You apply to Hong Kong Customs, not the HKMA, with Form 1, a business plan and an AML/CFT policy. A bank account is not a precondition: without one, the business plan must explain how you will operate; with one, the bank must confirm it is used for your money service. You also need a Compliance Officer and MLRO on your staff, and at least one director must pass Customs' Competence Assessment.
Four numbers before you apply for a Hong Kong MSO licence
Part of Substance, cost and risk: how the Money Service Operator (MSO) application works. Whether an MSO can carry crypto is a separate question: see Can an MSO or MSB cover a crypto business?
Key takeaways
- No bank account is required to apply, but the business plan must explain how you will run without one. Third-party accounts are not allowed.
- A company secretary's, accountant's, solicitor's or home address is not accepted as your local office or records store.
- Customs' Licensing Guide sets no minimum capital. The "HK$500,000 minimum" seen online is an agency website's figure, not Customs'.
- Customs' register listed 613 licensees on 12 November 2026; 271 of them hold a correspondence address only.
On this page9 sections
What does Customs require before it will process an application?
A company needs fit and proper directors and owners, a Compliance Officer and MLRO, a director who passes the Competence Assessment, registered premises or a local office, and the paperwork below, before it starts money changing or remittance. The conditions are in Customs' MSO Licensing Guide (May 2026):
Hong Kong MSO licence: what a corporate applicant needs
| Requirement | What the Licensing Guide says |
|---|---|
| Fit and proper people | Every director and every ultimate owner (anyone holding more than 25% of the issued share capital) |
| Compliance staff | A competent Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO); failing to appoint one is a refusal ground |
| Competence Assessment | Directors sit it; the application is refused if none of senior management passes |
| Places | Registered premises, or a local management office (LMO), correspondence address and local place for storage of books and records (LPS) |
| Paperwork | A valid Business Registration Certificate; Form 1 with its supplementary sheet and annex; a Business Plan; an AML/CFT policy |
Do you need a bank account before you apply?
No, but you cannot leave the question blank. Item 8 of Customs' business plan guidelines asks for every account the business will use, with its number and owner, and states that no third-party bank account is allowed. If you see no need for an account, you must give details of how the company will provide its money service without one.
If you do use an account, the document checklist asks the bank for two things:
- proof of bank account ownership, such as a statement;
- an acknowledgement that the account is used for operating a money service business.
Once licensed, the account must be in the name of the company or its sole proprietor, partner, director or ultimate owner. The wider banking picture is in Can a licensed crypto business actually open a bank account?
Can you use a company secretary's address?
No. An MSO either operates at registered premises, such as a shop, or without particular premises, for example by transacting on mobile devices. Without premises you must provide an LMO, a correspondence address and an LPS, and paragraph 4.7 of the guide is explicit:
"residential address/premises of an MSO or the address/premises of its service provider (if any), such as company secretarial firm, accounting firm, or solicitor firm, etc. will not be accepted by the CCE as the LMO of an MSO."
The same rule applies to the records store. The people at the LMO must be the sole proprietor, a partner, a director, an ultimate owner or the CO; the landlord must permit money service use; and an application without LMO details is invalid. Registered premises cannot sit in a wholly residential building or be shared with another MSO.
Running without a shop is common. On 12 November 2026 the Customs register of licensees listed 613 licensees: 271 (about 44%) with a correspondence address only, and 342 with registered premises, 798 premises in all. Each of the 271 still needs a real LMO. Other jurisdictions are compared in Local substance requirements explained.
Who can be the Compliance Officer and MLRO?
The CO and MLRO must be your employees under the Employment Ordinance, unless the sole proprietor, a partner, a director or an ultimate owner takes the roles. The checklist asks for each one's Hong Kong Identity Card copy and a valid employment contract. Customs' AML/CFT Guideline for MSOs (paragraphs 3.7 and 3.8) puts the CO at management level and the MLRO among senior staff, and expects both, as far as practicable, to be:
- appropriately qualified with sufficient AML/CFT knowledge;
- independent of all operational and business functions, subject to the size of the business;
- normally based in Hong Kong;
- of a sufficient level of seniority and authority within the MSO.
A non-resident director or owner submits Form 3A and their travel document's bio-data page, but an LMO must be staffed by a director, owner or the CO. See also glossary: AML Officer and glossary: MSO.
Is there a minimum capital?
Not in the Licensing Guide: its eligibility section names no capital figure. The business plan is where money comes in. It must cover the company's source of capital, the entire transaction process including fund flows, expected margin and turnover for two years, and the running capital for daily operations.
Figures quoted elsewhere are not Customs' rules. A Chinese-language agency page states a HK$500,000 minimum liquid capital and a HK$8,500 application fee; a consultancy suggests HKD 100,000 to 500,000 of paid-up capital and calls it, in its own words, "a planning recommendation, not a statutory minimum".
What happens after you submit?
- File Form 1, the supplementary sheet and annex, the Business Plan and the AML/CFT policy, in English or Chinese. Premises applications attach at least two 4R (102x152 mm) photographs.
- Supply anything outstanding within the specified period, or the application is treated as invalid.
- Once complete, you receive an interview notice and a demand note for the fees.
- At the interview, the application is signed in front of Customs officers.
- Directors sit the Competence Assessment; at least one must pass.
- The Commissioner decides. A refusal can be appealed to the Review Tribunal within 21 days of the notice.
The guide commits to no timetable: processing time "may vary", and we do not forecast it. If an application fails, see What happens if your licence application is rejected.
What does it cost in government fees?
A company whose two directors are also its only two ultimate owners, with no extra premises, pays Customs HK$5,700 (HK$3,810 plus 2 x HK$945), then HK$2,800 at each renewal. Fees are non-refundable, even if the application is refused, and exclude professional fees.
Customs fees for an MSO licence
| Item | Fee |
|---|---|
| Grant of a licence | HK$3,810 |
| Plus, each person subject to the fit and proper test | HK$945 |
| Plus, each additional business premises | HK$2,440 |
| Renewal | HK$910, plus HK$945 per fit and proper check and HK$410 per additional premises |
What do you owe Customs once licensed?
- Renewal: a licence normally runs 2 years; apply to renew at least 45 days before expiry. Customs sends a reminder 90 days before.
- Periodic returns: within 2 weeks beginning from each half year; late filing can mean suspension or revocation.
- Change notices: changed particulars, including the business bank account, go in on Form 6 within one month.
- Prior approval: a new director needs written approval first; breach is liable on conviction to a HK$50,000 fine and 6 months' imprisonment. See Who can own a licensed crypto company?
- Actually operating: never providing a money service is one of the guide's examples of grounds to revoke, and disciplinary penalties reach HK$1,000,000.
Year-two duties are compared in Keeping a crypto licence.
Frequently asked questions
What does a Hong Kong MSO licence cover?
Money changing, and remittance: sending money to, or receiving money from, a place outside Hong Kong. Operating without a licence is an offence: on conviction on indictment, up to HK$1,000,000 and two years' imprisonment.
Can a non-resident be a director of an MSO?
Yes: a non-resident director or ultimate owner submits Form 3A and their travel document's bio-data page. Without registered premises, the LMO must be staffed by a director, owner or the CO, and the CO and MLRO give Hong Kong Identity Card copies.
Sources: Customs' MSO Licensing Guide (May 2026), business plan guidelines, AML/CFT Guideline and register of licensees, read on 13 November 2026. Not legal advice. CryptoLicense is a licensing advisory brand of CL GLOBAL SDN BHD (1421939-T); Hong Kong is one of the 12 jurisdictions we cover. Whether a licence is granted, and how long a regulator takes, is at the regulator's discretion and we promise neither. Start with licence selection and the jurisdictions overview; who we are is on the entity proof page.