A Complete Guide to Obtaining a TCSP Licence in Hong Kong

What Is a TCSP?

A Trust or Company Service Provider (TCSP) is an individual or professional firm  that carries on a business of helping clients set up and manage companies or trusts in Hong Kong. These firms play a key role in ensuring companies comply with local rules, especially regarding ownership, control, and reporting obligations to the Hong Kong Companies Registry.

In Hong Kong, TCSPs typically offer the following services:

• Forming and registering companies
• Acting as company secretaries or providing nominee directors/shareholders
• Offering a registered office address or business correspondence address
• Handling statutory filings and corporate compliance
• Managing trust structures

Many small and medium-sized businesses in Hong Kong outsource these tasks to TCSPs to remain compliant with government regulations and save time on complex paperwork.

TCSPs also serve international clients seeking to establish a presence in Hong Kong’s business-friendly environment. Because these services are often linked to ownership and control of legal entities, they are considered high risk for money laundering and terrorist financing if not properly regulated. This is why Hong Kong introduced a licensing system and strict Anti-Money Laundering (AML) controls under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO) in 2018.

What Is a Hong Kong TCSP Licence?

In Hong Kong, any business that provides trust or company services must apply for a licence from the Companies Registry. This is called a TCSP license, and it has been a legal requirement since March 2018 under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

The purpose of the TCSP licence is to prevent abuse of Hong Kong’s financial system by ensuring that service providers meet high standards of transparency, security, and professional conduct. Licensed firms must pass a fit-and-proper test, implement robust internal controls, and comply with AML rules to detect and prevent unlawful activities such as money laundering and terrorist financing.

A valid TCSP licence allows the business to lawfully provide services such as:

• Forming companies or legal entities
• Acting, or arranging for another person to act, as a director, partner, or nominee shareholder
• Providing a registered office, business address, or correspondence address
• Acting as, or arranging for another person to act as, a trustee of an express trust or similar arrangement
• Offering company secretarial and administrative support services, including assistance with annual compliance filings

A TCSP licence is generally valid for three years and must be renewed before expiry. Firms that continue operating without renewing their licence, or that begin operating without ever obtaining one, may face severe penalties.

As part of the ongoing obligations, a TCSP licence is required to comply with the requirements of the AMLO and the guidelines issued by the CR (including the customer due diligence and record-keeping requirements). To facilitate compliance, the CR has issued the “Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Trust or Company Service Provider Licensees)” (TCSP AML Guidelines).

Who Needs a TCSP Licence in Hong Kong?

Any business in Hong Kong that provides trust or company services must hold a valid TCSP licence. This requirement applies even if the company offers such services only part-time or as part of a broader range of business activities.

A TCSP licence is mandatory under Hong Kong’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) framework. These rules are enforced through the AMLO, which seeks to keep bad actors out of the financial system and safeguard the city’s reputation as a global business hub.

a. Examples of Applicable Businesses

You need a TCSP license if your business offers any of the following:

• Setting up companies or legal entities on behalf of clients
• Acting or arranging someone to act as a company director or secretary
• Providing nominee shareholders
• Offering a registered office or business address for other companies
• Handling statutory filings or compliance documents
• Managing bank account openings or day-to-day business administration

These services are often used by SMEs, start-ups, family offices, and high-net-worth individuals. In recent years, some TCSPs have also begun assisting with virtual assets and crypto-asset services, creating new risks that require more robust KYC (Know Your Client) procedures.

b. Exemptions to the TCSP Licence Regulation

Under section 53B of the AMLO, certain businesses are exempt from the need to hold a TCSP licence. For example:

• Legal professionals, such as solicitors or foreign lawyers, when carrying out work related to their legal practice
• Accounting professionals, such as certified public accountant as defined by the Professional Accountants Ordinance (Cap. 50 of the laws of Hong Kong), or a corporate practice or a CPA firm as defined under the Accounting and Financial Reporting Council Ordinance (Cap. 588 of the laws of Hong Kong) 
• a SFC licensed corporation that operates a trust or company service business in Hong Kong that is ancillary to the licensed corporation’s principal business; or 
• Other classes of persons designated by the Secretary for Financial Services and the Treasury.

Even if exempt, these professionals must still comply with the relevant AML/CFT requirements and maintain good practice standards.

c. Penalties for Operating Without a TCSP Licence

Operating without a TCSP licence is a criminal offence in Hong Kong under section 53F(1) of the AMLO. Companies and individuals found guilty may face:

• Fines of up to HK$100,000
• Imprisonment for up to six months
• Business stoppage or temporary closure
• Reputational damage with clients, banks, and regulators

Failure to comply also increases the risk of being flagged during KYC checks by banks or business partners. It may affect your ability to open accounts, raise capital, or bid for tenders. Under the AML Guidelines, all financial and professional institutions are expected to verify the licence status of any TCSP with which they engage.

Application Process for a TCSP Licence

Obtaining a TCSP licence in Hong Kong involves several steps, including document preparation, compliance checks, and regulatory assessment. The Companies Registry is the government authority responsible for reviewing and issuing TCSP licences in Hong Kong.

The full application process usually takes two to three months from submission to approval, provided there are no errors or compliance issues. However, delays may occur if supporting documents are incomplete or if the applicant fails to meet regulatory requirements. You are not permitted to begin offering TCSP services until your licence has been formally approved.

a. Application Categories

Once you’re ready to apply, the next step is to identify which application type and form apply to your situation. There are three main types of applications:

1. New Licence: Form TCSP1
2. Renewal of Licence: Form TCSP2
3. Approval to Add Ultimate Owners, Partners, or Directors: Form TCSP3

Each application type may also require accompanying fit and proper statements (Forms TCSP4 or TCSP5) depending on the nature of the applicant and associated persons.

b. Procedures for Submitting TCSP Applications

Now that you've determined which application category applies to your situation, the next step is to follow the correct procedure. Each application type has its own process, forms, and required documents. The sections below walk through how to apply, renew, or update your TCSP licence in compliance with Companies Registry requirements.

1. How to Apply for a New TCSP Licence

• Form Used: TCSP1
• Who Should Use It: First-time applicants who are not currently licensed.

Steps:

1. Complete Form TCSP1 and include required supporting documents (see section e. Submission and Fees for details).
2. If fit and proper declarations are required (see section c. Determining the Required Forms for details): Use Form TCSP4 (for individuals) or Form TCSP5 (for corporations).
3. Submit your application in person, by post, or via the TCSP Licensing Portal.
4. Pay the new license fee: HK$3,440 and an additional fee of HK$975 for each person subject to the fit and proper test.
5. Await assessment. The Registrar may request further information if needed.

2. How to Renew Your TCSP Licence

• Form Used: TCSP2
• Who Should Use It: Existing licence holders nearing the end of their three-year licence period.

Steps:

1. Submit Form TCSP2 along with updated business documents, including any changes to ownership or control (see section e. Submission and Fees for details).
2. If new fit and proper declarations are required (e.g. new directors added since last application), include TCSP4 or TCSP5 accordingly (see section c. Determining the Required Forms for details).
3. Submit the form before licence expiration in person, by post, or via the TCSP Licensing Portal.
4. Pay the renewal fee: HK$2,910 and an additional fee of HK$975 for each person subject to the fit and proper test.
5. Continue operations only if your current licence is still valid at the time of submission.

3. How to Add New Ultimate Owners, Partners, or Directors

• Form Used: TCSP3
• Who Should Use It: Licensed TCSPs adding new relevant persons to their structure.

Steps:

1. Submit Form TCSP3, providing information about the new individual/individuals or entity/entities and supporting documentation (see section e. Submission and Fees for details).
2. Include fit and proper declaration (TCSP4/TCSP5), unless the person is exempt under section 53B of the AMLO (see section c. Determining the Required Forms for details).
3. Attach updated structure charts and board approval (if applicable).
4. Pay the adding new owners/partners/directors fee: HK$1,140 per person being added.
5. Await the Registry’s review and approval before the new person begins acting in the TCSP role.

c. Determining the Required Forms

The correct set of forms depends on whether the relevant person (as defined in paragraph 4.2 of the Guideline) is an individual or a corporation, and whether they fall within an exempt category.

1. For Individuals

• If the individual is not a certified public accountant, solicitor,  foreign lawyer, or a person specified under section 53B of the AMLO:
  • The fit and proper test is required.
  • Complete and sign Form TCSP4, and submit it together with Form TCSP1, TCSP2, or TCSP3.
• If the individual is a certified public accountant, solicitor, foreign lawyer, or a person specified under section 53B of the AMLO:
  • The fit and proper test is not required.
  • Submit a copy of documentary proof showing the person belongs to one of these categories, together with Form TCSP1, TCSP2, or TCSP3.

2. For Corporations

• If the corporation is not a corporate practice of certified public accountants, an authorised institution, a licensed corporation, or a person specified under section 53B of the AMLO:
  • The fit and proper test is required.
  • Complete and sign Form TCSP5, and submit it with Form TCSP1, TCSP2, or TCSP3.
• If the corporation is a corporate practice of certified public accountants, an authorised institution, a licensed corporation, or a person specified under section 53B of the AMLO:
  • The fit and proper test is not required.
  • Submit a copy of documentary proof showing the entity’s exempt status, together with Form TCSP1, TCSP2, or TCSP3.

d. Fit and Proper Criteria

In determining whether a person is a fit and proper person, the Companies Registry considers the following factors of each applicant and relevant person:

• whether the person has any conviction for money laundering, terrorist financing, fraud, or dishonesty offences (in Hong Kong or elsewhere);
• whether the person has failed to comply with AMLO or related regulatory requirements;
• whether the person is bankrupt, insolvent, or subject to winding-up; and
• whether the person possesses the integrity, competence, and financial soundness required to manage TCSP operations responsibly.

If the Registrar is not satisfied that a person is fit and proper, the application may be refused or delayed until the issue is resolved.

e. Submission and Fees

• Applications may be submitted electronically via the Companies Registry TCSP Licensing Portal or in person/by post to the CR office.
• Each application must be accompanied by the following supporting documents:
  • A copy of a valid Business Registration Certificate
  • A copy of the corporation's organisational structure
  • A copy of the shareholding structure (percentage of shareholding for each group member)
  • Supporting documents for persons exempted from submitting Form TCSP4 or Form TCSP5 (if any)
  • A copy of the authorization letter from the Board of Directors stating approval for the TCSP application
• Application Fees (non-refundable):
  • New licence: HK$3,440
  • Renewal: HK$2,910
  • Fit and proper test: HK$975 per person subject to assessment
  • Adding new owners/partners/directors: HK$1,140 per person

Incomplete or incorrect submissions will not be processed.

f. Review and Approval

After an application is submitted, the Companies Registry examines all forms and accompanying documents to ensure they are complete, accurate, and properly signed. In some cases, the Companies Registry may invite relevant persons to attend interviews to obtain further information. If any inconsistencies or missing information are identified, the Registry may request clarifications or additional supporting materials before continuing with the assessment.

Where required, the fit and proper test is conducted to verify that every individual or corporation associated with the application meets the statutory criteria under the AMLO. This may include background checks and, in some cases, requests for further evidence of suitability.

Once the Registry is satisfied that all requirements have been met, the TCSP licence will be issued and the name of the TCSP licensee will be included in the register of the TCSP licencees.  Each licence remains valid for three years, provided that the licensee continues to observe all statutory, anti-money-laundering, and counter-terrorist-financing obligations.

Applicants should note that they are not permitted to commence any trust or company service business until formal approval has been granted and the TCSP licence has been issued.

Note: If you prefer a visual summary of the application process, check out the flowchart (see below) or on page 14 (labelled page 13 in the PDF) of the Guideline on Licensing of Trust or Company Service Providers (May 2025), Companies Registry. It outlines the full TCSP application process step by step, showing which forms apply to each situation.

Ongoing Obligations of a TCSP Firm

Once a TCSP licence is granted, the responsibilities do not end there. Licensed trust and company service providers in Hong Kong must fulfil strict ongoing obligations to remain compliant with regulations. These include keeping the Companies Registry informed of changes, following anti-money-laundering (AML) requirements, and observing all licence conditions and inspections.

Ongoing Notification and Reporting Requirements

All TCSP licensees must notify the Companies Registry of any major changes to their business, such as updates to ownership, directors, business address, or contact details. The Registry must also be informed of any changes affecting fit-and-proper status, money laundering reporting officers or compliance officers.

Notices must be submitted within one month of the change using Form TCSP6 – Notification of Changes in Particulars, either electronically or by post. No fee is charged for filing this form.

Failure to provide timely notification is an offence under the AMLO, punishable by a fine of up to HK$50,000, and may also lead to disciplinary action or suspension of the licence. Maintaining transparency and prompt communication with the Registry is an essential part of a TCSP’s ongoing obligations.

Comply with Anti-Money Laundering (AML) Requirements

TCSPs must establish systems to detect and prevent financial crime, including money laundering and terrorist financing. This involves implementing a comprehensive AML/CFT compliance programme in accordance with the TCSP AML Guidelines.

Key areas include:

• Conducting effective Know Your Client (KYC) and Customer Due Diligence (CDD) procedures and verifying the identities of clients and beneficial owners
• Record-keeping for a period of at least five years beginning on the date on which the transaction is completed, regardless of whether the business relationship ends during the period.
• Undertaking ongoing monitoring of client activities and transactions; and
• Filing Suspicious Transaction Reports (STRs) with the Joint Financial Intelligence Unit whenever a transaction appears suspicious.

TCSPs must remain up to date with any amendments to the AML Guidelines issued by the Financial Action Task Force (FATF) or other applicable AML laws and regulations.

Comply with AML Audit Requirements

TCSP firms are subject to regular audits and inspections by the Companies Registry. The purpose of the audits is to assess whether the TCSP licensee has complied with the AMLO, including whether the AML/CFT systems are effectively implemented and properly documented.

A failed audit may result in disciplinary action, including monetary penalties or revocation of the licence. Maintaining clear and comprehensive records of all client due diligence, risk assessments, and internal procedures is essential for successfully passing an audit.

Appointment of compliance officer (CO) and money laundering reporting officer (MLRO)

The TCSP licensee must appoint a CO and a MLRO throughout the term of the licence. If either position becomes vacant, a replacement must be appointed within seven days.

Annual Submission of Form SIS2

All TCSP licensees will receive Form SIS2 by email or letter as part of the annual reporting exercise.

Licensees must complete and submit the form by the prescribed deadline. Failure to do so will constitute a breach of Licensing Condition 3, and the Registrar may take disciplinary action under section 53Z of the AMLO.

Comply with Licencing Conditions

In addition to general obligations, the Registrar may impose specific conditions on TCSP licences. If any condition is breached, the Registrar has the authority to vary, suspend, or revoke the licence. It is important to ensure that all conditions are met on an ongoing basis.

TCSP Licence Renewal

A TCSP licence in Hong Kong is valid for three years. To continue providing trust or company services without interruption, firms must renew their licence before it expires. The renewal process ensures that TCSPs remain compliant with the latest AML/CFT standards and other legal obligations under the Companies Ordinance.

When to Renew a TCSP Licence

The renewal application must be submitted no later than 60 days before the licence expiry date. Missing this window could result in the licence lapsing, requiring the company to cease operations or reapply from the beginning.

Applications received less than 60 days before expiry will not be accepted, and the business must stop providing TCSP services once the licence expires.

If a renewal application is submitted properly and on time, the existing licence remains in force until the Registrar of Companies decides the outcome of the application.
If the Registrar decides not to renew the licence, the decision will take effect after the licensee has been formally notified.

Failure to renew before expiry means the business must cease operations immediately. Carrying on TCSP activities without a valid licence is an offence, punishable on conviction by a fine of HK$100,000 and imprisonment for six months.

What’s Required

To renew a TCSP licence, the applicant must submit:

• A completed Form TCSP2 – Application for Renewal of a TCSP Licence;
• A copy of a valid Business Registration Certificate;
• For each person subject to the fit and proper test, a signed Form TCSP4 (for individuals) or Form TCSP5 (for corporations); and
• The prescribed non-refundable fee: HK$2,910, plus HK$975 for each person subject to the fit and proper test.

Applications can be submitted electronically via the Companies Registry’s TCSP e-Services Portal or in person/by post to the Registry’s office.

Key Considerations

To maintain eligibility:

• Ensure there are no pending violations or unresolved compliance issues
• Keep audit results and training records up to date
• Confirm all business changes have been properly reported

Firms should also review the latest TCSP AML Guidelines prior to submission to ensure continued alignment with the applicable AML laws and regulations.

If approved, the renewed licence will be valid for a further three years. If the Registrar refuses renewal, the licensee will receive a written notice stating the reasons for the decision. Licensees may apply to the Anti-Money Laundering and Counter-Terrorist Financing Review Tribunal for a review of the decision within 21 days of receiving the notice if they wish to appeal (for more information, contact the Review Tribunal Secretariat).

How KYC Management Helps TCSPs Stay Compliant

Trust or Company Service Providers (TCSPs) in Hong Kong face increasingly complex compliance obligations. From AML audits to meeting KYC standards, staying on top of evolving regulations like the AMLO and the TCSP AML Guidelines requires ongoing vigilance. That’s where KYC Management can make a difference.

What KYC Management Offers

KYC Management is designed to help regulated entities in Hong Kong meet their legal obligations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615 of the laws of Hong Kong). Its tools are suitable for industries including:

• Trust or Company Service providers
• SFC-licensed corporations
• Law firms
• CPA firms
• Dealers in precious metals and stones
• Money service operators
• Licensed money lenders
• Insurance institutions

Tailored Compliance Support

For TCSP licensees, KYC Management streamlines key areas such as:

• Automated document collection via a client-facing customer due diligence portal
• Centralised storage via a document management system
• Regular monitoring to meet AML/CFT obligations, including tools that streamline the process for compliance with client due diligence, risk assessment and record-keeping obligations
• Assisted risk assessment and risk scoring system
• Automated reminders for expiring documents, including expiring identification documents and passports, address proofs, annual returns and business registration certificates

These features align with the TCSP AML Guidelines, helping ensure your business remains audit-ready and fully compliant.

Why It Matters

Non-compliance with AML legislation can lead to licence suspension, substantial fines, or even criminal prosecution. KYC Management provides a reliable, technology-driven solution to safeguard your business and strengthen client trust.

References and Sources

For more information about TCSP licensing, compliance obligations, and AML guidelines in Hong Kong, refer to the following official resources:

1. Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
2. Guideline on Licensing of Trust or Company Service Provider issued by Companies Registry
3. Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Trust or Company Service Provider Licensees) issued by Companies Registry
4. Application for Licence by Trust of Company Service Provider issued by Companies Registry

Official TCSP Forms and Documents

• Form TCSP1 – Application for a Trust or Company Service Provider Licence
  (Must be submitted together with the supplementary sheets Form TCSP1-SIS and Form TCSP1-SIS2A)
• Form TCSP1-SIS – Supplementary Information Sheet for Form TCSP1
• Form TCSP1-SIS2A – Supplementary Information Sheet 2A for Form TCSP1
• Form TCSP2 – Application for Renewal of a Trust or Company Service Provider Licence
• Form TCSP3 – Application for Approval to Become an Ultimate Owner, Partner, or Director of a TCSP Licensee
• Form TCSP4 – Statement as regards Fit and Proper Criteria (for Individual Applicants, Ultimate Owners, Partners, or Directors)
• Form TCSP5 – Statement as regards Fit and Proper Criteria (for Corporate Partners or Directors)
• Form TCSP6 – Notification of Changes in Particulars
• Form TCSP7 – Notification of Cessation of Trust or Company Service Business
• Form 53E-TCSP – Application for Certificate under Section 53E of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
• Form CC-TCSP – Application for Certified Copy of an Entry or Extract from the Register of TCSP Licensees

Disclaimer: This publication is provided for general information and guidance only. The views and comments expressed herein do not constitute, and should not be relied upon as, legal advice or a legal opinion.

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