Fintech Market Overview

This article does not constitute legal advice.

Digital onboarding in Hong Kong


In accordance with the amended Paragraph 5.1 of the SFC Code of Conduct, the SFC permits licensed intermediaries to employ other account opening methods, provided that such procedures can verify the identity of their clients. This is in addition to face-to-face contact. To assist intermediaries, details of approved account opening techniques are now available on the SFC's website. Additionally, a Circular to Intermediaries: Remote onboarding of Overseas Individual Clients was issued by the SFC on 28 June 2019 and came with an FAQ which addressed various issues related to digital onboarding. There are several methods that are acceptable to the SFC, including:

  1. certification by qualified person: the client agreement and the identity documents of the customer are certified by another licensed person, an affiliate, a justice of the peace or a professional person;
  2. using the certification services: the licensed intermediary accepts electronic signature certificates to replace actual identity documents;
  3. mail approach: the customer posts a copy of the identity document and the client agreement to the intermediary together with a physical cheque bearing the same signature as the one on the client agreement;
  4. online onboarding with Hong Kong-designated bank account: the customer electronically signs the client agreement and provides a copy of the identity document, and all future deposits and withdrawals from the client's trading account must be with a bank account in Hong Kong in the customer's name; and
  5. remote onboarding of overseas individual clients: technology adhering to international standards and best practice, such as ISO/IEC 19795 (biometric performance testing and reporting) and ISO/IEC 30107 (biometric presentation attack detection) would be adopted in the process of client identification together with the requirement that all deposits into and withdrawals from the client's trading account are made with a bank account in the customer's name opened with a designated bank from an eligible jurisdiction. 1

There are currently 16 eligible jurisdictions, including Australia, Austria, Belgium, Canada, Ireland, Israel, Italy, Malaysia, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, the United Kingdom and the United States.1

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Fintech in Hong Kong

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  1. https://thelawreviews.co.uk/title/the-financial-technology-law-review/hong-kong