Can an online store sell gift cards or store credit without a licence?

The Payment Systems and Stored Value Facilities Ordinance requires a licence from the HKMA for issuing a "stored value facility" in Hong Kong, which in broad terms is a facility where money is paid in advance and can be used for payments. The Ordinance excludes some limited-purpose facilities from the definition, and a facility usable only for goods or services from the issuer itself is the usual example of one that falls outside the regime.

For a typical store:

• A gift card or credit redeemable only in your own shop is normally outside licensing, though it is a liability until redeemed.
• Credit that can be used at other merchants, transferred widely or cashed out is more likely to be a regulated stored value facility.
• Terms such as expiry dates, fees and refund rules should be stated clearly, so as not to mislead consumers under the Trade Descriptions Ordinance.

The exact boundaries are technical. Check the HKMA's guidance, or ask the HKMA, before launching a scheme that goes beyond your own goods.