1. Core statutory access conditions for Hong Kong MVNO license application
Corporate entities and foreign investment access
Applicants can be Hong Kong registered companies or registered non-Hong Kong companies，and submit corresponding company registration and business registration documents。The current SBO application form does not list a unified upper limit of foreign investment ratio.，but control、The entity and actual operating arrangements are still reviewed according to license conditions。
Network interconnection prerequisites
Application information must describe how to access the Unified Carrier Licensee network to which mobile spectrum is allocated，and interconnection、Capacity and service arrangements。The form and final submission time of cooperation documents shall be confirmed according to the notification from the Business and Communications Bureau，Do not write a certain MoU as a unified decisive element。
Financial and Capital Capacity Review
The application form requires established companies to provide audited financial information for the last three complete financial years.，and require the new company to provide equity、Bank confirmation and/or holding company financial information，As well as proof of budgeted profits and losses and capital investment capacity in the first three years；There is no unified “12-month” statutory number。
Technical architecture and local support
An accurate system network topology diagram must be submitted，Clearly describe core network equipment (such as billing、exchange、HLR, etc.) configuration、Transmission protocol and line capacity with MNO，and details the local technical support team structure and daily maintenance procedures.。
2. Hong Kong MVNO License Comparison The Differences of Hong Kong SBO License
| Compare dimensions | Hong Kong SBO License (Services-Based Operator) | Hong Kong MVNO License (Mobile Virtual Network Operator) |
|---|---|---|
| Definition and affiliation | Large classification license：A general term for all telecommunications licenses that are "service-based" and do not build their own underlying physical infrastructure.。 | subcategory license：Belongs to the “Third Class Services” under the SBO license 3 Service）”。 |
| Core business areas | Very broad coverage，include： • Local Voice Redirect (Category 1) • Internet access ISP (Type 2) • International Telecommunications ETS/MVNO (Category 3) |
scope focus，Specifically refers to the "mobile virtual network operator" business： • Provide mobile communication services (monthly plan/SIM card) • Provides mobile roaming data and Internet of Things (IoT) cards |
| Internet resource sources | Wholesale bandwidth can be rented from fixed network operators (FTNS) or mobile network operators (MNO)、line or capacity。 | Mobile network capacity must be purchased wholesale from mobile network operators (MNOs) that own the radio spectrum。 |
| Number resource permissions | The types of services that can be applied for specifically，Apply to OFCA for allocation of a local fixed-line telephone number or international dialing code。 | You can apply to the Communications Authority (OFCA) for allocation of mobile phone number resources (such as Hong Kong mobile phone numbers prefixed with 5/6/9)，And supports number portability (MNP)。 |
| Typical business scenarios | Enterprise line、IDD International Call、Network data center access、VoIP。 | Retail/Corporate Mobile Phone Monthly Plan、Local/roaming SIM card、Cross-border one-card, two-number service。 |
| Typical business form | local voice、Internet access、International Telecommunications and Other Service Providers Business | Mobile communications resale、IoT connection、Roaming data and corporate SIM services |
References：Communications Authority"List of Service Operator License Holders" Apr 2026 data
3. Statutory fee structure for Hong Kong MVNO license application
| Expense items | Amount (HKD) | illustrate |
|---|---|---|
| MVNO Category 3 service fixed fee | 750 per year | "Service Operator License Validity Period and Fees" set out，MVNO services belong to the third category of services with an annual payment of HK$750.。 |
| User number fee | 3 per user number | According to the CA’s charging documents and license conditions，Charges are calculated on user numbers assigned or assigned to licensees。 |
| performance bond | upon written request | The CA may require a bank performance bond according to license conditions；There is no uniformly fixed level of HKD 100,000 or HKD 200,000 for official license conditions.。 |
4. Statutory approval process for Hong Kong MVNO license application
1. Preparatory stage
Prepare detailed business plans and technical solutions，And reached a cooperation intention with the target MNO，Obtain a signed interconnection agreement or memorandum of understanding。
2. Submit application
Complete statutory form OFCA A825，Together with a full set of supporting documents (subject qualification、financial statements、Technology blueprint、Real-name registration plan, etc.) shall be submitted in confidential form to the Office of the Communications Authority。
3. official review
OFCA conducts multiple rounds of written inquiries，Focus on reviewing technical feasibility、Financial soundness and compliance mechanisms。Applicants must promptly、Accurately respond to all questions。
4. Approved in principle
The CA may specify the licensing conditions that need to be completed when the application materials are basically acceptable.，For example, network、Number、system、warranty or other document；Whether to issue in-principle approval and its contents will be notified on a case-by-case basis，Not intended as a fixed phase commitment。
5. Officially issued
After the CA confirms receipt of the deposit and final documents，The third type of service authorization of the service operator license (SBO Licence) is officially issued，The applicant officially becomes a licensed MVNO。
5. List of core materials required for Hong Kong MVNO license application
Certificate of Incorporation (CI)、Business Registration Certificate (BR) and latest Annual Return (NAR1)
Audited financial statements or bank credit certificates for the last three complete fiscal years (new companies must submit three-year audit reports of the holding company)
Budgeted income statement for first three years of proposed MVNO service，Covers capital expenditure、interconnection fee、operating costs、Estimated users and revenue
Interconnection agreement or memorandum of understanding with at least one licensed MNO in Hong Kong
High-precision system network topology diagram，Detailed list of core device settings、transport protocol、Signaling and capacity planning
Fully compliant phone card real-name registration system solution，Comply with the Telecommunications (Registration of Subscriber Identity Cards) Regulations
Customer Personal Data Privacy Protection Policy and Fraud Prevention Code of Practice
6. Special compliance red lines and risks for Hong Kong MVNO license application
[Performance Bond] The CA may require the MVNO licensee in writing to provide a performance bond issued by a recognized bank or an approved guarantor in accordance with the license conditions.；Amounts and conditions are subject to written request，Fixed grades should not be preset based on online articles。
【Exit Arrangement】Applicable codes of practice must be followed when stopping services、Licensing conditions and CA requirements for customer notification，Process number portability、Arrangements such as refunds and customer service hotline；The specific deadline should be based on current official documents.。
[SIM card real-name registration] If the service involves user identification card，Must comply with the Telecommunications (Registration of Subscriber Identity Cards) Regulations and OFCA’s current system requirements。Insufficient data or systems may result in supplementary parts、Correction or disapproval，Outcome is determined on a case-by-case basis。
[Private transfer prohibited] License is a legal personal right，Not transferable without CA's written approval、sell、Lease or transfer in any form，Change of control must be applied for and approved in advance。
[Testing and Supervision Cooperation] Licensees must provide test accounts in accordance with the license conditions and the Communications Authority’s written requirements、SIM card、Technical information or other regulatory assistance；quantity、the term、Fees and monitoring methods are subject to current conditions and case notifications。
7. Hong Kong MVNO License Application Frequently Asked Questions (FAQ)
No。The Hong Kong Communications Authority does not have a separate license type named "MVNO"。Operators planning to provide mobile virtual network services，You must apply for the "Third Class Service (Class)" under the "Service Operator License (SBO License)" in accordance with the law. 3 Services)" authorization，Only those with legal operating qualifications。
Hong Kong registered companies and registered non-Hong Kong companies can apply according to Form A825。The current table does not list a unified upper limit of foreign investment ratio.；main body、Controls and business arrangements must still be truthfully disclosed and comply with license conditions。
The MVNO license itself does not allocate radio spectrum，and provide services using the radio infrastructure of licensed mobile network operators。The MVNO shall not operate radio base stations based on this SBO authorization.；If the business intends to use the spectrum or set up radio equipment on its own，The corresponding license must be separately evaluated。
Applicants must demonstrate operational network access、Interconnection and Capacity Arrangements。Initial cooperation materials、The final agreement and submission time should be based on actual commercial arrangements、A825 requires confirmation of written notification from the Communications Authority，There is no promise that the LoI will necessarily be sufficient or that it will be handled in the same way without a final agreement.。
The legislation and current SBO forms do not list a uniform minimum registered capital，But the share capital will be reviewed、Bank information、audit report、Budget and capital investment capacity for the first three years。The final financial allocation must match the business size and risk。
The performance bond is not automatically fixed at HK$100,000 or HK$200,000 based on the number of customers.。According to the service operator license conditions，The CA may, when necessary, require the licensee in writing to provide a bank performance bond，Amount、The guarantor and applicable conditions are subject to the written request and license document.。
Cannot stop taking it directly。Suspension of services should be in accordance with applicable codes of practice、Licensing conditions and CA requirements for customer notification，Arrange number portability、Refunds and inquiries，And check the specific deadline with current official documents。
Yes，This is the top priority of current supervision。According to the Telecommunications (Registration of Subscriber Identity Cards) Regulations，Applicants must submit their license application，Prove to OFCA that it has deployed an electronic real-name registration system that fully complies with statutory standards。The system has not been confirmed to be compliant by OFCA.，The competent authority may require additional、Correction or disapproval；The specific results are subject to review by the competent authority.。
Is it necessary to provide a test SIM card?、Quantity and time limit，The license conditions and written requirements of the Communications Authority shall prevail.。Licensees must provide testing resources and regulatory assistance as required，However, this page does not regard the fixed quantity and one-month period in the old information as the unified current conditions for all cases.。
The SBO license is valid for two years。The current fixed fee for MVNO Category 3 service is HK$750 per year；It may also involve a number fee of HK$3 per user number and a performance guarantee required in writing by the CA.。
The SBO license is valid for two years，and may be renewed for a period of two years at a time at the discretion of the CA。续期、Payment and information updates must be made in accordance with the current requirements of the Communications Authority before expiration.。
Absolutely prohibited。License is a personal right，Highly personal attachment。Without the prior written approval of the Communications Authority，The licensee shall not transfer the license in any form、sublet、Subcontract or dispose to any third party。If the company undergoes a change of control (equity transfer results in a change of actual controller) without prior approval from OFCA，will be considered a serious violation。
8. The latest regulatory developments for MVNO licenses in Hong Kong
- Keep checking
MVNO’s real-name registration、Stop service arrangement、License conditions and fees may vary depending on updates to applicable services and regulatory documents。Before applying or operating, you shouldCommunications Authority Service Operator License Official Page、Current license conditions and written notification shall prevail。
9. Hong Kong MVNO License｜Typical application preparation scenario (does not represent specific customer cases)
IoT companies evaluate MVNO business models
Enterprises first determine target users、Network cooperation model、Number requirements、System architecture and customer support arrangements，Then prepare application materials for service operator license based on this。
This is a general preparation scenario，Does not represent specific customers、Approval cycle or application results。Actual requests will be reviewed by the Communications Authority on a case-by-case basis。
Verification of application documents for cross-border communication services
Applicants should arrange cooperation with basic network providers、three-year financial forecast、Network topology、The real-name registration and customer protection plans correspond to OFCA A825 form and related license conditions item by item.。
This is a general preparation scenario，Does not represent specific customers、Approval cycle or application results。Actual requests will be reviewed by the Communications Authority on a case-by-case basis。
10. Hong Kong MVNO license information sharing：
11. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
|---|---|
| Related licenses |
