Country _ Name
Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).


API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:

The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.


Attitude of the country towards online-banking services

Hong Kong has a supportive climate for online banking services. There have been many initiatives to transform Hong Kong into a more sophisticated city in terms of online banking. These include the linkage of digital retail payments through the Faster Payment System; facilitating the introduction of virtual banking in Hong Kong; and introducing a new “Banking Made Easy”-initiative to reduce regulatory frictions and improve customer experience.

In response to the market's demand for virtual banks, HKMA has introduced the regimes for granting of the virtual banking licences in 2018. The first round of virtual banks was launched in 2019 and currently eight virtual banks have been licensed.

Legal affairs

Obligations and requirements to provide online-banking services described above

The HKMA has published a supervisory policy manual on risk management of E-banking. The requirements, such as risk management framework, risk governance, customer security, system, and network security, apply to online banking services.

In respect of virtual banks specifically, the HKMA published a guideline on 30 May 2018, setting out the principles which the HKMA will consider when deciding whether to authorize virtual banks. Further information on the relevant licensing requirements can be accessed at the website:

Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area


Economic conditions

Market size for online-banking services and biggest companies in this business area

According to the research conducted by McKinsey in December 2021, which polled more than 1,000 respondents in Hong Kong and about 20,000 across the region, 93 percent of Hong Kong consumers use digital banking at least once per month.

Within two years from the launch of virtual banks in Hong Kong, by the end of 2021, there were more than 1.2 million accounts opened with virtual banks. 

Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area




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