Hong Kong Company Secretary Licence Needed | Generated by AI
Question: Does registering a company in Hong Kong require a 秘书牌照 (company secretary licence / TCSP licence)?
Answer:
Short version: your company doesn’t need a licence — but whoever provides company secretary services as a business does. The two things get conflated a lot.
Breaking it down:
1. Every HK company must appoint a company secretary. A private local limited company must have at least one director who is a natural person and one company secretary, and the Companies Ordinance prohibits a sole director from also acting as the company secretary of the same company. So if you’re a single-founder company, you can’t be your own secretary — you need someone else.
2. The “秘书牌照” is the TCSP licence. Since March 2018, under the AMLO (Cap. 615), acting as, or arranging for another person to act as, a secretary of a corporation by way of business is a licensed activity, and doing it without a TCSP licence is an offence punishable by up to a HK$100,000 fine and 6 months imprisonment.
3. Who needs it and who doesn’t:
- If the secretary is a corporate entity, it must hold a TCSP licence issued by the Companies Registry (this covers the typical secretarial firms you’d hire for ~HK$1,000–3,000/year).
- If a natural person (HK resident) — a friend, co-founder, or family member — acts as secretary for your company not as a business, no licence is needed. The Companies Registry FAQ explicitly covers this: someone acting as company secretary for a family member’s company, without providing secretarial services to other persons, does not need a TCSP licence.
- Note the individual secretary must ordinarily reside in Hong Kong.
Practical implication for you (mainland-based founder): since you likely don’t have a HK-resident individual to fill the role, you’d hire a licensed secretarial firm. That firm holds the TCSP licence, not you. You can verify any provider’s licence status at the official TCSP register before paying — worth doing, because directors should check whether the provider is properly licensed, especially when they also provide registered office, nominee, or incorporation services (those are also licensed activities).
So: registration itself needs no licence from you; the secretarial + registered-office package you’ll inevitably buy must come from a TCSP-licensed provider.
References:
- Companies Registry — TCSP Licensing FAQ (PDF)
- TCSP Licensee Public Search
- Sovereign Group — HK Company Secretary Requirements
- Arnifi — HK Company Secretary Requirements Guide