For the purposes of paragraph 5.1 of the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission (Code of Conduct), the SFC considers the following account opening approaches acceptable:
Face-to-face
The account opening documents are executed in the presence of an employee of the licensed or registered person.
Non-face-to-face
1. Certified by other persons
Where the account opening documents are not executed in the presence of an employee of the licensed or registered person, the signing of the client agreement (as defined in paragraph 6.1 of the Code of Conduct) and sighting of related identity documents should be certified by any other licensed or registered person, an affiliate of a licensed or registered person, a JP (Justice of the Peace), or a professional person such as a branch manager of a bank, certified public accountant, lawyer, notary public or chartered secretary1.
The SFC expects that any affiliate performing client identity verification for account opening purpose should be a regulated financial institution.
2. Certification services
Certification services that are recognised by the Electronic Transactions Ordinance (Cap. 553) (ETO), such as the certification services available from the Hongkong Post, may also be employed2.
There are certification authorities outside Hong Kong whose electronic signature certificates (recognised signing certificates) have obtained mutual recognition status3 accepted by the HKSAR Government. The SFC considers that the use of the certification services provided by such certification authorities could be accepted for client identity verification.
3. Mail approach
The identity of the client (other than corporate entities) may be properly verified if the licensed or registered person complies with the following steps:
(i) the new client sends to the licensed or registered person a signed physical copy of the client agreement (see paragraph 6.2 of the Code of Conduct) together with a copy of the client's identity document (identity card or relevant sections of the client's passport) for verification of the client's signature and identity;
(ii) the licensed or registered person should obtain and encash a cheque (amount not less than HK$10,0004 and bearing the client's name as shown in his identity document) issued by the new client and drawn on the client's account with a licensed bank in Hong Kong;
(iii) the signature on the cheque issued by the client and the signature on the client agreement must be the same;
(iv) the client is informed (in the client agreement or by way of a notice) of this account opening procedure and the conditions imposed, in particular the condition that the new account will not be activated until the cheque is cleared; and
(v) proper records are kept by the licensed or registered person to demonstrate that the client identification procedures have been followed satisfactorily.
4. Online onboarding of clients using a designated bank account in Hong Kong
(i) Obtain a client agreement5 which is signed by a client by way of an electronic signature6 together with a copy of the client's identity document (an identity card or relevant sections of the client's passport);
(ii) Successfully transfer7 an initial deposit of not less than HK$10,000 from a bank account in the client's name maintained with a licensed bank in Hong Kong (Designated Bank Account8) to the intermediary's bank account;
(iii) Conduct all future deposits and withdrawals for the client's trading account through the Designated Bank Account(s) only; and
(iv) Maintain proper records of the account opening process for each client which are readily accessible for compliance checking and audit purposes.
5. Remote onboarding of overseas individual clients
Please click here for the "Circular to intermediaries - Remote onboarding of overseas individual clients" dated 28 June 2019.
Please click List of eligible jurisdictions for remote onboarding of overseas individual clients for the latest list of eligible jurisdictions.
6. Online onboarding of clients using iAM Smart
The authentication function of both versions of iAM Smart and iAM Smart+ for client identity verification in account opening is accepted.
Please refer to Appendix B of the “Circular to intermediaries – Updates to acceptable account opening approaches” for the illustrative processes.
1 A chartered secretary refers to a person who is a current full member of the Chartered Governance Institute or its designated divisions.
2 The list of recognised certificates available for subscriptions is published on the website of the Digital Policy Office at https://www.digitalpolicy.gov.hk/en/our_work/digital_infrastructure/legal_framework/regulation/eto/ca/rec_certs/.
These include, among others, the “Hongkong Post iAM Smart-Cert” and “Personal (Remote) ID-Cert Class 12” which can be remotely subscribed by iAM Smart account holders and the International Civil Aviation Organization compliant ePassport holders respectively.
3 Please refer to the following website for the latest Trust List of Certificate Types with Mutual Recognition Status: https://www.digitalpolicy.gov.hk/en/our_work/digital_infrastructure/mainland/cepa/mr_ecert/trust_list/
4 The minimum cheque amount required is subject to periodic review and will be revised when appropriate.
5 Section 17 of the ETO provides that in the context of the formation of contracts, an offer and the acceptance of an offer may be in whole or in part expressed by means of electronic records, unless otherwise agreed by the parties.
6 "Electronic signature" is defined in section 2(1) of the ETO to mean any letters, characters, numbers or other symbols in digital form attached to or logically associated with an electronic record, and executed or adopted for the purpose of authenticating or approving the electronic record.
7If the intermediary does not receive sufficient information about the sender from its receiving bank, the intermediary should obtain satisfactory evidence from the client to confirm that the transfer was made from the client's bank account.
8The client may designate more than one bank account as Designated Bank Account provided that the same verification by way of a bank transfer is completed.
Last update: 30 May 2025