CRP-1 Arrives: A Comprehensive Analysis of Hong Kong's New Crypto Asset Regulations, Reshaping the Crypto Landscape

Let’s take a closer look at the new requirements of CRP-1, compare them with regulatory policies in other countries and regions, and then discuss what impact these changes will have on crypto players like us.

Driven by the wave of technological innovation, the global crypto asset market has expanded rapidly. At the same time, a series of risk issues such as sharp price fluctuations and money laundering have emerged, making effective regulation increasingly urgent. In September 2025, the Hong Kong Monetary Authority (HKMA) issued a consultation draft of the new module CRP-1 "Crypto Asset Classification" in the "Supervisory Policy Manual" (SPM) to the local banking industry. The aim is to align with international regulatory standards by establishing a regulatory system that balances innovative development and risk prevention, providing clear guidance for the banking sector’s participation in crypto asset-related businesses.

Next, the Sa Jie team will take you through the new requirements of CRP-1, compare them with the regulatory policies of other countries and regions, and discuss what impact these changes will have on crypto players like us.

01 Key Content Interpretation of Hong Kong CRP-1 New Regulation

(1) Basic Definition: Regulatory Scope and Applicable Entities

The new CRP-1 regulation first sets a clear scope for crypto asset regulation, laying a solid foundation for subsequent implementation. Specifically, the new regulation defines crypto assets as: those that mainly rely on cryptography and distributed ledger technology (DLT) or similar technologies; can be used for payment or investment purposes, or to obtain goods or services. However, it explicitly states that central bank-issued digital currencies are not included in this scope. This not only precisely defines crypto assets but also distinguishes them from legal digital currencies, preventing overregulation.

In terms of regulatory targets, the new regulation covers all licensed financial institutions in Hong Kong, such as licensed banks, restricted license banks, and deposit-taking companies. These institutions are important components of Hong Kong’s financial system, and their crypto-related activities directly affect financial stability. Including them in the regulatory framework allows risk control at the source.

Regarding risk control, the new regulation adopts a "no one left behind" strategy. Whether it’s crypto assets held by banks themselves, risks arising from custody or trading of crypto assets for clients, or risks from indirect exposure through financial derivatives, all must be managed. This way, financial institutions cannot exploit loopholes to evade regulation, and all crypto asset-related risks are strictly managed.

(2) Core Classification

Risk grading is the core logic of the CRP-1 new regulation. The regulation divides crypto assets into Group 1 (low risk) and Group 2 (high risk) based on their risk mitigation capabilities. Through the table below, you can clearly see its core classification at a glance.

02 Connection and Differences between CRP-1 and International Rules (BCBS Standards)

(1) Core Logic of BCBS Standards

The Basel Committee on Banking Supervision (BCBS), as the core institution for global banking regulation, issued the "Prudential Treatment of Cryptoasset Exposures" in December 2022 and released the "Cryptoasset Standards Revision" in July 2024, establishing a globally unified regulatory framework for crypto assets. Its core logic can be summarized as "risk grading and prudent management."

In terms of regulatory objectives, the BCBS standard focuses on "controlling crypto asset risks and ensuring adequate bank capital" to prevent crypto asset risks from spreading to the traditional banking system and to maintain global financial stability. In its core framework, BCBS divides crypto assets into "Group 1" and "Group 2" based on risk, sets strict capital requirements for high-risk assets, and promotes global regulatory coordination to prevent regulatory arbitrage.

The introduction of BCBS standards stems from the rapid development and risk accumulation in the global crypto asset market. Its purpose is to provide a unified regulatory benchmark for internationally active banks, balancing "financial stability" and "responsible innovation," and offering a reference framework for regulators in various countries.

(2) Connection between CRP-1 and BCBS

The new CRP-1 regulation and BCBS standards share similar ideas in many key areas, demonstrating Hong Kong’s commitment as an international financial center to keeping pace with global regulatory trends.

In terms of asset classification, CRP-1 divides crypto assets into "Group 1" and "Group 2," while BCBS uses "Group 1" and "Group 2." The core standard for classification in both is the asset’s risk control capability. For example, compliant stablecoins, which are relatively low-risk and reliable, are classified as "Group 1" in BCBS and correspond to "Group 1" in CRP-1. Both require such assets to have clear legal provisions and robust risk controls. For high-risk assets, both impose strict requirements on the amount of capital financial institutions must prepare to control risk, fully reflecting the principle of "the greater the risk, the stricter the regulation."

Regarding capital requirements, CRP-1 basically continues the prudent management approach of BCBS. BCBS stipulates that for certain high-risk crypto assets, financial institutions need to prepare capital equivalent to 1250% of the asset value to cover risks. CRP-1 applies the same standard to "Group 2b" assets. For highly liquid crypto assets, BCBS requires trading on compliant exchanges and a certain market size. CRP-1’s requirements for "Group 2a" assets are similar, mandating trading on regulated exchanges and setting thresholds for market capitalization and trading volume to ensure that invested capital matches asset risk.

In addition, both CRP-1 and BCBS emphasize comprehensive regulation. Whether it’s crypto assets held by banks themselves, assets involved in services provided to clients, or even indirectly related risks, all must be included in the regulatory scope to avoid "grey areas" and achieve the goal of unified global regulation.

03 Specific Impact of CRP-1 New Regulation on Crypto Asset Users

After the implementation of the CRP-1 new regulation, banks will make major adjustments to their crypto businesses, directly affecting how users buy, store, and use crypto assets.

First, regarding trading options, the new regulation "tightens" both the assets and channels available for trading. High-risk Group 2b assets, such as certain NFTs and governance tokens, can no longer be traded by banks and must be traded on other platforms, which may not be as reliable. While Group 1 compliant assets are safer, the range of available options is reduced. Group 2a assets must be traded on licensed exchanges, with stricter account opening reviews and higher thresholds. As for asset security, the new regulation does make asset custody safer, ensuring priority recovery of funds even if a platform fails. However, anti-money laundering requirements are very strict, reducing personal privacy, and price volatility varies among different assets.

For friends holding Group 2b NFTs or governance tokens, the Sa Jie team recommends prioritizing platforms regulated by the HKMA or those with international compliance qualifications, and not putting all assets in one place. Users who prefer Group 1 compliant assets can benefit from bank-level security but must accept fewer available options. For those trading Group 2a assets, be prepared with full documentation such as ID cards and bank cards to meet the strict review requirements of exchanges. Regardless of the type of asset you hold, you need to re-plan your investment portfolio and pay attention to changes in bank fees, enjoying the security brought by the new regulation while balancing privacy protection and operational convenience.

Final Thoughts

In summary, the Hong Kong CRP-1 new regulation demonstrates significant foresight in the field of crypto asset regulation, providing new ideas and directions for industry development and risk prevention.

Sa Jie believes that Hong Kong’s crypto asset regulation will enter a stage of dynamic optimization and deepening practice. In the future, regulators need to keep up with international trends and strengthen cross-border regulatory coordination; industry participants should establish regular compliance communication mechanisms. It is expected that Hong Kong will use CRP-1 as an opportunity to improve regulatory technology, balance investor protection and innovation, and set a global regulatory benchmark.