What Are Trust and Company Service Providers (TCSP)? Complete Guide (2026)

A Trust and Company Service Provider (TCSP) is a licensed business authorized to provide regulated trust and company services in Hong Kong, including company formation, registered office services, nominee arrangements, and trust administration. The TCSP licensing regime is administered by the Hong Kong Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615), which came into effect for the sector on 1 March 2018.

For businesses establishing or expanding operations in Hong Kong, working with a licensed TCSP helps ensure that corporate formation and administration are carried out in accordance with local regulatory requirements. The Hong Kong Companies Registry maintains a public register of licensed TCSPs, allowing businesses to verify a provider's licensing status before engaging its services.

This guide explains what Trust and Company Service Providers (TCSPs) do, who needs a TCSP licence, the licensing requirements and AML/CFT obligations under Hong Kong law, and how businesses can evaluate a regulated TCSP when expanding internationally.

What Services Do Trust and Company Service Providers Cover?

Under Schedule 1 of the AMLO, a TCSP is defined as a person who carries on a business of providing any of the following services as a regular business activity. The six regulated TCSP service categories are:

Company Formation and Incorporation: Forming companies, limited partnerships, or other legal entities on behalf of clients — including preparing constitutional documents, filing incorporation applications with the Companies Registry, and advising on the most appropriate corporate structure for cross-border operations.
Directorship and Company Secretary Services: Acting as, or arranging for another person to act as, a director, company secretary, or partner of a legal entity. Under the Companies Ordinance (Cap. 622), every private company in Hong Kong must have at least one director and one company secretary at all times.
Registered Office and Business Address Services: Providing a registered office address, business correspondence address, or administrative address for a company. This service is widely used by multinational enterprises and fintech platforms establishing a Hong Kong presence without a full physical office.
Nominee Shareholding: Acting as, or arranging for another person to act as, a nominee shareholder for a client. TCSPs providing this service must maintain accurate records of the ultimate beneficial owners they represent, in line with AMLO beneficial ownership transparency requirements.
Trust Services: Acting as a trustee, or arranging for another person to act as trustee, under an express trust — including family trusts, discretionary trusts, and purpose trusts used for asset protection, estate planning, and cross-border wealth structuring.
Nominee Partnership Services: Arranging for a person to act as a nominee partner in a limited partnership or general partnership, including maintaining associated regulatory filings and compliance documentation.

For businesses engaged in international business payments, a regulated TCSP is often the first structural step when establishing the right Hong Kong entity for cross-border payment flows.

Who Needs a TCSP License in Hong Kong?

The TCSP licensing requirement applies to any person who carries on a business of providing one or more of the six regulated service categories as a regular activity. Four types of businesses are most commonly affected:

Corporate Secretarial Firms: Professional firms offering company incorporation, registered office, and company secretarial services to local and offshore clients represent the largest segment of licensed TCSPs in Hong Kong.
Law Firms and Accounting Practices: Legal and accounting professionals who provide TCSP activities — such as trust setup, nominee directorship, or company formation — as part of their wider advisory offering must hold a TCSP license specifically for those regulated activities.
Family Office and Wealth Management Platforms: Entities structuring trusts, nominee holdings, or holding companies for high-net-worth clients must hold a TCSP license for any trust or nominee components of their service offering.
Fintech and Payment Platforms: Payment and fintech companies may require a TCSP licence if they provide regulated trust or company services—such as company formation, registered office services, or nominee arrangements—as part of their business activities.

There is no minimum transaction volume or revenue threshold that triggers the licensing requirement. The obligation arises from the nature of the activity itself, regardless of scale. Sole proprietors, partnerships, and corporations are equally subject to the TCSP licensing regime.

TCSP License Requirements and Application Process (2026)

The Hong Kong Companies Registry assesses TCSP applications against a "fit and proper" standard, evaluating the applicant's integrity, competence, and financial soundness. As of 2026, the following requirements apply:

Business Registration: The applicant must hold a valid Business Registration Certificate issued by the Inland Revenue Department (IRD). Foreign-incorporated entities providing TCSP services in Hong Kong must also register as a non-Hong Kong company under the Companies Ordinance (Cap. 622) before applying.
Fit and Proper Assessment: All directors, partners, and responsible officers must meet the Companies Registry's fit and proper criteria: no unspent criminal convictions involving dishonesty or AML/CFT offenses; no prior regulatory sanctions in any jurisdiction; and demonstrated professional competence and financial solvency.
AML/CFT Policies and Procedures: Applicants must submit written AML/CFT policies covering customer due diligence (CDD), transaction monitoring, suspicious transaction reporting (STR), beneficial ownership identification, and regular AML/CFT training. Policies must be reviewed at least annually and updated to reflect regulatory changes.
Ongoing Supervision: Licensed TCSPs are subject to on-site inspections by the Companies Registry and must submit annual returns confirming continued compliance. Licenses are issued on a continuing basis and may be suspended or revoked for compliance breaches or failure to maintain fit and proper status.

The 2026 fee schedule for TCSP licensing is as follows:

Fee Item	Amount (HKD)
TCSP License Application Fee	HK$3,160
Annual Renewal Fee	HK$3,160
Late Renewal Surcharge	HK$630 per month overdue

*Please refer to the latest fee schedule published by the Hong Kong Companies Registry.

The application is submitted online via the Companies Registry's eLicensing portal. Processing times vary depending on application completeness and regulatory review. For businesses requiring payment services alongside corporate structuring, understanding how TCSP and payment licensing interact is essential before commencing cross-border transactions through the new entity.

AML/CFT Compliance Obligations for Licensed TCSPs

The Financial Action Task Force (FATF) classifies TCSPs as designated non-financial businesses and professions (DNFBPs), recognizing the elevated money laundering and terrorist financing risks associated with corporate formation and nominee services. The AMLO subjects licensed TCSPs in Hong Kong to the same tier of AML/CFT obligations as regulated financial institutions. Key obligations include:

Customer Due Diligence (CDD): TCSPs must verify the identity of every client and, where the client is a legal entity, identify all beneficial owners who ultimately own or control 25% or more of the entity. CDD must be completed before any regulated service is provided, and ongoing monitoring must be maintained throughout the business relationship.
Enhanced Due Diligence (EDD): EDD is mandatory for politically exposed persons (PEPs), clients from FATF high-risk and monitored jurisdictions, and clients involving complex multi-layered corporate structures or nominee arrangements. EDD requires senior management approval before establishing or continuing the relationship.
Beneficial Ownership Records: TCSPs must maintain accurate and current records of the beneficial owners behind every corporate entity or trust they administer. These records must be available for inspection by the Companies Registry and law enforcement upon request.
Suspicious Transaction Reporting (STR): TCSPs that suspect — on reasonable grounds — that a transaction or business relationship involves money laundering or terrorist financing must file an STR immediately with the Joint Financial Intelligence Unit (JFIU), the joint body of the Hong Kong Police Force and the Customs and Excise Department (C&ED). Filing an STR does not constitute a breach of confidentiality obligations.
Record Retention: All CDD documents, transaction records, and relevant correspondence must be retained for a minimum of 6 years from the end of the business relationship or the date of the transaction, whichever is later.
Annual Staff Training: All staff involved in TCSP activities must complete AML/CFT training annually. The Responsible Officer is personally accountable for ensuring training records are current and available for regulatory inspection.

How PhotonPay Meets TCSP Compliance Standards

PhotonPay's corporate services entity, Photon Dance Consulting Limited, holds TCSP License No. TC010478, issued by the Hong Kong Companies Registry. This license authorizes PhotonPay to provide regulated trust and company services in Hong Kong under the full compliance framework of the AMLO. The following points outline PhotonPay's complete multi-jurisdiction compliance architecture:

TCSP License — Hong Kong: Entity: Photon Dance Consulting Limited | License No.: TC010478 | Regulator: Hong Kong Companies Registry (under AMLO, Cap. 615) | Scope: Company formation, registered office, nominee, and trust services in Hong Kong.
MSO License — Hong Kong: Entity: Photon Dance (Hong Kong) Limited | License No.: 15-04-01638 | Regulator: Hong Kong Customs and Excise Department (C&ED) | Scope: Money-changing and remittance services, enabling integrated corporate and payment services on a single regulated platform.
SFC Type 1, 4 & 9 Licenses — Hong Kong: Entity: Photon Dance Asset Management (HK) Limited | SFC CE No.: BWJ859 | Regulator: Securities and Futures Commission (SFC) | Scope: Dealing in securities (Type 1), advising on securities (Type 4), and asset management (Type 9).
Authorized Payment Institution — United Kingdom: Entity: Photon Dance Fintech UK Limited | FCA Reference No.: 801082 | Regulator: Financial Conduct Authority (FCA) | Scope: Regulated payment services under the Payment Services Regulations 2017 (PSRs 2017).
MSB Registration — Canada: Entity: Photon Dance CA INC. | FINTRAC Registration No.: M21161397 | Regulator: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) | Scope: Cross-border remittance and money services for Canadian operations.
Category 3D License — UAE (DIFC): Entity: Photon Dance (DIFC) Limited | DFSA License No.: F010944 | Regulator: Dubai Financial Services Authority (DFSA) | Scope: Authorized payment and financial services in the Dubai International Financial Centre (DIFC).
MSB Registration — United States: Regulator: Financial Crimes Enforcement Network (FinCEN) | NMLS Registration No.: 2756066 | Scope: Money services business operations across 11 US states, including Alabama and Michigan.
Small Payment Institution — Poland: Entity: Photon Dance (Poland) Limited | KNF Registration No.: 0000998751 | Regulator: Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) | Scope: EU-internal cross-border payment processing.

Additional Certifications and Infrastructure: SOC 2 Type I Certification for information security and operational controls, together with native Travel Rule compliance to support secure and compliant digital asset transactions.

PhotonPay operates under a multi-jurisdiction regulatory framework spanning Hong Kong, the United Kingdom, Canada, the United States, the UAE, Poland, the British Virgin Islands, and Switzerland. This regulatory foundation enables businesses to access trusted corporate and cross-border payment services through licensed entities that comply with applicable local regulatory requirements.

Clients requiring B2B international money transfers alongside corporate administration can access both services through a single licensed counterparty, reducing onboarding complexity and overall compliance overhead.

For context on how Hong Kong's regulatory environment is evolving for digital asset and payment service providers, see PhotonPay's 2026 Hong Kong Stablecoin Regulation Guide.

Frequently Asked Questions (FAQ)

What is a Trust and Company Service Provider (TCSP)?

A Trust and Company Service Provider (TCSP) is a licensed entity authorized by the Hong Kong Companies Registry under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) to provide regulated corporate and trust services. These include company formation, registered office provision, nominee directorship, nominee shareholding, and trust administration. Operating as a TCSP without a valid license is a criminal offense under Section 53ZI of the AMLO, punishable by up to HK$100,000 and 2 years' imprisonment.

Is PhotonPay licensed as a TCSP in Hong Kong?

Yes. PhotonPay's corporate services entity, Photon Dance Consulting Limited, holds TCSP License No. TC010478, issued by the Hong Kong Companies Registry. This license authorizes PhotonPay to provide trust and company services in Hong Kong under the AMLO compliance framework. The license can be verified directly on the Companies Registry's public TCSP register at any time.

What is the difference between a TCSP and an MSO license in Hong Kong?

A TCSP license, issued by the Hong Kong Companies Registry, covers corporate formation, nominee, and trust services under the AMLO. An MSO (Money Services Operator) license, issued by the Customs and Excise Department (C&ED), covers money-changing and remittance services. The two licenses are distinct and address different regulated activities. PhotonPay holds both — TCSP License TC010478 and MSO License 15-04-01638 — making it one of a limited number of providers in Hong Kong authorized to offer both corporate and payment services under a single regulated platform.

What AML/CFT obligations apply to TCSPs in Hong Kong?

Licensed TCSPs must perform customer due diligence (CDD) on all clients, identify beneficial owners of legal entities, apply enhanced due diligence (EDD) for politically exposed persons (PEPs) and FATF high-risk jurisdictions, file suspicious transaction reports (STRs) with the Joint Financial Intelligence Unit (JFIU), retain all records for a minimum of 6 years, and conduct annual AML/CFT staff training. These obligations are equivalent to those applied to financial institutions under the AMLO.

How long does it take to obtain a TCSP license in Hong Kong?

The Hong Kong Companies Registry typically processes complete TCSP applications within 6 to 10 weeks. Preparation — including business registration, Responsible Officer appointment, and AML/CFT policy drafting — adds a further 4 to 6 weeks. Applicants should plan for a total end-to-end timeline of approximately 3 to 4 months before commencing licensed TCSP activities.