-friendly" Ethereum Layer 2 expansion network—HashKey Chain. Its positioning is not aimed at retail users or general decentralized applications but is specifically designed as infrastructure to provide compliance services for institutions. The PHIP also mentions that HashKey Chain has been selected by major financial institutions as the underlying system for tokenized securities.
The document shows that compliance was considered at the protocol design stage of HashKey Chain, meaning that the issuance, transfer, and settlement on this chain must adhere to predefined rules, with the transparency, auditability, and penetrability valued by the Hong Kong government directly supported by the underlying infrastructure.
As a result, enterprises do not need to build complex systems from scratch, and HashKey Chain can meet regulatory requirements without the enterprise bearing the development costs of technical compliance, accelerating the entire traditional financial industry's adoption of compliant digital assets.
3. Disclosure of Governance Structure
The complete disclosure of HashKey's corporate governance structure in the PHIP is a relatively rare aspect mentioned in other documents.
First, from a corporate form perspective, HashKey Holdings is an exempt company registered in the Cayman Islands. The document begins by listing the applicable "Cayman Islands Companies Law," "Hong Kong Companies Ordinance," and "Corporate Governance Code," which determines that its overall governance structure is built in accordance with the standards for listed companies set by the Hong Kong Stock Exchange.
For example, the PHIP discloses that the post-listing board will consist of 1 executive director, 1 non-executive director, and 3 independent directors, with the audit committee entirely composed of independent directors. This is a standard structure for listed companies but is not common in Web3 companies. HashKey's ability to reach this stage, while its governance structure may seem unremarkable, is crucial from a legal perspective.
III. Significance
The discussion around HashKey's listing is particularly significant partly due to its unique legal status. Crypto Salad has noticed that there are often comparisons made between HashKey and OSL in the market, debating who is the "first cryptocurrency stock in Hong Kong." From a legal perspective, OSL did not hold a VATP at the time of its listing, while HashKey is indeed the first company attempting to enter the traditional capital market with a VATP license, thus carrying clear regulatory and industry signaling significance.
In Crypto Salad's view, HashKey's advancement in Hong Kong is primarily driven by strong external motivation and clear internal development demands.
The Hong Kong government is currently in a window period for cryptocurrency policy. We believe that Hong Kong is undoubtedly a pilot bridgehead for virtual assets in China, and the Hong Kong government may also need a successful compliance case to showcase its achievements. As a benchmark for Hong Kong VATPs, if HashKey can successfully list, it essentially conveys that Web3 and compliance are not in conflict and can be achieved through institutionalization.
Of course, from a business perspective, while compliance is important, the costs of compliance are also substantial. Bearing legal obligations under multiple national regulatory frameworks, including ongoing risk control, AML/KYC, cybersecurity, technical security, and audit costs, requires continuous funding support. The risk factors section of the PHIP clearly states that the platform may face regulatory scrutiny, investigations, and enforcement procedures during its operations, which could lead to significant time investment and "huge legal and compliance costs." HashKey needs to continuously bear these obligations, not just a one-time investment.
Moreover, being able to gain institutional-level trust and global reputation through listing is far more attractive to traditional financial institutions seeking stable and secure partners than a private exchange.
Special Statement: This article is an original work by the Crypto Salad team, representing the personal views of the author and does not constitute legal advice or consultation on specific matters. For reprinting, please privately message to discuss authorization matters: shajunlvshi.
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