1. What is moneylender business? What types of loans are covered?
Money lender business definition
The business of money lenders and the scope of "loans" are judged based on the definition of the "Money Lenders Ordinance" and the substance of the transaction.。Except for the exemptions specified in the Ordinance and Schedules,Any person operating moneylender business without a license in Hong Kong commits an offense。
personal、Business and SME Credit
personal、enterprise、Secured or unsecured loans may be money lending business;credit card、bill、Whether trade finance or other arrangements are regulated by license,Both transaction structure and statutory exemptions must be checked。
Mortgage and asset pledge
Including mortgage loans with real estate as collateral (subject to strict restrictions on relevant mortgage conditions and the Housing Authority's Home Ownership Ordinance),and other secured loans。
Leasing and syndicated lending
lease、finance lease、Whether a syndicated or project loan is regulated money lending,depends on contract、risk、Funding methods and statutory exemptions,You cannot judge based on the product name alone。
2. Functions of the three major regulatory agencies and core considerations in court licensing
1. Licensing Tribunal:Responsible for making final determinations on money lender license applications and issuing licenses,The court will comprehensively consider the review results of the Police Force and the Registrar。
2. Registrar of Money Lenders:Responsible for processing licenses、Application for renewal and endorsement of license;and maintain a register of debtors for public inspection。
3. Commissioner of Police:Responsible for enforcing the Money Lenders Ordinance,Review license、Renewal and endorsement applications and investigate complaints;Can be investigated,to decide whether there are grounds for objecting to the application。
4. Court consideration 1 (fit and proper person):Consider whether the applicant and relevant persons are appropriate。Knowledge、Educational qualifications、experience、Compliance、manage、financial condition、Good faith and other facts may be considered,Should not be reduced to a uniform academic qualification or “no criminal record” threshold。
5. Court consideration two (Suitability of the premises):Whether any premises involved in the application are suitable for money lending business (the land use of the premises and the permission given by the owner/tenant must be reviewed)。
6. Court consideration three (public interest):Licensing tribunal considers whether licensing would be contrary to public interest;AML/CFT、Internal controls and business plans are also important information for current applications and ongoing compliance。
3. 2026Highlights of 16 money lender license conditions starting from August 1, 2020
Regulation of third parties and prohibition of fees:Before entering into an agreement, you must ask the borrower whether there is any third-party intermediary involved.,and attach a third-party agreement。It is strictly prohibited for any appointed third party to charge any fees or remuneration from the borrower for facilitating the loan。
Mandatory interpretation of terms and record keeping:Loan interest rates must be explained to borrowers(APR)、Total repayment amount and consequences of default (including the right to take over and sell the mortgaged property),and must be kept in writing、Video or audio recording。
Personal data privacy (PDPO) limit:Do not illegally obtain personal information from others for money lending purposes,Must obtain written confirmation that the disclosed information does not breach the Personal Data(privacy)Regulations。
Advertising conditions:Advertisements in Chinese must display the "money lender's license number" and the number;character、Sound or visual advertising must be fair、Not misleading,and display the complaint hotline and “advice” in accordance with current conditions.:Borrow money and have to pay it back,Risk warnings such as "Meet money intermediaries"。
HOS mortgage restrictions:Unless a letter of confirmation of full payment of the land premium issued by the Hong Kong Housing Authority for lifting the restriction on transfer rights is presented,or written approval from the Director of Housing,Otherwise, the sponsoring unit must not be accepted as collateral.。
Internal controls and prudent lending:The licensee must establish a system to ensure that relevant personnel comply with the regulations and license conditions,and comply with AML/CFT guidelines;Unsecured personal loans are also subject to a repayment ability assessment,As well as new restrictions on the repayment-to-income ratio for low-income people in 2026。
4. Money Lenders License Application Form、Business plans and research materials
| File category | Specific detailed requirements (According to laws and police requirements) |
|---|---|
| Statutory application form | Form 2/4 (individuals) or Form 3/5 (Company license application form and statement);Supplementary information page (SIS-1/SIS-2 and SIS-1A/2A Fit and Proper Criteria)。 |
| Proof of ability and finances | The police may request employment and academic documents proving the ability to manage a money lending business (the 2016 Guidelines state that more than just resumes will be accepted),and company、Financial certificates such as bank information of directors or shareholders;Actual list can be expanded on a case-by-case basis。 |
| Premises leases and licenses | Tenancy agreement for premises intended to be used for carrying on money lending business;Written permission from the landlord (in the case of subletting,Written permission from both the landlord and tenant must be obtained)。 |
| Land and use certificate | Police guidance lists occupation permits、Use permission、Information such as land registers and floor plans;If the existing use is not an office or shop,Additional permission from relevant departments may be required,It is ultimately up to the Licensing Tribunal to determine whether the premises are suitable。 |
| Business and AML Program | according toCompanies Registry 2025 Business Plan GuidelinesDescription subject、Source of funds、personnel、loan、client、bank account、process、system、Outsourcing and other regulatory situations,and pressAML/CFT Guidelines for Licensed Money LendersEstablish proportional controls。 |
5. Money Lender License Application and Approval Process (Approximately required 3 to 4 months)
step 1:Prepare application form and supplementary supporting documents
Confirm the applicant、Loan business、Relevant persons and premises,Prepare business plan based on current form and supplementary information pages、fit and proper person、AML/CFT、Financial and premises documents;Personnel and responsibilities are reported according to actual governance arrangements。
step 2:Deliver documents and pay fees
Submit the required documents to the Companies Registry, the money lender’s registered office and the Police in accordance with the current procedures。New applications must pay HKD to the Companies Registry 8,800;Pay HKD to the Licensing Court when the license is issued 1,910,Fees paid are non-refundable。
step 3:Police investigation and additional information
Police investigate applications and may require competency、finance、Premises and other information,to decide whether to object。Whether to arrange a meeting、Participants and time will be notified on a case-by-case basis;Official guidance does not commit to 60 days to complete investigation。
step 4:Attend Licensing Court Hearing
Licensing Tribunal considers suitable candidates in accordance with Money Lenders Ordinance、Premises and public interest,and handle any objections。Is attendance required?、Who will attend and what documents will be brought?,Subject to notification from the court and competent authority。
step 5:Licensing Court Determination and Licensing
If the Licensing Tribunal considers it appropriate,Can issue licenses valid for 12 months and impose conditions。The Companies Registry's 2023 leaflet states that new applications generally take 3 to 4 months,But the actual time depends on the file、investigation、Objections and court arrangements,does not constitute a guarantee。
6. Common challenges and risks of rejection when applying for a license
Fit and proper information:Companies Registry and police can assess applicants、Controller、director、secretary、Senior personnel and management business personnel。20162019 Police Guidelines Require Work and Educational Qualifications to Demonstrate Management Ability,Explain that not only resumes are accepted;Final assessment on a case-by-case basis。
Suitability of the premises:Prepare a lease、Landlord and if necessary tenant permission、occupation license、Land registration and layout information;If the purpose does not match,Permission from relevant departments may be required。The Licensing Court determines based on the actual location,No unified conclusion is made on the difficulty of site selection.。
Business Planning and AML/CFT:20252016 guidance requires clarification of funding sources、personnel、loan、client、bank、process、system、Outsourcing and other regulatory situations,and establish commensurate AML/CFT controls;Insufficient information may lead to supplementary inquiries or objections,But the outcome cannot be predicted。
7. Hong Kong Huitong’s one-stop licensing service
Company Registration and Premises Compliance
Hong Kong Express can assistHong Kong company informationCheck with premises documents,and prompt for occupation permission、Land registration and owner consent matters;The suitability of premises is determined by the Licensing Court on a case-by-case basis。
A complete set of statutory documents and plans
Can assist in organizing statutory forms based on customer confirmation information、Supplementary information page、Business Plan and AML/CFT Policy。Applicants must confirm the facts and assume responsibility,The consultant cannot guarantee acceptance of the document。
Responding to police and court hearings
As an application consultant,Hong Kong Huitong assists in preparing for police interviews、Respond to regulatory inquiries and compile Licensing Court hearing materials;Whether the license is approved will be reviewed by the relevant agency on a case-by-case basis,Subsequent bank account openings will also be independently decided by the relevant banks.。
8. Hong Kong Money Lenders License FAQs (FAQ)
Except for the exemptions set out in the Money Lenders Ordinance and its Schedules,A license is required to operate a money lender business in Hong Kong。按揭、Individual or business、Secured or unsecured、Arrangements such as leasing and syndication must be judged on a case-by-case basis based on contracts and statutory exemptions。
Current fit and proper guidelines may relate to applicants、A person who controls a company or gives instructions、director、secretary、Other senior personnel,and persons responsible for the management of a money lending business or any part thereof。The specific declaration and signatory must be confirmed according to the application form and subject。
The information cited on this page does not require all applicants to stay in Hong Kong for the entire application period.,There is no requirement that every case must be met in person.。Applicants are required to respond to inquiries promptly,and press the police、Notice of attendance or submission of information from the Companies Registry or court。
The court will strictly consider three major factors:1) Whether the applicant is a fit and proper person to operate a money lending business (e.g. relevant knowledge、Educational qualifications and experience);2) Whether the premises involved in the application are suitable for business (e.g. land use and landlord/tenant permission);3) Will licensing be contrary to public interest?。
The Information Sheet of the Companies Registry in December 2023 stated that a new license generally takes 3 to 4 months from the date of delivery of application.;This is a dated service reference,Not a statutory guarantee。The license is usually valid for 12 months。
The December 2023 information leaflet from the Companies Registry states that applications for renewal of the license can be made within 3 months before the expiry of the license.,It is said that it usually takes 2 to 3 months;Should be done as early as possible,The actual time is based on current procedures and case progress。
The Police Force is responsible for enforcing the Ordinance、Review applications and investigate complaints,and may conduct an investigation to determine whether to object。Police guidance sets out abilities、Requestable documents such as finance and premises,The actual scope is determined on a case-by-case basis。
2016Police guidance in 2019 states that proof of management ability can include moneylending work and academic documents,And indicate that not only resumes are accepted。Required experience、Proof and adequacy are assessed on a case-by-case basis by the police and licensing courts。
Applications must be made using the currently applicable forms and supplementary information pages。From March 2025,Corresponding information should also be provided according to the appropriate candidates and business plan guidelines;Form number and version should be checked from the Registrar of Companies before submission。
Absolutely not。Strict license conditions,Unless a confirmation letter issued by the Hong Kong Housing Authority that the land premium has been paid in full is presented,or written approval from the Director of Housing,Otherwise, money lenders are not allowed to accept Housing Authority-subsidized flats as collateral。
Collection is strictly prohibited。A moneylender shall not knowingly allow any person (including his employee)、agent or appointed third party) for procuring、Negotiate a loan or guarantee,and charge any fees to any borrower、reward or consideration。
Any form of advertising (text、sound or visual) must clearly display the money lender’s license number、Complaint handling hotline,and legal risk warning words:"advice: Borrow money and have to pay it back,"A money-making agency"(“Warning: You have to repay your loans. Don’t pay any intermediaries.”)。The sound part must also be read clearly。
Exemptions and exclusions must be checked item by item according to the definitions and Schedule 1 of the Money Lenders Ordinance。bank、Insurance、employee loan、Pawnbroking or securities margin financing cannot be automatically exempted based solely on the institution or product label.。
The official information quoted on this page does not list the uniform conditions for all shareholders to be Hong Kong residents.。Application subject、Controller、director、secretary、business managers、Service and attendance arrangements must be made in accordance with the form、Confirmation of subject and case requirements;Hong Kong Huitong does not provide unfounded "local staffing" guarantees。
9. Hong Kong Companies Registry - Overview of application requirements for money lender license
10. Hong Kong Money Lender License | Typical Application Preparation Scenarios in 2026
11. Hong Kong Money Lenders License-Industry Information Sharing
Current official information:
1、Companies Registry:Regulatory authorities and responsibilities
2、Hong Kong electronic legislation:Money Lenders Ordinance (Chapter 163)
3、202616 license conditions starting from August 1
4、Companies Registry:Guidance on licensing conditions (April 2026)
5、AML/CFT Guidelines for Licensed Money Lenders (March 2025)
6、Fit and proper guidance (March 2025)
7、Business Planning Guidance (March 2025)
8、Fees required to be paid under the Money Lenders Ordinance
12. Offices suitable for application for money lender license in Hong Kong

13. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
|---|---|
| Professional interpretation |
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| Licensing and regulatory authorities | |
| Licensing Process and Ongoing Responsibilities |