Why is opening a bank account for a new Hong Kong company difficult, and what do banks ask for?
Banks must carry out customer due diligence under anti-money-laundering rules, so they ask who owns and controls the company and what it will do. New companies with non-resident owners or no trading history often face extra questions. The HKMA says banks should not reject applicants just for being offshore or a start-up.
What banks usually ask for
- Certificate of incorporation, business registration certificate, articles, and the latest annual return or incorporation form.
- Identity and address documents for directors, shareholders and significant controllers.
- Explanation of the business model, customers, suppliers, countries involved and expected transaction volumes.
- Proof of source of funds and wealth, and sometimes contracts or invoices.
Why it feels hard
- Banks use a risk-based approach and may apply tighter checks to certain industries, countries or ownership structures.
- Start-ups often have no track record, and owners based overseas are harder to verify.
- Requirements differ between banks, some require a minimum deposit, and decisions are at the bank's discretion.
What the regulator says (HKMA)
- Account opening is generally by one authorised person; not every director must attend.
- There is no requirement for a Hong Kong business address, and an application should not be refused merely because the company is offshore.
- Start-ups and SMEs have no special rulebook, but banks should not apply one-size-fits-all demands or insist on unreasonable sales benchmarks.
Tips Prepare a short business description, keep documents consistent, and ask the bank about its list before applying. Banks may refuse without giving reasons.
Legal basis
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Schedule 2
Sources
Applies to 2026 · Last reviewed 29 October 2026
General information for business owners, not legal, tax or professional advice. Rules change, so check the sources or ask a licensed professional before you act.
Related questions
- Should an overseas company set up a branch, a representative office or a Hong Kong subsidiary?A branch is the overseas company itself trading in Hong Kong and must register as a non-Hong Kong company within one month. A representative office can only liaise or research, not trade for profit. A subsidiary is a separate Hong Kong company that ring-fences liability.
- Can a foreigner or non-resident be a director of a Hong Kong company?Yes. The Companies Ordinance has no residency or nationality requirement for directors, and a non-resident can be the only director. Being a director does not by itself give any right to live or work in Hong Kong, which is a separate immigration question.
- Can a foreigner set up a company in Hong Kong, and what is required?Yes. Hong Kong has no nationality or residency requirement for shareholders or directors. The company needs at least one director who is an individual, a company secretary based in Hong Kong, a Hong Kong registered office, and business registration. A visa to live or work in Hong Kong is a separate matter.
- Does setting up a Hong Kong company give me a visa to live and work there?No. Incorporating a company or holding its shares does not give immigration status. A non-resident founder normally needs permission from the Immigration Department, for example under the Investment as Entrepreneurs route or a talent scheme, and must show a real business.
- How do I register an overseas company in Hong Kong (Part 16, registered non-Hong Kong company)?An overseas company that establishes a place of business in Hong Kong must register with the Companies Registry within one month on Form NN1. You file certified copies of its constitution, incorporation certificate and latest accounts, plus the business registration notice. The fee is HK$1,545 online or HK$1,720 on paper.