On October 8, it was noted that the official website of the Hong Kong Special Administrative Region government recently disclosed the content of a written reply to the Legislative Council regarding the regulation of emerging payment platforms, emphasizing that payment business must be operated under a license.
In recent years, a number of emerging aggregated payment platforms have appeared in the Hong Kong market, attracting small merchants with low handling fees and offers such as "buy now, pay later." However, some platforms have successively experienced problems such as delayed payments and false deposit records, causing serious losses to merchants. Some payment platforms are registered only as fintech companies without obtaining any financial license, and they do not disclose their partner institutions or operational status, leaving their operations unregulated.
Regarding these issues, Acting Secretary for Financial Services and the Treasury Joseph Chan Ho-lim said in his reply that between January 2024 and September 2026, the Hong Kong Monetary Authority received a total of 16 complaints about the suspected unlicensed issuance or operation of stored value payment facilities (SVF). After investigation, one complaint was substantiated, and the Hong Kong Monetary Authority is following up with the company concerned.
Aggregated payment refers to a technical service that integrates multiple payment channels into a single entry point, allowing merchants to collect payments through multiple channels, conduct unified reconciliation, and carry out fund clearing after a single integration. Considering the industry conditions and regulatory requirements in mainland China, in addition to the aggregated payment services provided by banks and payment institutions themselves, there are also third-party platforms on the market that do not hold payment licenses and provide payment services only by connecting to multiple payment channels. However, such platforms may be abused for illegal cash-out and other risks during actual operations, making them a key focus of payment regulation.
Regarding the regulatory attention now being given to Hong Kong's emerging aggregated payment platforms, Wang Pengbo, chief analyst at Botong Consulting, pointed out that newly emerging aggregated payment entities in the market are expanding their merchant base through low fee rates and buy now, pay later products, and some entities have not been incorporated into the existing regulatory framework, making risks related to merchant funds more likely. Therefore, Hong Kong regulators need to adapt the rules to changes in the local market landscape in order to clarify business access boundaries, distinguish the licensing requirements corresponding to different businesses, reduce disputes caused by unlicensed operations, and maintain the basic order of fund flows on the merchant side.
A further review found that as early as late 2004, Hong Kong's core law in the payment field, the Clearing and Settlement Systems Ordinance, had already taken effect. Later, with the rise of electronic wallets, Hong Kong amended the ordinance in 2015, expanded the regulatory functions for SVF, and renamed it the Payment Systems and Stored Value Facilities Ordinance, implementing a mandatory licensing system under which unlicensed issuance is a criminal offense. At the same time, Hong Kong also has many detailed requirements for licensees in areas such as anti-fraud and anti-money laundering.
Chan Ho-lim pointed out that the current regulatory regime already imposes rigorous and effective risk management requirements on relevant licensed institutions. Under the Payment Systems and Stored Value Facilities Ordinance and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, unless a statutory exemption applies, it is illegal for anyone to issue or operate stored value payment facilities in Hong Kong without a license. Operating money exchange or cross-border remittance services also requires a license.
In addition, Chan Ho-lim also mentioned that at present, among all institutions providing buy now, pay later services, apart from banks, which are supervised by the Hong Kong Monetary Authority, other institutions providing buy now, pay later services must also apply for a money lender's license if their services involve lending business. The relevant lending transactions are subject to the Money Lenders Ordinance and licensing conditions.
For a long time, payment, as the foundation of financial and commercial operations, has been the underlying channel for various financial activities, and fund transfers and the implementation of credit products all need to rely on payment links. Wang Pengbo believes that in regulating payment business, Hong Kong regulators can refer to the mainland's approach. In the process of improving payment regulation, they can continue to follow the business boundaries of fintech business, clarify the regulatory connections among stored value payment facilities, buy now, pay later, and money lending business, keep rule updates aligned with the pace of market innovation, and at the same time strengthen compliance reminders for market participants, guiding them to identify the potential risks of unlicensed operations.