Hong Kong TCSP Licenses

Hong Kong TCSP Licenses | Bestar

Hong Kong TCSP License Guide

Operating a corporate services business in Hong Kong requires more than just a local address; it demands a Trust or Company Service Provider (TCSP) License.

As of March 3, 2025, the Hong Kong Companies Registry has implemented stricter Anti-Money Laundering (AML) guidelines. This article provides a comprehensive guide to the current TCSP licensing requirements, application process, and compliance standards.

What is a TCSP License?

A TCSP license is a mandatory regulatory requirement under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO). It is issued by the Registrar of Companies to ensure that service providers adhere to global financial transparency standards.

Who Needs to Apply?

You must hold a TCSP license if your business provides any of the following services in Hong Kong:

• Company Formation: Incorporating legal entities for clients.

  
  

• Corporate Secretarial: Acting as a director, secretary, or partner for a corporation.

  
  

• Registered Office Services: Providing a business or correspondence address.

  
  

• Trustee & Fiduciary Services: Acting as a trustee of an express trust or a nominee shareholder.

Key Requirements & "Fit and Proper" Test

To obtain the license, all applicants—including directors, partners, and ultimate beneficial owners (UBOs)—must pass a "Fit and Proper" assessment. The Registry evaluates:

1. Criminal Record: No convictions related to money laundering, terrorist financing, or fraud.

   
   

2. Financial Integrity: No history of bankruptcy or liquidation.

   
   

3. Compliance Framework: Evidence of robust internal AML/CTF policies.

   
   

Important Note: Operating without a TCSP license is a criminal offense in Hong Kong, punishable by a fine of HK$100,000 and up to 6 months' imprisonment.

2026 Regulatory Updates: New Compliance Standards

Recent updates have introduced two critical changes that all current and prospective licensees must follow:

1. Dual Risk Assessment (IRA & CRA)

Licensees are now required to conduct two types of risk assessments:

• Institutional Risk Assessment (IRA): Evaluating the overall risk of the entire firm (geography, customer types, products).

  
  

• Customer Risk Assessment (CRA): Individual risk profiling for every client.

2. Accelerated Identity Verification

The timeline for completing Customer Due Diligence (CDD) has been shortened.

• 30 Working Days: Maximum time to verify a client's identity.

  
  

• 120 Working Days: If verification is not completed, the business relationship must be terminated.

The Application Process: Step-by-Step

Step	Action	Details
1	Prepare Forms	Complete Form TCSP1 and supplemental forms (TCSP4/5) for all directors/owners.
2	Appoint Officers	Designate a Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO).
3	Pay Fees	Application fee: HK$3,440 + HK$975 per person for the "Fit and Proper" test.
4	Interview	The Registrar may invite directors for an interview to verify compliance knowledge.
5	Issuance	Once approved, the license is valid for 3 years.

Benefits of Holding a TCSP License

• Market Credibility: Signals to international clients and banks that you operate under a high-trust regulatory framework.

  
  

• Bank Account Opening: Most Hong Kong banks will not open accounts for corporate service providers without a valid license.

  
  

• Global Expansion: Positions your firm as a legitimate gateway to the Mainland Chinese and Asian markets.

Conclusion

The Hong Kong TCSP license is the cornerstone of the city’s corporate services industry. With the 2025 AML updates, compliance is no longer a "one-off" task but a continuous operational requirement.

Checklist of the Specific Documents You Need to Gather for a 2026 TCSP License Application

To secure a Trust or Company Service Provider (TCSP) License in 2026, your application must go beyond simple forms. The Hong Kong Companies Registry now emphasizes "operational readiness"—meaning you must prove you have the systems in place before you start.

Here is the definitive document checklist for a 2026 TCSP license application.

1. Statutory Forms & Identification

These are the core government filings required to initiate the "Fit and Proper" assessment.

• [ ] Form TCSP1: The primary application form for the license.

• [ ] Form TCSP1-SIS & SIS2A: Supplementary sheets detailing your intended business nature and employee count.

• [ ] Form TCSP4 (For Individuals): Required for every director, partner, and ultimate beneficial owner (UBO) holding ≥25% shares.

• [ ] Form TCSP5 (For Corporations): If a shareholder or director is another company, this form is required for that entity.

• [ ] Identity Proof: Certified true copies of HKID or Passports for all relevant persons.

• [ ] Address Proof: Utility bills or bank statements (less than 3 months old) for all relevant persons.

2. Business Presence Proof

The Registry has tightened rules on "virtual" presences. You must demonstrate a legitimate place of business.

• [ ] Valid Business Registration Certificate (BRC): Must show the current business address.

• [ ] Certificate of Incorporation (CI): For local Hong Kong companies.

• [ ] Lease Agreement or Title Deed: Proof of a physical office in Hong Kong.

  Note: P.O. boxes and residential addresses are generally rejected in 2026.

• [ ] Office Photos/Layout: Proof that the space is suitable for maintaining confidential client records.

3. The 2026 Compliance "Blueprint"

This is the most critical section. In 2026, "off-the-shelf" policies are often rejected during the interview phase.

• [ ] AML/CTF Policy Manual: A comprehensive written document (APPC) covering:

  • Customer Due Diligence (CDD): Your specific steps for verifying client identities.

  • Record-Keeping: How and where you will store data for the mandatory 5-year period.

  • Sanction Screening: Tools you will use to check UN and HK sanction lists.

• [ ] Institutional Risk Assessment (IRA): A report identifying the specific risks of your business model (e.g., "We serve high-net-worth clients from high-risk jurisdictions").

• [ ] Suspicious Transaction Reporting (STR) Flowchart: A clear internal process for reporting to the JFIU.

4. Personnel & Management Structure

You must prove that your team has the expertise to manage regulatory risks.

• [ ] Appointment Letter for CO & MLRO: Official documents naming your Compliance Officer and Money Laundering Reporting Officer.

• [ ] CVs of Key Officers: Demonstrating relevant experience in corporate services or compliance.

• [ ] Staff Training Log: A plan or record of AML/CTF training for all employees.

• [ ] Organizational Chart: Showing clear reporting lines to senior management.

5. Fees & Submission Preparation

• [ ] Application Fee: HK$3,440 (Standard fee).

• [ ] Fit and Proper Fee: HK$975 per person (e.g., if you have 3 directors, this is HK975 \times 3$).

• [ ] Payment Method: Credit card (Visa/Mastercard) or FPS for electronic submissions.

Pro-Tip for 2026:

The Registrar now frequently conducts pre-license interviews. Ensure your appointed Compliance Officer is prepared to explain your AML manual in person.

Would you like a template for the "Institutional Risk Assessment (IRA)" required for your policy manual?