HK TCSP License

Who Needs This Route?

Likely required: сompany service providers and trust service providers serving clients commercially.

Exemption assessment: accounting and legal professionals may qualify, depending on legal form and statutory conditions. Employing an accountant does not exempt an ordinary corporation. Authorized institutions and SFC-licensed corporations providing ancillary services have separate exemptions.

Separate permission: financial services require their own regulatory assessment.

Outside scope: ordinary office letting alone differs from selling registered-address services.

Which Filing Applies?

Use the official forms for each procedure.

Trigger	Applicant	Form	Authority	Outcome	Deadline	Dependency
Start business	New provider	TCSP1	Registrar	Grant/refusal	Before operating	Valid business registration certificate
Continue	Licensee	TCSP2	Registrar	Renewal/refusal	≥60 days before expiry	Updated assessments
New ultimate owner/partner/director	Licensee	TCSP3	Registrar	Written approval/refusal	Before appointment	Assessment or exemption
Particulars change	Licensee	TCSP6	Registrar	Records updated	Within one month	Change details
Stop business	Licensee	TCSP7	Registrar	Cancellation	Before cessation	Intended date

Fit-and-proper statements use TCSP4 for individuals and TCSP5 for corporate partners/directors, unless exempt. Notification does not replace prior approval.

Which Trust and Company Services Are Covered?

The statutory categories cover services provided to others by way of business.

Activity	Statutory trigger	Typical model	Caveat	Adjacent permission
Formation	Forming corporations or legal persons	Incorporation agency	Client service	Separate financial permissions
Appointments	Acting/arranging directors, secretaries, partners or equivalent roles	Corporate administration	Includes arrangements	Separate financial permissions
Addresses	Registered office, business, correspondence or administrative address	Address provider	Mere letting differs	Separate financial permissions
Trusteeship	Acting/arranging an express-trust trustee or equivalent	Trust administration	Business test applies	Separate financial permissions
Nominees	Acting/arranging nominee shareholders	Shareholding service	Excludes corporations listed on recognized markets	Separate financial permissions

What Does the Application Service Cost?

The total includes Gofaizen & Sherle’s professional fees, government charges and any additional expenses.

Professional fees depend on your company structure and the support required. Gofaizen & Sherle confirms the scope and quote before work begins. Officer salaries are excluded.

Government charges depend on the application:

• Initial license: HK3,440plusHK975 for each person assessed.
• Renewal: HK2,910plusHK975 for each person assessed.
• Approval of a new ultimate owner, partner or director: HK$1,140 per person.

These official fees are non-refundable.

Additional expenses may include business registration, document certification and translation. Registered-address and company-secretarial services incur renewal costs after the first year. Renewal applications and ongoing compliance support are quoted separately.

What Do We Need From You?

• People: sole proprietor plus ultimate owners, partners plus ultimate owners, or corporate directors plus ultimate owners. Provide identity/address evidence, ownership/control charts and conviction, disciplinary or insolvency disclosures for fit-and-proper assessment.
• Entity: corporate documents, valid business registration certificate and applicable exemption evidence.
• Business: services, client types, countries served and premises information.
• Compliance: existing policies, records, CO/MLRO arrangements and signed declarations. Initial filing includes TCSP1-SIS and TCSP1-SIS2A.

What Affects the Timeline?

Preparation → regulatory review → follow-up → decision.

Preparation depends on document readiness and setup. The Registry’s 2026–2027 service standard is 2.5 months, targeting 90% of qualifying applications. Cases requiring amendments, additional information or further investigation are excluded. This is not an approval guarantee. Gofaizen & Sherle estimates preparation separately.

Which Rules Apply?

The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO) governs this regime:

• part 5A addresses licensing
• schedule 1 defines covered services
• schedule 2 sets customer due diligence (CDD) and record-keeping duties.

Licensing and AML/CFT guidance explain practical requirements.

What Is the Current Regulatory Status?

Rule	Current status	Authority	Source	Checked	Practical effect
Licensing	Mandatory since March 1, 2018, subject to exemptions	Registrar	AMLO	29 Sep 2026	Assess before launch
Guidance	Licensing: May 2025. AML/CFT: March 2025	Companies Registry	Guidelines	29 Sep 2026	Use current requirements
Public status	Searchable TCSP register	Companies Registry	Register	29 Sep 2026	Verify licensee identity

What Compliance Must You Maintain?

Customer checks
Staff identify and verify customers and beneficial owners, screen politically exposed persons and sanctions/proliferation risks, apply enhanced checks where needed and monitor relationships. Keep evidence at onboarding and during ongoing reviews.

Management
Senior management approves business risk assessments and AML/CFT systems. The CO oversees implementation. The MLRO handles suspicious transaction reports to the Joint Financial Intelligence Unit (JFIU) when warranted. Retain assessment and reporting records. Both officers should normally be Hong Kong-based.

Controls
Screen employees, train staff regularly and arrange independent reviews at a frequency proportionate to risk. Retain training and review evidence.

Records and filings
Under the AML/CFT guideline, management must keep customer records throughout the relationship and for five years afterwards, and transaction records for five years after completion, at minimum. Management maintains renewal and change-notification calendars.

What Are the Regulatory Risks?

Trigger	Authority	Consequence	Mitigation	Source
Unlicensed operation	Courts	Up to HK$100,000 and six months’ imprisonment	Await grant	AMLO 53F
CDD/record failures	Registrar	Reprimand, corrective action, penalties up to HK$500,000	Effective controls	AMLO 53Z
Unapproved appointments/late notifications	Registrar/courts	Disciplinary action or prosecution	Approval/filing calendar	AMLO 53S–53X
Loss of fitness	Registrar	Suspension/revocation	Monitor relevant persons	AMLO 53Q

Which Taxes Need Planning?

Topic	Trigger	Responsible party	Source	Caveat
Profits tax	Hong Kong-sourced business profits	Taxpayer	IRD	Source requires factual analysis
Corporate rates	Qualifying assessable profits	Corporation	IRD	8.25% on first HK$2 million, 16.5% above. Connected-entity restrictions apply

How Does This Compare With Other Routes?

Route	Activity	Authority	Applicant	Key condition	Limitation
TCSP	Corporate/trust services	Registrar	Provider	Fit and proper	No financial permissions
MSO	Remittance/currency exchange	Customs and Excise	Operator	Separate application	Not trust administration
VATP	Centralized virtual-asset trading platform	SFC	Platform operator	Applicable licensing requirements	Not corporate services
Money lender	Lending business	Licensing Court, Registry, Police	Lender	License unless exempt	Not TCSP permission
Exempt professional	Eligible corporate/trust work	Relevant professional regulator	Qualifying professional/entity	Statutory status and legal form	No blanket subsidiary exemption

Combined models may need several permissions. In-house and overseas arrangements require assessment of the actual business activity.