Why is HashKey embarking on its IPO journey at this time?

Deng Tong, Jinse Finance

According to a disclosure by the Hong Kong Stock Exchange on December 1, HashKey Holdings Limited has passed the Hong Kong Stock Exchange's listing hearing and is about to IPO. JPMorgan Chase, Guotai Haitong Securities, and Guotai Junan International are the joint sponsors.

HashKey's IPO journey is not sudden. As early as October 10 this year, there were reports that HashKey was seeking an IPO in Hong Kong to raise no more than US$500 million.

I. HashKey's Current Business Overview

1. Exchange Products.

HashKey is expanding into derivatives and perpetual contracts, targeting institutional and professional traders employing more sophisticated trading strategies such as hedging and leverage, similar to how trading firms and funds design complex stock and options products. These transactions typically incur higher commission rates compared to spot trading. Licensed Exchange Business: HashKey Pro is a platform licensed by the Hong Kong Securities and Futures Commission and was among the first virtual asset trading platforms to serve both professional and retail investors. As of September 30, 2025, the platform supported trading in 80 digital asset tokens, including USDT and BTC, facilitating a cumulative spot trading volume of HK$1.3 trillion; its Bermuda platform also supports trading in 72 categories of digital assets. Over-the-Counter (OTC): Designed to complement exchange services, OTC trading is specifically tailored for large-scale or customized trading. Compared to order book trading, this service offers greater flexibility and confidentiality, has less market impact, and integrates with custody services to achieve efficient settlement and reduce risk. Revenue is primarily generated through trading spreads.

2. On-chain Services. Due to regulatory liberalization allowing the tokenization of a wider range of financial products, including money market funds, debt instruments, structured products, stocks, and other real-world assets, the tokenization market will expand significantly.

• Staking Services: HashQuark, a subsidiary, is a leading blockchain infrastructure provider in Asia, offering enterprise-grade staking services for multiple PoS public chains such as Ethereum 2.0 and Polkadot. As of September 30, 2025, HashKey's on-chain staked assets reached HK$29 billion, making it the largest staking service provider in Asia and the eighth largest globally.

Blockchain Infrastructure Development: HashKey has developed the Ethereum Layer 2 network HashKey Chain. This network serves as a scalable and interoperable infrastructure, supporting the tokenization of real-world assets. As of September 30, 2025, the total value of real-world assets on the chain reached HK$1.7 billion, contributing to the implementation of blockchain technology and the migration of assets on the chain. 3. Asset Management Services: HashKey is launching a fund with a specific strategy related to the digital asset vault market. Currently, it is raising funds for the digital asset vault strategy fund, targeting a size of US$300 million to US$500 million. Given a gross profit margin exceeding 95% during the track record period, the launch of new products for HashKey's asset management division is expected to improve profitability. 4. Stablecoins: The Stablecoin Ordinance, which came into effect on August 1, 2025, provides a comprehensive regulatory framework for stablecoin issuers, distributors, and other intermediaries in Hong Kong. To promote the application of stablecoins in cross-border commerce, HashKey is actively communicating with various cross-border payment companies to build the compliant technology stack required to support stablecoin-based cross-border payments. HashKey has already made a strategic investment in RD InnoTech Limited. (RD InnoTech Limited, also known as Yuanbi Innovation Technology Co., Ltd., is a fintech company focusing on stablecoin business. Its core business revolves around the research and application of Hong Kong dollar stablecoins, and it is a key participant in the process of stablecoin compliance in Hong Kong.) II. Why is HashKey embarking on its IPO journey at this time? 1. Support from Hong Kong's Policy Dividends Since 2022, Hong Kong has clearly proposed the strategic goal of building an international virtual asset center. From the promulgation of the "Regulations on the Supervision of Virtual Asset Trading Platforms" to the formal implementation of the "Stablecoin Ordinance" in 2025, a complete framework of "appropriate regulation and controllable risk" has been gradually built, clearing away obstacles for the compliant development of crypto companies. In October 2022, the Hong Kong Special Administrative Region Government issued the "Policy Declaration on the Development of Virtual Assets in Hong Kong," formally demonstrating its determination to develop the virtual asset industry. In June 2023, the Hong Kong Securities and Futures Commission (SFC) officially implemented the "Guidelines Applicable to Virtual Asset Trading Platform Operators," requiring all central virtual asset trading platforms operating in Hong Kong to apply for a license from the SFC starting June 1. In August 2023, the first batch of licensed virtual asset trading platforms (such as HashKey Exchange) were officially approved to provide services to retail investors, marking the entry of Hong Kong's virtual asset retail trading into a compliant era. In early 2024, the Hong Kong SFC successively approved the listing of several virtual asset spot ETFs (including Bitcoin and Ethereum). From the end of 2024 to the beginning of 2025, the Hong Kong government and regulatory agencies conducted consultations on the regulatory system for stablecoin issuers and completed legislative preparations; in June 2025, the Hong Kong SAR government issued the "Hong Kong Digital Asset Development Policy Declaration 2.0"; on August 1, 2025, the "Stablecoin Issuer Licensing Mechanism" was officially implemented; in September 2025, the Hong Kong Monetary Authority issued a consultation document on the "Crypto Asset Classification" (CRP-1). 2. Crypto IPO Boom 2025 can be called the year of a crypto IPO boom. Stablecoin issuer Circle completed its IPO in June 2025. The final IPO price was set at US$31 per share, and the opening price on the first day surged by 122.58%. Due to excessive price volatility, a temporary circuit breaker was triggered during trading; after trading resumed, the increase continued to expand, with the stock price exceeding US$103 at its highest, corresponding to a maximum increase of 234.68%. In August 2025, Bullish became the second pure-play cryptocurrency exchange to IPO in the US, with its share price surging 150% on its first day of trading. Gemini Space Station listed on the Nasdaq Global Select Market in September, becoming the third pure-play cryptocurrency exchange to IPO in the US. Cryptocurrency companies that have filed for IPOs include Grayscale, BitGo, and Kraken. On November 13, Grayscale filed its S-1 registration statement with the SEC, planning to list on the New York Stock Exchange under the ticker symbol "GRAY," with an expected IPO completion date between the end of 2025 and the beginning of 2026. On September 22, BitGo secretly filed its S-1 statement, which was publicly amended on November 13, with a proposed listing on the New York Stock Exchange under the ticker symbol "BTGO," and an expected IPO completion date between the fourth quarter of 2025 and the first quarter of 2026. On November 19th, Kraken was reported to have secretly filed for a US IPO, planning to list on Nasdaq in the first quarter of 2026. Many crypto companies, especially leading exchanges, are rushing to file for IPOs, signifying a dual increase in industry maturity and capital market acceptance. HashKey's IPO journey is a precise grasp of this trend. 3. The Company's Own Development Needs Gaining broader influence and funding through an IPO can help HashKey achieve greater market expansion. HashKey plans to use these funds for: 1) Technology and Infrastructure Iteration a. Driving Product Innovation and New Product Supply HashKey will establish cross-platform shared liquidity and upgrade its custody system to support a wider range of blockchains and digital assets on the platform over the next two years; upgrade its OTC service to a more automated market model; and collaborate with banks to launch co-branded card products combining digital assets and mainstream financial services; and develop a "Crypto-As-a-Service" ("CaaS") platform to provide institutional clients with a secure and compliant one-stop solution for blockchain participation. b. Enhancing Infrastructure Through the Acquisition of High-Quality Cloud Services HashKey's cloud-based staking and custody solutions will benefit from distributed storage, advanced encryption, and enhanced disaster recovery capabilities, thereby reducing operational risks and improving service continuity. Furthermore, cloud-native development tools will accelerate the deployment of new products, facilitate integration with ecosystem partners, and support seamless international expansion.

c. Strengthening R&D Capabilities

HashKey will continue to retain and further strengthen its R&D team over the next three to five years. This team is expected to consist of over 70 employees proficient in blockchain technologies such as zero-knowledge proofs.

d. Upgrading Cybersecurity Defense Plan

HashKey plans to procure relevant hardware, software, and professional services, such as security auditing, endpoint detection and response (“EDR”) services, and a network intrusion detection system (“NIDS”).

2) Market Expansion and Ecosystem Partnerships

a. Maintaining Business Development and Operations Teams to Support Growth

HashKey will recruit and retain talent in business development, customer service, user growth and operations, asset and product operations, and institutional account management during this period.

HashKey will recruit and retain talent in business development, customer service, user growth and operations, asset and product operations, and institutional account management.

b. Deepen understanding and application of digital assets. HashKey will increase awareness and adoption of compliant digital assets through targeted education and marketing campaigns. c. Enhance collaboration with stakeholders. HashKey will foster thriving activities on its platform by providing incentives to partners, such as liquidity providers. 3) Operations and Risk Management a. Strengthen legal, risk, and compliance functions. HashKey will retain and expand its legal, risk, and compliance teams to ensure continued compliance with evolving regulatory standards throughout the period. b. Engage professional vendors to enhance operations, compliance, and security. This includes, but is not limited to, anti-money laundering auditors, cybersecurity companies, and compliance advisors. c. Broader Enhancement of Middle and Back-Office Capabilities HashKey will upgrade key middle and back-office functions, including finance, human resources, business intelligence, and internal control, primarily through the acquisition of industry-leading business intelligence software and the recruitment of experienced staff. 4) Working Capital and General Corporate Purposes This will provide HashKey with greater financial flexibility to support daily operations and address evolving business needs. III. Conclusion HashKey's IPO journey is a significant milestone in the compliant development of Hong Kong's cryptocurrency industry and a microcosm of global crypto companies embracing mainstream capital markets. Driven by Hong Kong's policy advantages, its own compliance strategy, and the global IPO wave, HashKey has a solid foundation for listing on the Hong Kong Stock Exchange. In the future, as HashKey's IPO process progresses and its business expands, HashKey will inject more vitality into Hong Kong's cryptocurrency industry. Appendix: HashKey Major Business Development Milestones 2018: HashKey commenced operations in Hong Kong. 2019: Launched HashKey OTC, providing compliant over-the-counter trading services to institutional clients. 2019: HashKey Cloud began providing secure infrastructure and node management services. 2020: HashKey Capital Limited obtained a Type 9 license from the Hong Kong Securities and Futures Commission, authorizing it to manage assets involving virtual assets. 2021: Tokyo Hash Co., Ltd. received approval from the Japanese Financial Services Agency to legally provide cryptocurrency trading services. In 2022, HashKey Exchange obtained Type 1 and Type 7 licenses from the Hong Kong Securities and Futures Commission, authorizing it to conduct securities trading and operate an automated trading platform. In 2023, HashKey Capital Singapore Pte. Ltd. obtained a CMS license from the Monetary Authority of Singapore to provide fund management services. Also in 2023, HashKey became the first virtual asset trading platform approved to serve both professional and retail investors, marking a regulatory milestone in the Hong Kong virtual asset market. HashKey also launched HashKey Tokenisation to facilitate the on-chain issuance of real-world assets. In 2024, HashKey Bermuda Limited obtained a digital asset business license from the Bermuda Monetary Authority, supporting spot trading, futures, and issuance pools. In 2024, HashKey Chain was launched, a regulatory-friendly Ethereum Layer 2 network designed to support financial institutions' access to Web3. In 2024, gas tokens were launched on the HashKey chain to improve transaction efficiency and community participation. Also in 2024, HashKey Technology Services Pte. Ltd. obtained a Large Payments Institution License from the Monetary Authority of Singapore to conduct digital payment token services. In 2025, HashKey MENA FZE obtained a Virtual Asset Service Provider (VASP) License from the Dubai Virtual Assets Regulatory Authority, marking the official launch of its operations in the UAE.