Intermediary licences for client-facing crypto sales and execution. SFC Type 1 Hong Kong, JFSA CAESP broker, KoFIU VASP broker, SEC Thailand Broker, Labuan Money-Broking. Lower-capital alternative to a full exchange in many cases.
An exchange operates a multilateral trading venue with a matching engine and a captive client base. A broker intermediates between a client and one or more counterparties or venues. The broker model carries lower capital in most APAC regimes, useful when the business case is execution and advisory rather than running an order book.
The numbers below are paid-up capital floors in the currency of each regime, together with a typical wall-clock time-to-grant once the applicant company and senior managers are in place. Actual capital charges scale up with risk profile under each regulator's net-capital rules.
| Regime | Licence | Paid-up capital | Typical timeline |
|---|---|---|---|
| Hong Kong | SFC Type 1 (dealing in securities) | HKD 5M + liquid capital >= 5% of adjusted liabilities | 9–12 months |
| Japan | JFSA CAESP broker sub-category | JPY 10M stated capital + JVCEA membership | 8–10 months |
| South Korea | FSC / KoFIU VASP broker | No statutory floor; ISMS-P and real-name banking when handling KRW | 6–9 months |
| Thailand | SEC DA Broker, with client assets | THB 25M | 7–10 months |
| SEC DA Broker, asset-keeping, no access | THB 5M | 6–9 months | |
| SEC DA Broker, non-asset-keeping | THB 1M | 5–8 months | |
| Labuan | Money-Broking (VC endorsement) | MYR 500,000 | 4–6 months |
| Indonesia | OJK PFAK trader/broker | IDR 100B paid-up (plus IDR 50B equity floor) | 8–12 months |
Across APAC the substantive supervisory checklist for a broker application is remarkably consistent, differences sit in thresholds and statutory wording rather than subject matter. Every regime tests the same six areas.
A realistic APAC broker licence runs in three phases. We compress the first to four to six weeks, but the middle and final phases are regulator-bound and cannot be shortened meaningfully.
Hong Kong is the APAC market where the security-token business case now drives more broker filings than pure spot crypto. The SFC's November 2023 joint circular with the HKMA confirmed that tokenised securities remain securities under the Securities and Futures Ordinance, regardless of the underlying DLT. A broker that intends to deal in tokenised equity, fund units or debt issuance therefore needs Type 1 (dealing in securities). Where the same firm advises clients on token portfolio construction, common for tokenised private-credit funds and RWA products. Type 4 (advising on securities) is paired with Type 1 in a single licence application. Firms that also run discretionary digital-asset portfolios stack Type 9 on top.
The practical effect on capital is meaningful. Type 1 without holding client assets requires HKD 5M paid-up and liquid capital floor of HKD 3M; holding client assets lifts the paid-up to HKD 10M. Each added regulated activity needs its own Responsible Officer approved under the SFC Licensing Handbook, typically two ROs per RA, with at least one in Hong Kong day-to-day. The Type 1 plus Type 4 stack suits APAC-facing tokenisation platforms targeting professional investors under the HKD 8M portfolio threshold; the VATP regime remains the correct route for non-security virtual-asset spot venues, and the two tracks coexist rather than substitute.
Best execution is the single conduct obligation where APAC regulators' wording diverges most, and it is the first area competitor due-diligence teams probe when onboarding a new broker. Getting the policy stack right before filing saves months in the conditional-approval phase.
All three regimes converge on one documentary requirement: a written venue-selection policy, a quantitative execution-quality review at least annually, and clean disclosure of any payment-for-order-flow or rebate arrangements. Australia's ASIC RG 265 and Thailand's SEC best-execution notification apply the same substance.
Paid-up capital is the headline number in every comparison table, but the regulator who supervises the broker day-to-day cares more about the ongoing ratio. A broker that opens with the statutory minimum and then trades into a thin-capital position will trigger escalation long before the paid-up figure is breached. The ratios and triggers below are what each regime monitors on a monthly cycle.
Plan for a 30–50% buffer above the statutory floor at launch, the cost of breaching is a supervisory letter, conditional licence restrictions and, in several cases, public disclosure on the regulator's register.
Broker if execution and advisory are the model; exchange if you operate the matching engine and hold client positions. The decision shapes capital, operating expense and supervisory burden.
In SEC Thailand the categories are split. Broker without access (THB 1M), Broker holding client assets (THB 25M). Other regimes bundle differently. Architecture choice drives the licence tier.
Australia's existing AFSL framework licenses brokers under RG 166 standard NTA tiers. The new ASIC DAP regime (commencing 9 April 2027) may add a dedicated DAP-broker authorisation, see Australia.
A broker acts as agent executing client orders into external venues; a dealer takes principal risk quoting two-way prices from its own book; an exchange runs a multilateral matching engine. Most APAC regimes. SEC Thailand, KoFIU and OJK Indonesia, issue these as distinct authorisations, so a firm doing both agency and principal business typically stacks two licences rather than relying on one.
Yes. Under the SFC's November 2023 joint circular with the HKMA, tokenised securities fall within the Securities and Futures Ordinance, so dealing in them requires a Type 1 licence regardless of the underlying chain. Pure non-security virtual assets sit under the separate VATP regime, see Hong Kong for the dual-track picture.
Under the Thai SEC's 2018 Digital Asset Business Emergency Decree the Broker category intermediates client orders into external venues, while the Dealer category quotes prices from its own inventory. Capital scales with whether client assets are held: THB 25M with full asset-keeping, THB 5M with asset-keeping but no access, THB 1M without any custody. Each tier has its own net-capital ratio and segregation requirements.
Under OJK Regulation 27/2024, which moved supervision from Bappebti to OJK on 10 January 2025. PFAK is the trader/broker authorisation with an IDR 100B paid-up floor, distinct from the exchange (Bursa) and clearing-house (Kliring) layers. PFAK firms route into the licensed exchange rather than matching internally.
HK SFC Code of Conduct paragraph 3.2 and Australia's RG 265 both require brokers to take reasonable steps to obtain the best available terms for the client, factoring in price, cost, speed and likelihood of execution. For crypto brokers aggregating across venues this means documented venue-selection policies, periodic execution-quality review and clear disclosure of any payment-for-order-flow arrangements.
Most APAC crypto regimes are silent on dark-pool mechanics because the licences assume agency routing to lit venues. SFC's ATS rules under Part III of the SFO would capture any broker running a non-displayed matching facility, pushing the firm into Type 7 (ATS) territory rather than plain Type 1. Thailand's SEC and Korea's FSC similarly treat internal matching as exchange activity requiring the higher-tier licence.
Retail vs professional-investor classification drives disclosure, suitability and marketing rules across HK, Singapore and Australia. HK Professional Investor thresholds (HKD 8M portfolio for individuals) unlock streamlined conduct treatment; Singapore's Accredited Investor regime and Australia's wholesale-client test operate similarly. Broker licences in each jurisdiction require written opt-in and annual reconfirmation of client status.
SFC Type 1 intermediaries follow the Securities and Futures (Financial Resources) Rules, minimum paid-up capital HKD 5M and liquid capital not less than 5% of adjusted liabilities. Thailand's SEC requires NCR of 7% of general liabilities plus risk charges. JFSA CAESP and KoFIU apply Basel-style solvency overlays. These ratios are monitored monthly and breach triggers immediate supervisory notification.
Reverse solicitation is narrow across APAC. Singapore's MAS, Hong Kong's SFC and Japan's FSA each require the client to have initiated contact without any prior marketing, advertising or inducement from the broker. Once a website, app or intermediary actively promotes services into the jurisdiction, the carve-out falls away and local licensing applies, the conservative default for any broker with APAC-facing traffic.
HK SFC paragraph 10.1 of the Code of Conduct caps non-monetary benefits and requires disclosure of any commission sharing or rebates from venues. Australia's conflicted-remuneration rules under the Corporations Act 2001 broadly ban volume-based payments for retail clients. Soft-dollar arrangements, research, data feeds, must be demonstrably for the client's benefit and pre-disclosed.
Hong Kong SFC leverage cap on virtual-asset retail trading is effectively 1:1, no margin permitted for retail investors. Japan's JVCEA self-regulatory cap sits at 2:1 on crypto derivatives. Thailand's SEC and Korea's FSC also prohibit retail leverage on spot crypto. Institutional and professional-investor clients may access higher leverage subject to written risk acknowledgement and broker margin-call controls.
Paid-up capital ranges from MYR 500,000 at Labuan and THB 1M in Thailand's non-asset-keeping tier, up to IDR 100B for Indonesia's PFAK and JPY 10M for Japan's CAESP broker. Professional and regulatory fees typically add USD 80,000–200,000 for Tier-1 regimes (HK, JP, KR, TH with custody) and USD 35,000–70,000 for Labuan. Year-two running cost, audit, compliance, local substance, tends to sit between USD 120,000 and USD 350,000 depending on headcount requirements.
Labuan is fastest at four to six months end-to-end. Thailand's non-asset-keeping Broker tier, Korea's KoFIU VASP broker and Japan's CAESP broker typically run six to ten months. Hong Kong SFC Type 1 and Indonesia's PFAK sit at nine to twelve months, with Indonesia particularly sensitive to the paid-up capital escrow and the Bursa / Kliring routing arrangements that must be in place before OJK grants.
Yes, if the broker advises clients on which tokenised securities to buy, hold or sell, the SFC treats that as advising on securities and requires Type 4 in addition to Type 1. Dealing-only brokers who simply route orders into execution venues can file Type 1 alone. Firms running discretionary tokenised portfolios also need Type 9 (asset management). Each regulated activity attracts its own Responsible Officer approval and its own liquid-capital add-on under the SFC Financial Resources Rules.
Substance is similar but scope differs. MAS Notice SFA 04-N16 and the Guidelines on Execution of Customer Orders apply to capital-markets intermediaries and Payment Services Act licensees handling digital payment tokens, requiring a board-approved execution policy and annual effectiveness review. SFC paragraph 3.2 is more prescriptive on the six execution factors (price, cost, speed, likelihood of execution, settlement, size, nature) and is paired with paragraph 10.1 disclosure of venue rebates. A broker licensed in both centres typically writes a single policy that satisfies the stricter SFC wording and flags MAS-specific client-classification overlays.
Not quite. A broker acts as agent routing client orders; a dealer takes principal risk from its own book. US FINRA-regulated broker-dealers hold both authorisations in one entity, while most APAC regimes keep them separate. Thailand's SEC issues DA Broker and DA Dealer as distinct licences, Hong Kong's SFC Type 1 covers dealing in securities (agent or principal) but crypto spot principal trading typically sits under the VATP regime, and Korea's KoFIU framework does not presently carve out a dedicated dealer tier.
A 30-minute scoping call with the country lead. Map your model to the right broker tier in the right regime.
