one、What is a Hong Kong trust company “license”?
From the perspective of regulatory practice，What the market often calls “Hong Kong Trust Company License”，Usually refers to the compliance business qualifications that have completed the relevant registration of a trust company in Hong Kong and complied with the requirements of applicable laws and regulations such as the Trustee Ordinance.。Need special emphasis：There is no “universal trust license” in Hong Kong that can replace all financial activities。
If the institution also provides asset management、Securities distribution、Virtual asset services、Remittance and exchange services，Other regulatory licenses or registrations may be required，For example a bank、SFCRelevant licenses or MSO, etc.。We will first do business boundary mapping，Then provide a phased landing path，Avoid passive rectification at a later stage。
Further reading：Hong Kong banking license、Hong Kong VASP License、Hong Kong Money Lenders License。
two、Application subject threshold and governance requirements
Articles of Association、Business scope、The fiduciary responsibilities and the actual business model must be consistent，Avoid inconsistency between nominal trust and actual business。
Requires background and integrity checks，Focus on funding sources、Historical compliance records、Are there any major lawsuits or regulatory penalties?。
Establish a record of trustee decisions、Conflict of Interest Management、Investment Authorization Matrix、Beneficiary communication and information leaving mechanism。
Customer due diligence should be formed、Continuous monitoring、Suspicious transaction identification、Sanctions Screening、Closed loop of record keeping and employee training。
Can the trust structure open an account smoothly?，Depends on business description、Transaction logic and compliance document completeness。
Tax residency status needs to be assessed simultaneously、Beneficiary Breakthrough Disclosure、Automatic exchange of information and anti-tax avoidance implications。
For mainland entrepreneurs or family offices，It is recommended to combine the trust company structure and the holding structure、family charter、Synchronous design of tax residence planning。Can be combinedRed chip architecture constructionandOffshore tax optimizationadvance together，Reduce subsequent restructuring costs。
three、Processing process and expected cycle
Sort out customer types、Funding path、Product form and cross-border flow，Confirm whether other licenses need to be superimposed。
Complete company establishment、Articles of Association Amendment、Equity Penetration Instructions、Directors’ due diligence documents and draft fiduciary governance system。
Build AML/CTF、KYC、Transaction monitoring、Compliance reporting and outsourcing management mechanism，Identify responsible persons。
Submit relevant registration or license application materials according to business scenarios，Respond to regulatory questions and supplement documentation。
Complete bank account opening、System traces、Contract template and beneficiary disclosure process，Conduct stress testing。
Perform audits on an annual basis、training、Policy review and risk assessment，Ensure continued compliance as your business expands。
Four、Expense budget and cost structure
Hong Kong registered trust companies and TCSP licenses belong to two different systems，Expenses and capital should be budgeted separately。Registered trust company in accordance with Part VIII of Chapter 29 of the Trustees Ordinance；TCSP is based on Chapter 615 of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance.。TCSP does not automatically authorize custody of all virtual assets、Securities management or deposit-taking business。
| System and cost items | Amount or calculation method (Hong Kong dollars) | Nature and verification instructions |
|---|---|---|
| Registered trust company：Issued and paid-up share capital | At least 3,000,000，And at least 3,000,000 is fully paid in cash | Entity and capital conditions；Not an application fee paid to the government |
| Registered trust company：Deposit or bank guarantee | Arrange a deposit of at least 1,500,000 according to the guidelines，or an accepted bank guarantee | Deposits should be made in the name of the Director of Accounting Services and with a designated institution；Need to meet additional solvency requirements |
| Registered trust company：Application fee | 11,250 | Official registration application fee |
| Registered trust company：Issue a certificate of registration | 840 | separate from application fee；If the application is unsuccessful, you can apply for a refund of this fee according to the guidelines. |
| Registered trust company：Follow-up maintenance | Report by company、Audit and applicable obligations are accounted for separately | The cited registration guidelines do not include an annual renewal fee of $5,200.，Do not classify unsubstantiated amounts as statutory charges |
| TCSP：First time application | 3,440，975 for each person subject to a fit and proper test | Application fee；Not “first year annual fee” |
| TCSP：License renewal application | 2,910，975 for each person subject to a fit and proper test | The license is usually valid for three years；Renewal application must be made at least 60 days before expiration，Not renewed every year |
| TCSP：Add final owner、Partner or Director Approval | 1,140 per person | Determined separately from initial application and license renewal fees |
| TCSP：capital budget | The licensing system does not provide for a uniform statutory minimum capital amount | Actual operating resources still need to be assessed，The 3 million threshold for registered trust companies cannot be applied |
| consultant、law、Audit and operating costs | by subject、The service scope and actual quotation are agreed separately. | Not an official fee；including offices、personnel、Systems and necessary professional services |
| Licensed company acquisition and due diligence costs | Determined based on actual transactions and due diligence results | Not based on unsubstantiated fixed market price ranges，or “debt-free” description in lieu of due diligence |
Check the information on this table：2026October 22。in accordance withCompanies Registry：Guidelines for Registering a Trust CompanyandTCSP Licensing Guidelines Chapter 15 Fee Schedule；Fees are subject to the latest official regulations at the time of submission.。Company established、Business registration、capital、deposit、official fees、The purchase price and professional service fees cannot be mixed into a single "license fee"。
five、HKIT deliverables
Output license plate boundaries、regulatory mapping、Implementation path、Key risks and time budget。
Covers company documents、Governance documents、AML policy、Due diligence template、Business description and inquiry response draft。
Assist in preparing questions and answers、Supplement logic and evidence chain，Facilitate communication with authorities and maintain data on an ongoing basis。
Optimize information presentation around KYC requirements，Help companies explain their business more clearly、Funding sources and controls；Account opening and follow-up services are still independently reviewed by the bank。
Provide institutional updates、Internal training、Sampling review and rectification suggestions，Reduce compliance risks during operation。
with offshore companies、fund、Private Banking and Tax Structure Synergy，Form a scalable international business base。
If you plan to simultaneously promote overseas structures，Extendable planning：Offshore Funds、Offshore bank account opening、Singapore bank account opening。
Ongoing responsibilities after registration of a trust company
The registration of a trust company and the conduct of regulated trust or company service activities should be checked separately。fiduciary duties、customer assets、record keeping、Beneficial ownership and AML/CFT controls should be consistent with actual service scope。
- Clarify the principal、trustee、protector、Beneficiaries and investment or distribution rights。
- Distinguish between company's own funds and trust assets，retained valuation、Authorize、Payment and Conflict of Interest Records。
- control occurs、director、Evaluate reporting obligations promptly when registered address or service scope changes。
Official verification：Hong Kong Companies Registry Trust Company Information、Hong Kong TCSP licensing system。Application conditions、cost、Time limits and continuing obligations are subject to the latest rules and case facts at the time of filing by the competent authority.。
TCSP and registered trust company：Prepare according to two systems
| Comparison matters | TCSP license | Registered trust company |
|---|---|---|
| Institutional basis | Licensing regime for trust or company service providers under AMLO Chapter 615 | Trust company registration under Part VIII of Chapter 29 of the Trustees Ordinance |
| business judgment | Established corporation、Appoint director or secretary、Provide registered address、Serving as express trust trustee and other services，Judgment based on statutory definitions and exemptions | According to the subject of registered trust company、Charter、Judgment of capital and deposit/guarantee conditions |
| People and Maintenance | suitable person、Approval for adding new personnel、Change notification、Customer due diligence and record keeping, etc. | Company qualifications、capital、Articles of Association and ability to perform obligations are checked according to corresponding regulations. |
| business boundaries | Asset management is not automatically authorized、Taking deposits or all virtual asset custody business | Nor does registered status automatically replace financial licensing or other regulated qualifications |
A service list can be provided before consultation、Customer type、whether to act as trustee、Whether to hold or control assets、Charges and the main form to be used。Simply writing "I want to be a trust" is not enough to determine the application path；Nor can it be judged that a company has obtained relevant qualifications just because its name contains Trust.。
Company secretarial services and trust structures may involve different roles and responsibilities。Can be referenced separatelyHong Kong company secretarial servicesandOffshore trust establishment，But ultimately the contracting entity should、actual server、Professional qualifications and the coordination scope of Hong Kong Information Communication are clearly stated。
Check the information in this section：2026October 22。Companies Registry：TCSP Licensing Guidelines；Companies Registry：Guidelines for Registering a Trust Company。The following are suggestions for preparation，Specific requirements should be determined according to the applicant、Check business model and applicable rules。
six、Frequently Asked Questions about Hong Kong Trust Company License(FAQ)
no the same。A registered trust company shall be registered in accordance with the Trustee Ordinance；TCSP is the licensing system for trust or company service businesses under the Anti-Money Laundering Ordinance，Must be judged separately。 SeeCompanies Registry：Conditions and fees for registering a trust company。
no。Official definition includes acting or arranging for others to act as trustee of an express trust，It cannot be called TCSP in general. Only introduction is allowed.、Not allowed to serve as trustee；Specific assets and financial businesses will be assessed separately.。 SeeCompanies Registry：TCSP Licensing Guidelines。
The specified company specified in the Companies Registry’s guidelines does not include Article 1 of the Companies Ordinance. 11 Article private company，Must meet the registration subject and charter purpose conditions。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Current guidance includes eligible re-domiciled companies as specified companies，But still excludes private companies and is subject to other conditions。 SeeCompanies Registry：Conditions and fees for registering a trust company。
At least 300 10,000 Hong Kong dollars，of which at least 300 Must be paid in full in cash，and provide written confirmation from the directors；Not a general TCSP unified capital threshold。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Must be deposited in the name of the Director of Accounting Services in accordance with the guidelines for at least 150 10,000 Hong Kong dollars，or submit an accepted bank guarantee，And complete the corresponding confirmation and documentation procedures。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Guidance requires that obligations other than shareholders be fulfilled even if such deposits are not included.，Must be confirmed in writing by directors。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Official registration guidelines require the formal appointment of the board of directors in accordance with the articles of association，at least two directors。 SeeCompanies Registry：Conditions and fees for registering a trust company。
"Trustee Ordinance" 100 In principle, a single member's shareholding is limited to no more than one-fifth of the issued capital.，Exceptions such as bank subsidiaries must be checked specifically。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Official guidelines list application fees 11,250 Hong Kong dollar、Fee for issuing certificate of registration 840 Hong Kong dollar，total 12,090 Hong Kong dollar；Not about the old FAQ 5,200 Hong Kong dollar。Capital and margin are additional。 SeeCompanies Registry：Conditions and fees for registering a trust company。
The official basis is upon receipt of application or confirmation of deposit from the Director of Accounting Services，Usually, whichever is later 10 working days；Does not include preliminary preparation，Nor is it a guarantee of approval。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Guidelines cover sole proprietorships、Entities such as partnerships and corporations，And conduct appropriate candidate review for relevant personnel according to the type of subject.。 SeeCompanies Registry：TCSP Licensing Guidelines。
Covers sole proprietors by entity type、Partner、Directors and ultimate owners，with certain exemptions；You cannot just ignore other control arrangements based on shareholding ratio.。 SeeCompanies Registry：TCSP Licensing Guidelines。
The application fee is listed in this verification guide 3,440 Hong Kong dollar，Each person who is subject to a fit and proper test 975 Hong Kong dollar，Fees are non-refundable，Based on the current period table。 SeeCompanies Registry：TCSP Licensing Guidelines。
Usually valid for three years；Must be at least before expiry 60 Apply for renewal within days，Cannot be used before expiration 45 to 60 old expression for day。 SeeCompanies Registry：TCSP Licensing Guidelines。
cannot。Approvals must be obtained in advance according to the licensing guidelines and suitable candidate information must be submitted.，There is also a notification obligation for changes in other information.。 SeeCompanies Registry：TCSP Licensing Guidelines。
Must truthfully declare business and storage record arrangements and cooperate with regulatory inspections，Compliance cannot be presumed based on an address，You can’t make it up that all applications require the same kind of independent office.。 SeeCompanies Registry：TCSP Licensing Guidelines。
Can't。Additional assessment of SFC authority is required when regulated activities such as securities are involved，TCSP does not replace a financial business license。 SeeCompanies Registry：TCSP Licensing Guidelines。
trust document、Fiduciary responsibilities and identification of applicable rules、Keep and record property，Client assets cannot be used as personal or company working capital without authorization.。 SeeCompanies Registry：Conditions and fees for registering a trust company。
Customer due diligence still needs to be performed in accordance with applicable regulations、record keeping、Internal control and regulatory inspection obligations，Certificates are not a substitute for ongoing compliance。 SeeCompanies Registry：TCSP Licensing Guidelines。
