TCSP Registration Hong Kong

Who Needs This Route?

Likely required: company 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.

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.

What Will Gofaizen & Sherle Handle?

• Eligibility assessment: Map your services and applicant structure against the licensing rules using your business description.
• Company setup: Coordinate incorporation, company kit and business registration using founder documents.
• TCSP application support: Prepare/review forms and fit-and-proper files, support filing and authority correspondence using your declarations.
• Operating arrangements: Source Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) candidates and coordinate registered-address and first-year secretarial services through network firms.

You remain responsible for accurate information, signed declarations and operating compliance. Officer sourcing excludes salary. Renewal support, change notifications and ongoing AML/CFT support require an agreed scope. The Registrar decides the application.

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: HK$3,440 plus HK$975 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?

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?

Which Taxes Need Planning?

How Does This Compare With Other Routes?

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