Hong Kong government says existing laws cover new payment platforms after complaints
Hong Kong's government says existing regulations under the Payment and Settlement Systems Ordinance and other laws already govern new payment platforms, including buy-now-pay-later services. From January 2024 to September 2026, the Hong Kong Monetary Authority received 16 complaints about suspected
The Hong Kong government has said existing regulations already cover emerging payment platforms, after a lawmaker raised concerns about unlicensed operators and consumer losses. In a written reply to the Legislative Council on 7 October, the government said it and financial regulators continuously monitor the market, including new payment models, and take enforcement action under the statutory framework as needed.
According to the reply, which consulted the Hong Kong Monetary Authority (HKMA) and the Customs and Excise Department, the HKMA received 16 complaints about suspected unlicensed issuance or operation of stored-value payment tools between January 2024 and September 2026. One complaint was upheld after investigation, but the complainant reported no financial loss. The HKMA is following up with the company concerned and will take appropriate action depending on progress.
The government said the HKMA regulates stored-value payment tools under the Payment and Settlement Systems Ordinance to maintain the safety and sound development of local retail payment systems. Under the ordinance, anyone who issues or operates stored-value payment instruments in Hong Kong without a licence is breaking the law, unless a statutory exemption applies.
Separately, under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, anyone providing money-changing or cross-border remittance services must obtain a licence from the Customs and Excise Department, unless exempt. This means payment platforms involved in such services are also subject to the money service operator licensing regime.
The government noted that all institutions offering buy-now-pay-later services – except banks, which are regulated by the HKMA – must obtain a money-lending licence under the Money Lending Ordinance if they are engaged in lending. The existing regime imposes strict risk-management requirements on licensees, including due diligence, record-keeping and proper handling of client funds.
When unlicensed operations or breaches are suspected, the HKMA intervenes directly and may cooperate with other regulators or refer cases to law enforcement. The Customs and Excise Department also takes enforcement action against violations of the licensing regime. The government said it will continue to enhance cross-agency cooperation and intelligence sharing to identify, investigate and combat illegal financial activities, and will keep monitoring market trends, complaints and emerging payment models.