Hong Kong Investment Migration Now Accepts Bitcoin and Ethereum as Asset Proof: Insider Details and Challenges

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Hong Kong’s revamped Capital Investment Entrant Scheme (CIES) has made headlines by officially accepting major cryptocurrencies like Bitcoin (BTC) and Ethereum (ETH) as valid forms of asset proof. This groundbreaking shift opens new pathways for high-net-worth individuals, especially those from mainland China, to qualify for residency through digital assets. In this article, we dive into the first-hand experience of萧耀和 (Simon Siu), Deputy Managing Partner at Hong Yuan Certified Public Accountants, who successfully guided clients through this pioneering process.

From eligibility criteria and application steps to hidden challenges like fund sourcing and compliance, we break down everything you need to know—plus frequently asked questions to help you navigate the journey with confidence.

First-Hand Case: ETH and BTC Accepted for Hong Kong Investment Migration

In February 2025, a client successfully submitted a Hong Kong investment migration application using 30 million HKD worth of Ethereum (ETH) as asset proof—an approval that marks only the second such case in the territory’s history. The first, approved in October 2024, used Bitcoin (BTC) as the qualifying asset. Both applicants were from mainland China and passed the initial verification stage under the CIES.

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Simon Siu, whose firm has over 25 years of auditing and financial advisory experience, confirmed that these cases set important precedents. While crypto is not yet formally listed in official guidelines, its acceptance reflects Hong Kong’s growing openness to blockchain innovation and digital wealth.

Understanding the Two-Step Investment Migration Process

Step 1: Prove You Own 30 Million HKD in Eligible Assets

The first hurdle is demonstrating ownership of at least 30 million HKD in qualifying assets. These can include:

Notably, the assets don’t need to be located in Hong Kong—what matters is verifiable ownership. For crypto holders, this means providing wallet addresses, transaction histories, exchange statements, or cold storage proofs. Both hot wallets (e.g., Binance) and cold wallets are acceptable, as long as they can be independently verified by an accountant or auditor.

Step 2: Invest the Funds in Hong Kong Within Six Months

After asset verification, applicants must transfer and invest 30 million HKD into designated financial instruments in Hong Kong within six months. These include:

Direct investment into cryptocurrencies—even locally listed BTC or ETH ETFs—is not automatically permitted. However, there may be indirect routes via a Limited Partnership Fund (LPF) structure.

Can You Invest in Crypto ETFs Through the Migration Program?

While the program prioritizes traditional financial markets, some flexibility exists. One potential workaround is setting up a 100%-owned Limited Partnership Fund (LPF) in Hong Kong. Once established, this fund can theoretically allocate capital to a broader range of assets—including locally issued Bitcoin or Ethereum ETFs—provided they are registered with the Investment Promotion Office and come with auditable proof of ownership.

However, this approach remains untested at scale. For example, if a bank like HSBC offers a crypto ETF and provides a formal investment certificate, it may satisfy regulatory requirements. But without explicit policy clarification, applicants should proceed cautiously and consult professional advisors.

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Visa Timeline and Renewal Requirements

Contrary to popular belief, approval of asset proof does not immediately grant a visa. Only after completing the required investment does the applicant receive a two-year residency visa.

To renew:

Importantly, investment losses do not disqualify renewal, as long as the structure remains intact and compliant.

Which Cryptocurrencies Are Accepted? BTC and ETH Lead the Way

Currently, only Bitcoin and Ethereum have been successfully used in approved cases. There is no official list of accepted cryptocurrencies from the Hong Kong government—meaning recognition is still evolving on a case-by-case basis.

That said, Simon Siu suggests two key factors determine whether a crypto asset may be accepted:

  1. Market liquidity – High trading volume and price stability
  2. Transparent valuation – Reliable pricing data from major exchanges or indices

While stablecoins like USDT could theoretically qualify due to their pegged value, no known approvals have been granted yet. Altcoins or lesser-known tokens face even greater scrutiny due to volatility and traceability concerns.

The Biggest Challenge: Proving the Source of Funds (SOF)

Even if you hold millions in BTC or ETH, the real bottleneck lies in proving the origin of those assets—a requirement known as Source of Funds (SOF) verification. As one industry observer noted: “Coins are easy to show; cash trails are hard to prove.”

Common SOF hurdles include:

Blockchain’s anonymity features further complicate identity linking—while transactions are public, connecting wallet addresses to real-world identities requires robust evidence.

For example: A client who bought BTC for 1 million HKD in 2017 now holds 10 million HKD worth—but cannot produce original payment records. Without proof that the initial capital came from legal income (e.g., salary, business profits), the application fails.

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Best Practices for a Successful Application

To strengthen your chances:

Even informal documentation—like signed receipts or emails—can support your case when formal records are missing.

Frequently Asked Questions (FAQ)

Q1: Can I use any cryptocurrency for Hong Kong investment migration?

A: Currently, only Bitcoin and Ethereum have been successfully approved. Others like USDT or altcoins lack precedent and face higher rejection risks due to valuation and compliance concerns.

Q2: Do I need to sell my crypto to invest in Hong Kong markets?

A: Yes—after proving asset ownership with crypto, you must convert and invest 30 million HKD into approved local assets such as stocks or bonds within six months.

Q3: Is there an official policy allowing crypto as asset proof?

A: No formal rule exists yet. Acceptance is based on case-by-case evaluation, with recent approvals signaling growing openness—but not guaranteed future outcomes.

Q4: How important is the source of funds documentation?

A: It’s critical. Many applications fail not due to lack of assets, but inability to prove their legal origin—especially for early adopters with incomplete transaction histories.

Q5: Can I use a self-managed fund to invest in crypto ETFs?

A: Potentially—via a Hong Kong-based Limited Partnership Fund (LPF). If the ETF is regulated and provides verifiable ownership certificates, it may qualify under indirect investment rules.

Q6: Are mainland Chinese applicants eligible?

A: Yes—and in fact, all known crypto-based approvals so far have involved applicants from mainland China, indicating strong demand and feasibility for this group.

Final Thoughts: A New Era for Digital Wealth Mobility

Hong Kong’s quiet but significant acceptance of Bitcoin and Ethereum as asset proof marks a turning point for crypto holders worldwide. While challenges remain—especially around compliance and fund tracing—the door is now open for digital-native investors to access global residency through legitimate channels.

With careful planning, proper documentation, and expert guidance, blockchain wealth can become a bridge to new opportunities—not just financial growth, but also personal mobility and long-term security.