Complete Guide to Applying for a Hong Kong Trust or Company Service Provider (TCSP) Licence in 2026: Registration Requirements and “Fit and Proper” Assessment
The mandatory licensing regime has been in force for more than six years — operating without a licence is a criminal offence. With effect from 1 March 2018, Hong Kong implemented the Trust or Company Service Provider (TCSP) licensing regime. Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), any person who carries on a trust or company service business in Hong Kong without a TCSP licence commits an offence, punishable by a maximum fine of HK$100,000 and imprisonment for 6 months. As of early 2026, there were approximately 7,279 licensed TCSP companies in Hong Kong. If you are planning to provide company secretarial, registered office or trust services, this article provides a one-stop explanation of the registration requirements and the “fit and proper” assessment standards.
What Is a TCSP Licence? The Four Core Business Categories of the “Trust Licence Structure”
The formal English name of the TCSP licence is the “Trust or Company Service Provider Licence”. It is administered and approved by the Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, and is granted by the Registrar of Companies. The four core categories of TCSP business (i.e., the statutory business scope of what is commonly referred to as the “trust licence structure”) are as follows:
核心類別 Core Category | 具體業務範圍 Specific Scope of Business |
|---|---|
Company Formation | Forming a company or other legal entity for a client |
Company Officer Services | Acting as (or arranging for another person to act as) a director, company secretary, partner of a partnership, or a similar position in relation to other legal structures |
Registered Office Services | Providing a registered office, business address or correspondence address for a company, partnership or other legal entity / arrangement |
Trust and Nominee Services | Acting as (or arranging for another person to act as) a trustee of an express trust, or acting as a nominee shareholder for another person (except where the shares are of a company listed on a recognised stock market) |
Special Note: TCSP Licence vs Registration as a Trust Company
A TCSP licence only permits the provision of company services (such as company secretarial, registered office and nominee director services). It does not authorise the holder to act as a trustee managing trust property. If you wish to provide trust services (i.e., to act as a trustee of an express trust), you must separately register as a trust company under the Trustee Ordinance (Cap. 29) and must also hold a TCSP licence. The two regimes are governed by different ordinances, and applicants must pay particular attention to this distinction when planning their trust licence structure.
Companies Registry’s “Fit and Proper” Assessment Standards for TCSP Licence Applicants
Who is subject to the assessment?
According to the Companies Registry’s Guideline on Licensing of Trust or Company Service Providers, any applicant (whether a sole proprietor, partnership or corporation) that carries on or intends to carry on a TCSP business, together with its directors, ultimate owners and every relevant person, must pass the “fit and proper” test conducted by the Companies Registry.
Six Core Assessment Dimensions
When assessing whether a person is “fit and proper”, the Companies Registry focuses on the following six dimensions:
評價維度 Assessment Dimension | 審查具體內容 Specific Matters Examined |
|---|---|
Business Registration and Licence Status | Whether the applicant holds a valid Business Registration Certificate and complies with the relevant requirements for licence renewal |
Integrity and Character | Whether the relevant persons have been found guilty of misconduct in any professional capacity, or whether there are any other matters that may call their integrity into question |
Competence and Experience | Whether the applicant possesses the ability to carry on the intended business competently and diligently |
Regulatory Disciplinary Record | Whether the relevant persons have been publicly reprimanded, had their licence revoked or suspended, or been disciplined by any regulatory authority for breaches of regulatory requirements |
Bankruptcy / Liquidation Status | Whether an individual is an undischarged bankrupt; whether a corporation is in the course of being wound up |
Criminal Conviction Record | Whether the applicant or relevant persons have been convicted of money laundering, terrorist financing, fraud or other offences involving dishonesty |
Exemptions from the “Fit and Proper” Assessment
Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, the following professional persons may be exempt from the requirement to apply for a TCSP licence (including the fit and proper assessment) in specified circumstances:
-
Authorised institutions (i.e., banks)
-
SFC-licensed corporations (where the provision of trust services is incidental to their principal business)
-
Accounting professionals (as defined under the Professional Accountants Ordinance and the Accounting and Financial Reporting Council Ordinance)
-
Legal professionals
2026 TCSP Licence Application Process
階段 Stage | 工作內容 Work Content | 預計需時 Estimated Timeline |
|---|---|---|
Pre-application Preparation | Incorporate a Hong Kong limited company, lease suitable business premises, recruit a Compliance Officer and Money Laundering Reporting Officer, and design a shareholding structure that meets the fit and proper requirements | Approximately 1 month |
Document Preparation | Complete the licence application form (Form TCSP1), fit and proper declaration (Form TCSP4 for individuals / TCSP5 for corporations), and submit a copy of a valid Business Registration Certificate | Approximately 1–2 months |
Submission of Application | Submit the application documents and fees via the Companies Registry’s electronic platform | Immediate |
Licence Assessment | The Companies Registry examines the application and conducts the fit and proper assessment of the relevant persons | Approximately 2–4 months |
Licence Validity: A TCSP licence is valid for 3 years upon grant and must be renewed before expiry in order to continue carrying on the business lawfully.
ComplianceOne Consulting Limited (“ComplianceOne”) (TCSP Licence No.: TC007463) is itself a licensed Trust or Company Service Provider. We provide one-stop support covering structure planning, pre-screening of shareholders’ backgrounds, identification and appointment of local Compliance Officers (CO) and Money Laundering Reporting Officers (MLRO). We will tailor compliance policy documents for you and act as your full representative in submitting the application to the Companies Registry and responding to enquiries, helping you successfully pass the assessment and enter the Hong Kong financial market on a solid footing. With extensive experience in TCSP licence applications, ComplianceOne can assist you throughout the entire process.
Q&A: Common Questions on TCSP Licence Applications
Q1: What is the difference between a TCSP licence and registration as a trust company?
A: A TCSP licence is granted by the Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and permits the holder to provide company secretarial, registered office, nominee shareholder and similar services. If you wish to act as a trustee of an express trust, you must separately register as a trust company under the Trustee Ordinance (Cap. 29).
Q2: If a director or shareholder has a criminal record, will they necessarily fail the “fit and proper” assessment?
A: Not necessarily. The Companies Registry will consider the nature of the offence, the time that has elapsed since the conviction, whether the person has rehabilitated, and other relevant factors. It is nevertheless advisable to conduct a pre-assessment before submitting the application.
Q3: What are the specific requirements for business premises under a TCSP licence?
A: The applicant must maintain physical business premises in Hong Kong that are suitable for carrying on the business and for the safekeeping of records. Virtual addresses or P.O. Box numbers are not acceptable.
Q4: Does the renewal of a TCSP licence require a fresh “fit and proper” assessment?
A: Yes. Upon renewal, the fit and proper status of the licensee and its relevant persons will be re-assessed. If any event that may affect fitness and properness (such as bankruptcy or conviction) occurs during the licence period, the licensee must proactively notify the Companies Registry.
Conclusion
A TCSP licence is a mandatory statutory requirement for carrying on company secretarial, registered office and trust services. Operating without a licence is a criminal offence. Early planning of the trust licence structure and ensuring that directors and shareholders meet the “fit and proper” standards are the critical first steps to a successful application.