Country-specific guidance Current
TCSP licensing and AML/CFT obligations overview
What counts as a trust or company service, and who's exempt from the licence itself.
Providing a registered office, acting as a nominee, or handling company secretarial work for other people can make your firm a trust or company service provider under Hong Kong law, whether or not that label feels like it fits. This guide sets out the licensing regime. It is general information, not legal or compliance advice.
Action plan
1 Know what counts as a trust or company service The definition is specific, and covers more than people expect.
Under section 1 of Part 1 of Schedule 1 to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, "trust or company service" covers providing a registered office, business address, correspondence or administrative address for a corporation, partnership, or other legal person or arrangement, as well as acting as a nominee shareholder or providing company secretarial services for other people, when done by way of business. Preparing annual returns alone, or leasing office premises, falls outside this definition.
- Check whether your firm provides a registered office, business address, or correspondence address for clients
- Check whether your firm acts as a nominee shareholder or director, or provides company secretarial services, for clients
- Note that preparing annual returns alone, or leasing premises, isn't itself a trust or company service
Done when: Your firm's services have been checked individually against the statutory trust or company service definition
Companies Registry: TCSP licensing requirements FAQ2 Check whether your firm needs a licence, or is exempt Accounting and legal professionals get a specific licensing exemption, but it isn't unconditional.
The TCSP licensing requirement, including the fit and proper test, does not apply to an accounting professional or a legal professional. In practice, a certified public accountant acting as a sole proprietor, a CPA firm, or a corporate practice as defined by the Accounting and Financial Reporting Council Ordinance is not required to apply for a TCSP licence. A partnership that isn't a CPA firm, where at least one partner isn't a certified public accountant, does need a licence, and the Registrar won't apply the fit and proper test only to the accounting-professional partners.
- Confirm whether your firm structure actually qualifies as an accounting professional under the exemption
- Check a mixed partnership carefully, since one non-accountant partner can trigger the licensing requirement for the whole partnership
- Don't assume every accounting-adjacent business automatically qualifies for the exemption
Done when: Your firm's TCSP licensing status, licensed or exempt, has been confirmed against the actual structure, not assumed
Companies Registry: TCSP accounting professional FAQ3 Remember CDD and record-keeping still apply, even if you're licence-exempt The licensing exemption and the underlying CDD duty are two separate things.
Being exempt from the TCSP licence itself doesn't remove your firm's separate statutory customer due diligence, ongoing monitoring, and record-keeping obligations as an accounting professional under the AML/CTF framework where you provide a specified service. A licensed TCSP is also required to continuously monitor a customer relationship under Schedule 2 to the AMLO, reviewing customer information to keep it up to date and relevant, a discipline worth applying even where your firm sits outside formal TCSP licensing.
- Don't treat a TCSP licensing exemption as removing your firm's underlying CDD obligations
- Apply ongoing monitoring to keep customer information current, not only at initial onboarding
- Document CDD and monitoring steps whether or not your firm holds a TCSP licence
Done when: CDD and ongoing monitoring are applied consistently, independent of the firm's TCSP licensing status
See the AML/CFT operating playbook for accounting firms