What does an MSO licence cost?
There are two kinds of cost to plan for: the government fees payable to the Customs and Excise Department, and the real-world cost of compliance — premises, staff, systems and professional advice. Budget for both.
1. Government fees (AMLO Schedule 3)
The fees are set out in Schedule 3 of the AMLO and are revised from time to time. The most recent revision took effect on 15 May 2026 (under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Amendment of Schedule 3) Notice 2026), which increased most fees by roughly 10–15%.
| Fee | Indicative amount (from 15 May 2026) |
|---|---|
| Basic licence application fee | ~ HK$3,310 |
| Audit fee — per "proper person" assessed | ~ HK$860 |
| Additional business premises (per premises) | ~ HK$2,200 |
| Photocopying (per page) | HK$1.5 |
How the fees scale: the basic fee is per application, the audit fee is charged for each proper person the Department has to assess (so more directors/owners means more audit fees), and there is an additional-premises fee for each location beyond the first. A larger operator with several owners and many branches will therefore pay considerably more than a single-counter sole proprietor.
2. The real cost of compliance
For most applicants, the government fees are the smallest part of the budget. The bigger, ongoing costs are operational:
🏠 Premises
Suitable, often street-level commercial space — rent and fit-out — for each location you operate.
👥 People
A Compliance Officer and a Money Laundering Reporting Officer, plus trained front-line staff.
🛡️ AML/CFT systems
Customer-due-diligence and screening tools, transaction monitoring, and secure record keeping (6 years).
📑 Professional fees
Legal and consulting help to prepare the application, the compliance manual, and ongoing audits.
3. Renewal and ongoing fees
A licence is valid for 2 years. You must apply to renew no later than 45 days before it expires, and pay the applicable renewal fees. There are also fees for variations such as adding premises or making certain changes during the licence term. Treat compliance as a recurring cost, not a one-off.
Plan your budget
A useful way to think about it:
Government fees (application + per-person audit + per-premises) + premises + staff + AML/CFT systems + professional fees, repeating every 2-year licence cycle.
Get the precise government figures from the official fee schedule, and price the operational items for your specific business model and number of locations.