Author | Guo Fangxin, Li Xiaobei
Introduction
On December 1, 2025, a major piece of news broke: According to a disclosure from the Hong Kong Stock Exchange (HKEX), HashKey, as one of the first batch of licensed Virtual Asset Service Providers (VASPs) in Hong Kong, officially passed the HKEX's listing hearing.
As early as one or two months ago, the market had been abuzz with internal news about HashKey's preparation for listing. On December 1, HashKey passed the hearing and released the 'Post Hearing Information Pack' (PHIP). Many readers in Mainland China might wonder: What stage has HashKey's listing reached?
From a legal perspective, the HKEX conducted comprehensive due diligence and review of HashKey's basic information, including its underlying business structure, complex compliance system, financial status, and corporate governance structure, essentially endorsing HashKey's entry into the mainstream capital market. It is now just one step away from listing.
The 'Post Hearing Information Pack' (PHIP) released by HashKey on the HKEX's disclosure website, aside from withholding some sensitive information, is highly similar in content and information density to the traditional 'Prospectus' more familiar to Mainland readers.
Within the PHIP, we can see HashKey's key financial data, equity and management structure, and other core information. It is an important document for understanding why HashKey has the potential to become the 'First Crypto Stock in Hong Kong'.
Today, Crypto Salad will provide a detailed legal interpretation of this 'quasi-prospectus', hoping to offer valuable insights.
Compliance Structure Analysis
1. Regulatory Recognition Across Multiple Jurisdictions
HashKey's core narrative lies in its globally constructed cross-jurisdictional compliance framework. As Crypto Salad has mentioned before, so-called compliance is a relative concept. Within a specific jurisdiction, continuous operation of a business in accordance with local regulatory requirements constitutes compliance. However, digital assets are fluid; holding just a Hong Kong license is clearly insufficient. Moreover, Hong Kong has strict regulations on exchange liquidity. Although it recently relaxed some restrictions, allowing exchanges to connect with overseas liquidity, there are still strict limitations regarding foreign countries and exchange qualifications. For details, see Crypto Salad: 'Web3 Lawyer's In-Depth Policy Interpretation | Hong Kong's New Regulations for Virtual Asset Trading Platforms (Part 1): Circular on Virtual Asset Trading Platform Shared Liquidity'.
Therefore, the compliance issues for most platforms stem from the fact that they must provide services globally yet are only registered and licensed in a single region. To address this, HashKey's solution is to establish entities and obtain local licenses in various financial centers around the world to meet the regulatory requirements of different regions. 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 licenses' in a 'stamp collection' manner.
2. Technology and Internal Control Compliance First
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 for client asset management, including repeatedly emphasizing that the client asset custody structure is completely isolated from the company's own assets, belonging to an independent system; client digital assets are primarily stored in cold wallets—as of September 30, 2025, 96.9% of platform assets were held in cold wallets; other common compliance measures include using multi-signature approval processes, holding client fiat assets in independent trust accounts, etc.
Furthermore, unlike other licensed exchanges in Hong Kong, the HashKey Group has built a 'regulation-friendly' Ethereum Layer2 scaling network—HashKey Chain. Its positioning is not as a public chain for retail users or general decentralized applications, but rather as infrastructure specifically providing compliant 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 reveals that HashKey Chain considered compliance at the protocol design stage. This means that issuance, transfer, and settlement on this chain must follow pre-set rules. The auditability, and transparency valued by the Hong Kong government are directly supported by the underlying infrastructure.
In this way, enterprises do not need to build complex systems from scratch, and HashKey Chain can assume the regulatory requirements, relieving enterprises of the development costs associated with technical compliance and accelerating the adoption of compliant digital assets across the traditional financial industry.
3. Disclosure of Governance Structure
The complete disclosure of HashKey's corporate governance structure in the PHIP is a section less frequently mentioned in other documents.
First, in terms of corporate form, HashKey Holdings is an exempted company limited by shares incorporated in the Cayman Islands. The document lists the applicable Cayman Islands Companies Law, Hong Kong Companies Ordinance, and Corporate Governance Code right at the beginning. This determines that its overall standard must align with that required by the HKEX for listed companies, and it has already established its governance structure entirely according to this standard.
For example, the PHIP discloses that the post-listing board of directors will consist of 1 executive director, 1 non-executive director, and 3 independent directors, with the audit committee composed entirely of independent directors. This is a standard structure among listed companies but is not common among Web3 companies. HashKey's ability to reach this stage, while the governance structure may seem inconspicuous, is, from a legal perspective, crucial.
Significance
The discussion surrounding HashKey's listing is special partly due to the uniqueness of its legal identity. Crypto Salad notes that people in the market often compare HashKey with OSL, debating who is the 'First Crypto Stock in Hong Kong'. From a legal perspective, OSL did not hold a VATP license at the time of its listing, whereas HashKey is indeed the first company attempting to enter the traditional capital market with a VATP-licensed business entity, thus carrying clear regulatory and industry signaling significance.
In Crypto Salad's view, HashKey's ability to this point in Hong Kong stems mainly from strong external momentum and clear internal development demands.
The Hong Kong government is currently in a window period for crypto policy. We believe that Hong Kong is undoubtedly China's pilot bridgehead for virtual assets. The Hong Kong government might also need a successful compliance case to showcase its construction achievements externally. If HashKey, as a benchmark for Hong Kong VASPs, can successfully list, it essentially conveys that Web3 and compliance are not conflicting and can be achieved through institutionalization.
Of course, from a business perspective, compliance is important, but the cost of compliance is also enormous. Undertaking legal obligations under multiple national regulatory frameworks, including ongoing risk control, AML/KYC, network, technical security, and audit costs, requires a continuous flow of financial support. The risk factors section of the PHIP clearly states that the platform may face regulatory reviews, investigations, and enforcement procedures during its operations, which could require significant time investment and 'substantial legal and compliance costs.' HashKey needs to continuously bear these obligations; it is not a one-time investment.
Furthermore, 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—a listed company is much more appealing than a private exchange.
