Author | Guo Fangxin, Li Xiaobei
Introduction
On December 1, 2025, a major news broke: according to the Hong Kong Stock Exchange disclosure, HashKey, as one of the first licensed virtual asset service providers (VATP) in Hong Kong, officially passed the HKEX listing hearing.
As early as one or two months prior, market rumors about HashKey preparing to go public had circulated internally. On December 1, HashKey passed the hearing and released the “Post-Hearing Information Pack.” Many mainland readers might wonder: what stage is HashKey’s listing at?
From a legal perspective, the HKEX conducted a comprehensive due diligence and review of HashKey’s basic information, including its underlying business structure, complex compliance systems, financial status, and corporate governance. Essentially, this recognizes HashKey’s entry into the mainstream capital market, with only one step remaining before listing.
The “Post-Hearing Information Pack” (PHIP) published on the HKEX Disclosure Platform, aside from some sensitive information not disclosed, is highly similar in content and information density to the traditional “Prospectus” familiar to mainland readers.
In the PHIP, we can see key financial data, equity and management structures, and other core information about HashKey, which are crucial for understanding why HashKey is expected to become the “Hong Kong’s First Crypto Stock.”
Today, Crypto Salad will provide a detailed legal perspective analysis of this “quasi-Prospectus,” aiming to offer valuable insights.
Compliance Structure Analysis
1. Regulatory Recognition Across Multiple Jurisdictions
HashKey’s core narrative lies in its compliance framework built across global jurisdictions. Crypto Salad has previously stated that compliance is a relative concept; within a specific jurisdiction, as long as business operations continuously meet local regulatory requirements, it is considered compliant. Digital assets are fluid, and having only one license in Hong Kong is clearly insufficient. Moreover, Hong Kong’s strict regulation of exchange liquidity has recently loosened slightly, allowing exchanges to connect with overseas liquidity. However, there are still strict restrictions on overseas countries and exchange qualifications. For details, see Crypto Salad: “Deep Policy Interpretation by Web3 Lawyers | Hong Kong Virtual Asset Trading Platform New Regulations (Part 1): Circular on Shared Liquidity for Virtual Asset Trading Platforms.”
Therefore, most platforms’ compliance issues stem from the fact that they must serve a global market but only register companies and apply for licenses in certain regions. HashKey’s solution is to establish entities in major financial centers worldwide and hold local licenses to meet regulatory requirements. PHIP shows that HashKey’s business footprint covers major financial centers in Asia and globally, including Hong Kong, Singapore, Japan, Bermuda, UAE, and Ireland, with licenses obtained in each location. This approach is based on high legal operational costs and governance capabilities, expanding the legal matrix globally rather than simply collecting licenses in various places.
2. Prioritizing Technical and Internal Control Compliance
PHIP indicates that HashKey’s arrangements for asset custody and platform operation are generally consistent with Hong Kong’s regulatory system.
The document shows that HashKey has strict measures for client asset management, including repeated emphasis that client asset custody structures are completely segregated from the company’s own assets, forming an independent system; client digital assets are mainly stored in cold wallets. As of September 30, 2025, 96.9% of platform assets were stored in cold wallets; other common compliance measures include multi-signature approval processes and holding client fiat assets in independent trust accounts.
Additionally, unlike other licensed exchanges in Hong Kong, HashKey Group has built a “regulatory-friendly” Ethereum Layer 2 scaling network—HashKey Chain. Its positioning is not aimed at retail users or general decentralized applications but is infrastructure specifically designed to provide compliant services for institutions. 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 during the protocol design phase, meaning that issuance, transfer, and settlement on this chain must follow preset rules. The transparency, auditability, and transparency valued by the Hong Kong government are directly supported by the underlying infrastructure.
This allows enterprises to avoid building complex systems from scratch, and HashKey Chain can meet regulatory requirements without the enterprise bearing the costs of technical compliance development, accelerating the adoption of compliant digital assets in the traditional financial industry.
3. Disclosure of Governance Structure
The complete disclosure of HashKey’s corporate governance structure in PHIP is a section rarely covered in other documents.
Firstly, in terms of corporate form, HashKey Holdings is an exempted company registered in the Cayman Islands. The document explicitly lists the applicable “Cayman Companies Law,” “Hong Kong Companies Ordinance,” and “Corporate Governance Code,” which determines that its overall governance standards are aligned with HKEX’s listing requirements, and it has built its governance structure accordingly.
For example, 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 entirely composed of independent directors. This is a standard structure for listed companies but is uncommon among Web3 companies. HashKey’s ability to reach this stage is largely due to its governance structure, which, while not eye-catching, is legally significant.
Significance
The discussion around HashKey’s listing is particularly notable due to its unique legal identity. Crypto Salad has observed that the market often compares 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 listing, whereas HashKey is the first company to attempt to enter the traditional capital market with a VATP license as its core business. This gives HashKey clear regulatory and industry signaling significance.
In Crypto Salad’s view, HashKey’s progress in Hong Kong is mainly driven by strong external forces and clear internal development demands.
The Hong Kong government is currently in a window period for crypto policy. We believe Hong Kong is undoubtedly China’s pilot bridgehead for virtual assets. The government may also need a successful compliant case to showcase its achievements. As a benchmark for Hong Kong VATP, HashKey’s successful listing essentially signals: Web3 and compliance are not mutually exclusive; they can be integrated through institutional frameworks.
Of course, from a business perspective, compliance is crucial, but it also entails significant costs. Under multiple regulatory frameworks, fulfilling legal obligations—including ongoing risk control, AML/KYC, cybersecurity, technical security, and audits—requires continuous funding. PHIP’s risk factors section explicitly states that the platform may face regulatory reviews, investigations, and enforcement procedures during operation, which could involve substantial time and “huge legal and compliance costs.” HashKey must continuously bear these obligations, not just make a one-time investment.
Moreover, being listed to gain institutional trust and global reputation is far more attractive to traditional financial institutions seeking stable and secure partners than a private exchange.
