Who is swimming naked, and who is breaking the waves? Analysis Report on the Comprehensive Ranking of Hong Kong Licensed Virtual Asset Trading Platforms (VATP)

***Author: ** Senior Researcher Frank Lee, Hong Kong Virtual Asset Research Institute*

Introduction

As of the first quarter of 2026, the Hong Kong Securities and Futures Commission (SFC) has officially granted licenses to 12 virtual asset trading platforms (VATPs). Meanwhile, the transitional arrangement for early operations under the "deemed-to-be-licensed" status has gradually come to an end, with several platforms completing the SFC Phase II audit and being authorized for full operations.

However, the issuance of licenses is not completely over, as several platforms are still awaiting final approval. Although the era of licensing has begun, the real competition in Hong Kong's virtual asset industry is just starting. Established licensed platforms like HashKey and OSL are competing alongside traditional financial giants such as Bullish, Futu, Tiger Brokers, and Lianlian Digital, as well as new-generation forces represented by EX.IO. Who will ride the wave, and who will be left exposed in the regulatory tide? The answer remains to be seen by the market.

This report, based on this background, systematically evaluates the 12 licensed VATPs from the following five core dimensions, aiming to analyze the true competitiveness and differentiation paths of each platform beyond the licenses:

1. Trading volume and market share

2. Capital background and financial strength

3. Degree of business diversification

4. Compliance completeness and operational stage (including whether they have passed Phase II audit, whether they are authorized to serve retail customers, whether they have OTC capabilities, etc.)

5. Growth momentum and long-term potential

It is particularly noteworthy that there are significant differences among the platforms in terms of compliance: some platforms (such as EX.IO and Futu's Cheetah) have successfully passed the Phase II audit and can operate fully; some are still in the transitional phase; and there are also significant differentiations in terms of retail customer access, OTC service capabilities, and wealth management. These differences will become key variables determining the competitive landscape of the next stage for the platforms—the true competition in the industry has just begun. When established leaders like HashKey and OSL compete with giants like Bullish, Futu, Tiger, Lianlian Digital, and new-generation forces represented by EX.IO, who will be exposed, and who will ride the waves?

Against this backdrop, this report conducts a systematic evaluation of the 12 licensed VATPs based on trading volume, capital background, business diversification, compliance completeness, and growth momentum, attempting to identify the true competitiveness and differentiation paths of each platform beyond the licenses.

1. Core Conclusions

a) Market Tier Overview

• First Tier (Absolute Leaders): HashKey, OSL. They are far ahead in trading volume and business diversification.

• Second Tier (Strong Disruptors): EX.IO, PantherTrade, YAX, DFX Labs. They generally have strong backgrounds in traditional finance or payment giants, with EX.IO jumping to 3rd place in the market with a comprehensive score of 6.00, leading the new generation of platforms.

• Third Tier (Emerging Starters): Bullish HK (not yet operational), HKVAX, HKbitEX, BGE, Accumulus, VDX. Most are in the infrastructure and compliance framework implementation stage.

b) The market presents a "1+1+N" pattern—dual oligopoly solidified, fierce competition among new generations.

HashKey and OSL, with their first-mover advantage and complete business matrix, firmly occupy the first tier. Among the remaining 10 platforms, the ranking has already widened, and the competition is far from over.

c) Clear differentiation in the second tier; traffic ≠ trading volume, capital ≠ growth.

There are many platforms with large user pools or strong capital backgrounds, but whether they can effectively convert these resources into actual trading volume depends on product implementation capabilities, compliance progress, and differentiated strategies. The cold start efficiency among different platforms has shown significant differences. For example, EX.IO achieved over $1 billion in trading volume within 226 days of obtaining its license and quickly established a differentiated advantage through innovative businesses like RWA and OTC.

d) Compliance depth and product innovation are reshaping the rankings of the new generation.

Beyond basic trading services, the ability to obtain OTC licenses first, launch RWA and other tokenized products, and enter the institutional wealth management sector has become a key variable for new-generation platforms to achieve breakthroughs. The first-mover advantages in these dimensions are redefining the rankings of the second tier.

Note: Although Bullish was granted a Hong Kong license in February 2025, its local business has not yet commenced substantively and is only available to professional investors. Therefore, this report's scoring is strictly based on the actual business status in Hong Kong and does not include its global platform's trading volume and business data.

2. Comprehensive Ranking of 12 Licensed VATPs in Hong Kong

1. OSL Digital Securities (0863.HK) | Retail + PI | Staking/RWA/OTC/Wealth

2. HashKey Exchange (3887.HK) | Retail + PI | Staking/RWA/OTC/Wealth

3. HKVAX | PI Only | RWA/OTC/Custody

4. DFX Labs | Retail + PI | OTC/Trading

5. HKbitEX | PI Only (requires Phase II) | OTC/Trading

6. Accumulus | PI Only (requires Phase II) | RWA/OTC

7. EX.IO