Why did HashKey become the "first Hong Kong-listed cryptocurrency company"?

I. Introduction

On December 1, 2025, a major news story broke: According to the Hong Kong Stock Exchange (HKEX), HashKey, as one of the first batch of licensed virtual asset service providers (VATP) in Hong Kong, officially passed the HKEX's listing hearing.

As early as one or two months ago, there were internal rumors in the market that HashKey was preparing for an IPO. On December 1, HashKey passed the hearing and released the "Post-Hearing Information Set." Many mainland readers will 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 architecture, complex compliance system, financial status, and corporate governance structure. This essentially recognizes HashKey's entry into the mainstream capital market, and it is only one step away from listing.

HashKey's Post Hearing Information Pack (PHIP), published on the Hong Kong Stock Exchange's disclosure platform, closely resembles a traditional prospectus in content and information density, except for some sensitive information that is withheld. The PHIP contains key financial data, equity structure, and management information, making it a crucial document for understanding why HashKey is poised to become Hong Kong's first cryptocurrency stock. Today, Crypto Shalu will provide a detailed legal analysis of this "quasi-prospectus," hoping to offer valuable insights.

II. Compliance Architecture Analysis

1. Regulatory Recognition Across Multiple Jurisdictions

HashKey's core narrative lies in its globally constructed cross-jurisdictional compliance framework. Crypto Lawyers has previously stated that compliance is a relative concept; within a specific jurisdiction, continuous compliance with local regulations constitutes compliance. Digital assets are fluid, and a single Hong Kong license is clearly insufficient, especially given Hong Kong's strict controls on exchange liquidity. While recent easing allows exchanges to connect with overseas liquidity, strict restrictions remain on overseas countries and exchange qualifications. See Crypto Lawyers' article: "Web3 Lawyer's In-Depth Policy Interpretation | New Regulations for Hong Kong Virtual Asset Trading Platforms (Part 1): Circular Regarding the Sharing of Liquidity by Virtual Asset Trading Platforms."

Therefore, most platforms' compliance issues stem from the fact that they are required to provide services globally, yet only register a company and apply for a license in a single region.

To address this, HashKey's solution is to establish entities and hold local licenses in various financial centers globally to comply with local regulatory requirements. PHIP data shows that HashKey's business footprint covers major financial centers in Asia and globally, including Hong Kong, Singapore, Japan, Bermuda, the UAE, and Ireland, where it has obtained licenses. This is based on extremely high legal operating costs and governance capabilities, expanding its legal matrix globally, rather than simply "collecting" licenses in various locations.

2. Technology and Internal Control Compliance First

PHIP data shows that HashKey's arrangements for asset custody and platform operation are largely consistent with Hong Kong's regulatory system.