1. The functions and regulations of Hong Kong TCSP license
Designated company services
Regulated services include the formation of corporations or other legal persons, Provide registered office or business address, and act or arrange for others to act as directors, company secretary, Partner or nominee shareholder; Must be based on legal definitions and actual business judgments.
Designated trust services
Regulated services include acting or arranging for others to act as trustee of an express trust or similar legal arrangement. The TCSP license itself does not authorize virtual asset trading, custody, Payment or bank account, Relevant functions must be separately evaluated based on actual activities.
Stringent AML/CTF statutory compliance
Licensees must comply with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and applicable guidelines, Includes customer due diligence, Ongoing monitoring and record keeping. The TCSP system should not be described as a uniform application of virtual asset transfer information rules.
Criminal penalties for operating without a license
Unlicensed operations are strictly prohibited according to law. Pursuant to AMLO Section 53F(1) strip, It is a crime to operate TCSP business in Hong Kong without a license, Once convicted, Facing a maximum fine of HK$100,000 and 6 months' imprisonment.

2. Application conditions for TCSP license, Exemptions and capital boundaries
| Review feature categories | Legal standards and definition of exemption objects |
|---|---|
| capital requirements | There is no unified minimum capital requirement for ordinary TCSP licenses. If the applicant applies separately to become a trust company under the Trustees Ordinance, then the share capital must be verified in accordance with the independent system, Full payment amount and other registration conditions, The relevant requirements cannot be applied to all TCSPs providing trust services. |
| Statutory exemptions from applying for a license | Section 53B of the Anti-Money Laundering Ordinance lists authorized institutions, A licensed corporation operating subsidiary TCSP business in Hong Kong, accounting professionals, Exemptions for legal professionals and other prescribed categories; It must be checked according to the main form and actual services., It is not appropriate to generalize that all relevant institutions are automatically exempted. |
| Compliance obligations for exempt persons | The above-mentioned exemption application TCSP licenseprofessionals, When providing trust or company services, Full compliance with the AMLO Schedule is still required by law 2 Customer due diligence as set out in (CDD) and stringent record-keeping requirements. |
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3. [Fit and proper person] as prescribed by the Companies Registry (Fit & Proper) Review standards]
Legal review objects: All sole proprietors, Partner, Directors and "ultimate owners" (Ultimate Owner)” are required to submit a TCSP4 or TCSP5 statement to the Director in accordance with the law to undergo strict background checks (except for professionals who qualify for the aforementioned exemption).
Define the ultimate owner: Legally refers to directly or indirectly owning/controlling a corporation 25% The above issued share capital, or have the right to exercise 25% Voting rights above, or the natural person who exercises ultimate management control. The holding company itself does not fall into this category, Must penetrate to natural person.
fit and proper factors: The Commissioner will consider relevant convictions, Supervisory or disciplinary record, Comply with regulations, Legal factors such as personal bankruptcy and corporate liquidation or receivership, and may request additional information or interviews; Not all disclosures can be predicated on this page and will necessarily lead to denial of license..
Change approval red line: Any person becomes the new ultimate owner of the licensee’s business, Before partner or director, Must obtain prior written approval from the Director. Violators without reasonable excuse may be fined HK$50,000 and imprisoned for 6 months.
4. Information required to apply for Hong Kong TCSP license
| File category | Legal requirements submission details and compliance interpretation |
|---|---|
| Basic corporate and personnel due diligence documents | Copy of valid business registration certificate. Director and senior management biographies. All statutory "fit and proper statements" that need to be completed and signed by the reviewer(Table TCSP4 / TCSP5). |
| Commercial and anti-money laundering internal control system | application forms, Business registration, Documents proving the subject and the appropriate person, and provide supplementary information as required by the Companies Registry. AML/CFT Policy, Procedures and evidence of execution should be commensurate with business risks; Whether an independent business plan is required shall be based on the current form and case notification. |
| Documentation proving specific qualifications | If the relevant person claims that a fit and proper person exemption applies, Supporting documents must be submitted. If you apply separately for trust company registration under the Trustees Ordinance, Capital and other evidence should be submitted in accordance with this independent procedure. |

5. Application process and approval steps
first stage: Confirmation subject, Business and Applicable Exemptions
Confirm that the applicant is an individual, partnership or corporation, List the services to be provided and check for exemptions; Prepare business registration, application forms, Fit and proper statement, Supporting documents and an AML/CFT system commensurate with the business.
second stage: Formal submission of application to the Registrar's Office
Submit Form TCSP1 and its attachments through the TCSP online system or in person, and make a one-time payment 3,440 Hong Kong dollar application fee and 975 Background check fee in HKD/person.
The third stage: Companies Registry Review and Supplementary Information
The Registrar assesses the suitability of applicants and relevant persons, and may request additional information, Support documents or invite relevant persons to meet. Official information does not guarantee a unified approval cycle.
Stage 4: Approval and inclusion in the roster
After passing the review, The Director shall grant licenses in accordance with the law. The name and business address of the licensee will be publicly included in the "Register of Trust or Company Service Provider Licensees".
The fifth stage: Daily compliance supervision after licensing
The license is usually valid for 3 years. Licensee must comply with license conditions, CDD and record keeping requirements, And cooperate with the Companies Registry to enter business premises to check relevant business or transaction records in accordance with the law..
6. TCSP continuing liability and other license boundaries
Virtual asset boundaries: The TCSP license is only for legally defined trust or company services, Do not automatically authorize OTC, Virtual asset trading, custody, Payment or client asset holding. Involving these functions must be based on the product, Control and financial flow separately checked supervision system.
Other regulatory regimes: Operating a central virtual asset trading platform in Hong Kong may trigger the SFC’s VATP licensing regime; Broker, custody, pay, Stable currency issuance or other activities must be judged separately based on actual functions, It cannot be summarized by just “VASP license”.
Inspection and Recording: The licensee must allow the Companies Registry to enter the business premises for inspection in accordance with the law., Make copies of relevant records and answer inquiries. The specific starting point and period of retention of CDD and transaction records shall be implemented in accordance with Schedule 2 of the "Anti-Money Laundering Regulations" and current guidelines., It should not be written as unified "5 to 6 years".
Details change: The licensee must submit TCSP6 within 1 month after the change of notifiable details occurs; Add final owner, Partners or directors generally require prior approval, Exempted persons are treated differently, Should be handled according to change category.
7. official fees, Change of control and business cost boundaries
| matter | official request | Fees and boundaries |
|---|---|---|
| New license application | Submit TCSP1 and fit and proper statement and supporting documents. | Application fee HKD 3,440; Additional HKD for each person subject to assessment 975. Fees paid will not be refunded. |
| licence renewal | TCSP2 is usually required to be submitted at least 60 days before the license expiry date. | Renewal fee HKD 2,910; Additional HKD for each person subject to assessment 975. |
| Add final owner, partner or director | Subject to applicable exemptions, Written approval from the Director should be obtained before making changes. | HKD for each person to whom the application relates 1,140. Equity trading, legal, Accounting and consulting fees are not government fees, Must be confirmed separately according to the contract. |
8. Hong Kong TCSP license of Hong Kong Huitong, Agency application service
New license application and corporate establishment
Can assist in sorting out the main body and control structure, Application form and suitable candidate information preparation, and compile responses to supplementary questions from the Companies Registry. directors, The ultimate owner and applicant must truly perform their duties, Consultants cannot substitute for their presentation or review by the Registrar.
AML internal control system and review coaching
Write a Strictly Compliant AMLO Schedule 2 Required Anti-Money Laundering Compliance Manual. Develop CDD/KYC review forms and suspicious transactions that comply with statutory requirements (STR) Internal transfer reporting process.
Coordination of transaction data for licensed companies
Can assist in organizing public registration according to contract, Seller Disclosure and Change Request Information, and coordinate independent legal and accounting due diligence. There is no guarantee that the subject matter will be debt-free, Director's approval, The license continues to be valid or the equity delivery result.
9. Hong Kong trust or company service provider (TCPS) License plate FAQ answers
10. Hong Kong Trust or Company Service Provider License - Sample

11. Sharing related reference materials:
- 1, Trust or Company Service Provider Licensing Guidelines-Hong Kong Companies Registry
- 2, Register of Trust or Company Services Licensees-Hong Kong Companies Registry
- 3, Trust or Company Service Provider Licensing FAQ-Hong Kong Companies Registry
- 4, Apply for a trust or company service provider license-Hong Kong Companies Registry
- 5, Inquiry on the list of trust or company service licensees-Hong Kong Government Information Online
- 6, Application for Trust or Company Service Provider License-Hong Kong Companies Registry
- 7, Companies Registry "Guidelines for Licensing Trust or Company Service Providers", Companies Registry License Application Information Leaflet, Hong Kong Electronic Legislation Anti-Money Laundering and Counter-Terrorist Financing Ordinance
12. Relevant regulations, Regulatory information and further reading
| Data category | Related information |
|---|---|
| Professional interpretation |