1. Core statutory access conditions for Hong Kong MVNO license application
Corporate entities and foreign investment access
The applicant must be a local limited company incorporated under the Companies Ordinance (Chapter 622) of Hong Kong，Or a non-Hong Kong company that has been legally registered。The license does not impose any restrictions on foreign shareholding ratio，fully open to the outside world。
Network interconnection prerequisites
Before being officially issued a license，Applicants must submit a duly signed Interconnection Agreement (Interconnection Agreement) or Memorandum of Understanding (MoU) with at least one Hong Kong licensed entity Mobile Network Operator (MNO)，This is a decisive factor for approval。
Financial and Capital Capacity Review
Applicants must demonstrate sufficient financial resources to maintain the business for at least 12 months。Must submit audited financial statements for the past three years (if established) or bank credit certificate (if newly established)，and stating capital expenditures、Detailed "Budget Profit and Loss Statement" for the first three years of operating costs and profit forecasts。
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。 | Must contact the mobile network operator (MNO) that owns the radio spectrum (such as HKT、CMHK、SmarTone、3Hong Kong) wholesale purchase of mobile network capacity。 |
| 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 representative companies/brands | • Front line (DYXnet) • Worldwide telecommunications (HGC) • Hong Kong Broadband Network (HKBN)(Lineline/ISP part) |
• China Unicom (Hong Kong)(CUniq) • free bird (Birdie)(Part of SmarTone) • Club Sim (owned by HKT) • Hong Kong Broadband (HKBN)(Mobile Communication Section) |
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 |
|---|---|---|
| Fixed annual license fee | 750 | Pay annually |
| Mobile station (customer connection point) change fee | 500 / per 100 mobile stations | Calculated based on the number of active SIM cards/mobile stations |
| Performance Bond (Customer ≤ 100,000) | 100,000 | issued by a recognized bank，One-time deposit |
| Performance Bond (Customer > 100,000） | 200,000 | issued by a recognized bank，One-time deposit |
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
After reviewing that the application materials are complete and meet the requirements,，The Communications Authority issues a letter of approval in principle (Approval in Principle, AIP），At this time, the applicant must pay a performance bond and implement the final interconnection agreement。
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
[Mandatory Performance Bond] A performance bond issued by a recognized bank must be deposited with the Hong Kong government (customers less than 100,000 Hong Kong dollars)，(more than 200,000 yuan)，No license will be issued before payment is made。
[Strict Exit Mechanism] The suspension of services must be notified to the public at least 1 calendar week in advance and sales must be suspended，Maintain number portability (MNP) and customer hotline for at least 3 months after suspension of operations，Otherwise, the deposit will be forfeited in full，In addition, a maximum fine of HK$200,000 may be imposed。
[SIM card real-name registration] An electronic real-name registration system must be established and confirmed by OFCA，The license application will be directly rejected if the system does not comply with the regulations.。
[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。
[Mandatory Network Monitoring] Within 1 month of service launch, you must provide 2 test SIM cards to OFCA at your own expense，For the government to monitor network operations around the clock，Violators will be prosecuted。
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。
Can apply directly，And there will be absolutely no restrictions on foreign shareholding ratios.。Companies registered overseas must register non-Hong Kong companies in accordance with the Hong Kong Companies Ordinance，After obtaining the business registration certificate，Submit an application to the Office of the Communications Authority (OFCA) in this capacity。Natural persons cannot apply directly。
Absolutely not。According to the law，MVNO is defined as a non-facility-based operator，Its fundamental business model is to provide services through radio infrastructure connected to licensed entity mobile network operators (MNOs)。MVNOs are not allocated any radio spectrum，nor may you set up or operate any radio base station。
Must be provided before final licensing，However, a Letter of Intent (LoI) or Memorandum of Understanding (MoU) can be used instead for initial submission.。Before the CA issues the “Approval in Principle” (AIP) and officially issues the license，Will confirm the signed interconnection agreement。If it is still unable to prove that it has been supported by MNO network capacity，Application will be rejected。
No hard minimum capital amount is set，However, OFCA will conduct a very stringent substantive financial review。Applicants must pass bank certification、Parent company guarantee and detailed budgeted profit and loss statement for the first three years，Strong evidence of the financial capacity to sustain the business for at least 12 months。
To protect the public interest，Prevent consumers from suffering losses due to the sudden collapse of MVNOs。According to the "Code of Practice on Service Discontinuation Arrangements by Mobile Virtual Network Operators"，MVNO licensees are required to submit to the Hong Kong government an irrevocable performance guarantee issued by a recognized bank。The margin amount is set at HK$100,000 (≤100,000 users) or HK$200,000 (>10million users)。
Absolutely prohibited。Legal exit procedures must be strictly followed：Send service suspension notice to all affected customers and the public at least 1 calendar week in advance and terminate sales immediately；The customer service hotline must be maintained for at least 3 months after the service is stopped to process refunds.，And maintain the "Number Portability Service" (MNP) function，Facilitate customer number portability and network transfer。Violations will result in the forfeiture of all security deposits and heavy fines。
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.，License applications will never be approved。
required。The MVNO must provide services within 1 month from the official launch date of the service.，Submit 2 test smart cards (Test SIMs) to the Office of Communications at your own expense，To allow government departments to monitor the actual operating status of their networks and services around the clock，This is a mandatory requirement for continued compliance。
License fees are a two-track system：One is the fixed annual license fee，HKD 750 per year；The second is the mobile station (customer connection point) change fee linked to business volume，Calculated based on the actual number of active SIM cards，An additional HK$500 is required for every 100 mobile stations.。Both fees are paid annually。
The statutory validity period of a service operator license is usually one year。As long as there are no major violations during the license period and the financial status is still good，The licensee may submit a renewal application to OFCA before the validity period expires.，And pay the annual license fee and corresponding change fee for the current year。After each renewal is approved,，The license will remain valid for 1 year。
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
- 2024-10-21
Communications Authority issues notice，All MVNO licensees are reminded to be familiar with and comply with the latest version of the "Code of Practice on Service Suspension Arrangements for Mobile Virtual Network Operators"，and emphasized the need to submit audited compliance reports on time，In particular, the proof of effectiveness of the real-name registration system。
- 2022-05-01
The revised version of the "Code of Practice on Service Discontinuation Arrangements for Mobile Virtual Network Operators" officially comes into effect，Extend the statutory customer protection period to at least 3 months in the event of sudden closure of an MVNO，and increased the fine limit for violations (maximum HK$200,000 for first violation)，At the same time, the performance bond utilization mechanism has been strengthened.。
9. Successful cases of Hong Kong MVNO license application
Mainland smart device manufacturers receive Full MVNO license in Hong Kong
The Hong Kong Huitong legal team represents a leading mainland IoT solution provider，Build a Hong Kong main company from scratch，Work closely with the technical team to write a full-featured MVNO business plan and network topology solution，Successfully assisted the customer to obtain SBO Class 3 authorization with independent MNC and phone number range within 4 months，Laying the foundation for customers’ own brand cross-border connection services。
Transnational travel SIM card brand license quickly approved
Hong Kong Huitong assisted a travel communications company with mature operations in Europe to enter Hong Kong，Accurate planning of reseller MVNO model，Efficiently coordinated the signing of interconnection agreements with two local MNOs，2.5Obtained approval in principle within months，And obtain the official license within 1 week after paying the deposit，Customers successfully launched Hong Kong local and cross-border one-card, multiple-number services before the peak tourist season。
10. Hong Kong MVNO license information sharing：
- 1、List of licensed mobile virtual network operators (MVNOs)-Office of the Communications Authority
- 2、SBO service operator license application guide-Office of the Communications Authority
- 3、Service operator license official page-Office of the Communications Authority
