Payment service operations licensed by the HKMA should take note of the anti-money laundering and counter-terrorist financing laws which cover their customer due diligence obligations.
Payment services involve the collection of market and personal data, which will be subject to the local data privacy law as data users. The relevant legislation is the Personal Data (Privacy) Ordinance ('PDPO'). Payment service providers shall also comply with the non-binding code of practices and guidelines issued by the Office of the Privacy Commissioner for Personal Data ('PCPD') from time to time to ensure that personal data are collected, used, processed, and stored properly.
Economic conditions
Market size for payment services and biggest payment service providers
Electronic payments are regularly and widely used. The notable example is the Octopus card, which is a local card-based payment method similar to the Oyster Card in the UK and Suica in Japan. Originally, the Octopus card was only applicable to in-person payments on transportation and retail payments. Now it has expanded its application to online payments. According to the Transport Department, there are more than 36 million Octopus cards are in circulation, and the number of daily transaction is over 15 million. Approximately 95% of people in Hong Kong within the ages of 15 and 64 have an Octopus card.
According to the HKMA, the number of FPS registrations grew from over 2 million at the end of 2018 to 16.45 million as of March 2025, up by 16% year on year. The average number of Hong Kong dollar real-time transactions per day reached 1.98 million, worth of HKD $15.7 billion in March 2025. .
Additional comments regarding the economic situation for payment services or what FinTech’s must be aware of in this business area
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