Ten free tickets for the service, being held at Liverpool's Anfield ground in April, were sold as tickets for the club's match against Swansea on Sunday, the BBC said.
Hillsborough Justice Campaign's Steve Kelly, who was at the match and was told of the scam by stewards, said it "beggars belief".
He said: "The fact it was the anniversary tickets just goes to show how low some people will go."
A Liverpool FC spokesman said: "It was disgraceful anyone would consider using the tickets allocated to those who wish to attend a memorial service to remember the 96 Liverpool supporters who so tragically lost their lives at Hillsborough, for illegal gain.
"Supporters should only buy tickets through official channels and we regularly remind fans about the dangers of purchasing from touts and others.
"The technology deployed at our turnstiles will refuse entry to anyone without an official ticket."
The service will be held at 2.15pm on April 15 to mark the 25th anniversary of the disaster. Free tickets are available from the club until March 31.
Ninety-six Liverpool fans died as a result of a crush at Sheffield Wednesday's Hillsborough stadium during Liverpool's FA Cup semi-final against Nottingham Forest on April 15, 1989.
New inquests into the deaths of the Hillsborough victims are due to start in Warrington on March 31 and will take six months to complete.
The Independent Police Complaints Commission is also examining accounts of the tragedy made by police amid suspicion that they were later amended.