DPMS Registration for Dealers in Precious Metals and Stones

01 / BUSINESS SCOPE

Business Scope and Application Value

As of 3 November 2026, a business carrying on the relevant activities in Hong Kong and conducting non-cash specified transactions at or above the HKD 120,000 threshold must obtain a Category A or Category B registration; cash receipts or payments at or above the same threshold require Category B registration. Related or apparently related operations must be included, and cash and non-cash payments must be assessed separately; do not look only at the total invoice amount.[1][2]

• Conduct threshold-triggering transactions lawfully: Category A provides a registration route for specified non-cash transactions, while Category B permits specified cash and non-cash transactions. Select the category according to the actual payment and receipt model, rather than describing Category B as a universal licence to conduct all financial businesses.[1][2]
• Make it easy for customers to verify the entity: the Customs public register lists the dealer’s name, registration category and relevant business address, and customers can verify the identity using the registration number or QR code. Registration is not a government guarantee of the authenticity of goods, business strength or customers’ investment returns.[1][2]
• Adapt to multi-channel operations: the same legal entity may declare multiple business premises and obtain a branch certificate for branches conducting face-to-face transactions. Online shops also have a corresponding mechanism for displaying identification. These administrative arrangements are clearer, but another group company must not borrow the same registration to conduct business. [1][2]
• Supports transaction traceability and risk management: Category B’s customer due diligence, unusual transaction handling and record-keeping procedures can help explain the flow of goods and funds. These procedures may provide a basis for materials used in bank due diligence, but do not guarantee successful account opening, acceptance of large cash amounts or obtaining trade finance.[1][4]
• Control compliance costs according to the business model: businesses that do not conduct specified cash transactions may use the simpler Category A route. If large-value cash business is to be added later, first obtain Category B registration and establish the operational capability to implement it; do not accept cash first and complete the formalities afterwards.[1][2]

02 / ENTRY REQUIREMENTS

Entry Conditions and Core Requirements

• First identify the scope of the items: precious metals include gold, silver, platinum, iridium, osmium, palladium, rhodium and ruthenium; precious stones include diamonds, sapphires, rubies, emeralds, jade and pearls, whether natural or not. Jewellery or watches containing relevant materials may also constitute precious products.[1][2]
• The business is not limited to retail: it may include buying and selling, import and export, production, refining, value-added processing, and the issuance or trading of precious-asset-backed instruments and related intermediary services. Import and export activities involving the transportation of relevant goods in the ordinary course of logistics business are subject to a separate statutory exclusion.[1][2]
• The non-cash threshold is calculated based on non-cash payments received or paid in Hong Kong in connection with the relevant transaction. Credit cards, bank transfers, cheques and e-wallets may be aggregated. A single transaction or linked operations amounting to HKD 120,000 or the equivalent in foreign currency constitute a specified transaction, provided it is not a specified cash transaction.[1][2]
• The cash threshold covers both receiving cash from customers and paying cash to suppliers or sellers. If the total cash amount in a single transaction or related transactions reaches HKD 120,000 or the equivalent in foreign currency, it must be treated as Category B. Splitting invoices, paying in instalments or using multiple people to make payments does not automatically remove the related nature of the transactions.[1][2]
• Category A does not absolutely prohibit all cash; it prohibits specified cash transactions. Category B may handle both specified cash and non-cash transactions. For mixed payments, determine separately whether each type of payment meets the relevant definition; do not treat the total price of the goods as the cash amount in every case.[1][2]
• An applicant may be a sole proprietorship, partnership or corporation, and must hold a valid business registration certificate or a hawker licence that meets the requirements. It must declare all business premises and correspondence addresses. A Class A applicant must also declare that the business is conducted for a lawful purpose. All information and declarations must be consistent with the actual business.[1][2]
• Class B applicants must pass the fit-and-proper assessment and demonstrate their ability to meet anti-money laundering requirements, including institutional risk assessment, customer due diligence, ongoing monitoring, suspicious transaction reporting and record-keeping. Submitting blank templates without personnel, authority and implementation procedures is not sufficient.[1][4]
• First check whether a registration exemption applies: recognised institutions, licensed money lenders regulated under the Money Lenders Ordinance and other institutions meeting statutory conditions have corresponding arrangements. Some financial institutions must also meet conditions such as the relevant activity being ancillary to their principal business. An exemption applicable to a parent company does not automatically extend to its subsidiaries. [1] [2]
• Statutory non-Hong Kong dealers are subject to separate arrangements: they must meet all conditions, including having no place of business in Hong Kong and carrying on business in Hong Kong for no more than 60 days in each calendar year. They must report specified cash transactions within one day after completion or before leaving Hong Kong, whichever is earlier; they cannot simply be treated as unregulated.[1][2]

03 / PEOPLE & GOVERNANCE

Shareholders, directors and compliance personnel

• The scope of fit and proper persons for Category B is determined by the type of entity: each sole proprietor and its ultimate owner, each partner and ultimate owner of a partnership, and each director and ultimate owner of a corporation must be assessed. It is not sufficient to declare only one director responsible for day-to-day operations.[1]
• The ultimate owners of a company must be traced through to natural persons. This includes persons who directly or indirectly own or control more than 25% of the issued share capital or voting rights, and persons who exercise ultimate control over management. Do not check only direct shareholders or omit persons exercising control through trusts, nominees or agreements.[1]
• The fit-and-proper assessment covers relevant criminal, fraud and dishonesty records, regulatory compliance, and matters such as personal bankruptcy or the winding-up of a body corporate. Any adverse background should be explained truthfully and supported with evidence; a certificate showing no criminal record cannot be said to guarantee a successful assessment.[1]
• Class B senior management must appoint a compliance officer at management level and a senior officer as the money laundering reporting officer; one person may hold both roles depending on the scale of the business. The appointee should have sufficient qualifications, authority, access to information and resources, should normally be based in Hong Kong, and should be able to report directly to senior management.[1][4]
• Under the 2026 registration guidance, except where a sole proprietor, partner, director or ultimate owner also performs the relevant compliance and reporting roles, the Compliance Officer and Money Laundering Reporting Officer must be employees hired by the applicant under the Employment Ordinance; simply listing an external consultant in name only is not appropriate.[1]
• A Category B interview may be attended by a sole proprietor; a partner authorised in writing by all partners; or the sole director, together with a director or officer authorised in writing by the board. A beneficial owner or compliance officer nominated by an adviser is not automatically eligible to attend.[1]
• Category A does not have the same fit-and-proper assessment or dedicated compliance staffing framework as Category B. However, it must still have genuine authorisation and a person responsible for implementing display requirements, paying fees and notifying changes. Category B should also conduct employee screening and ongoing training, retaining training materials and attendance records.[1][4]

04 / CAPITAL & PREMISES

Capital and business address requirements

Financial resources and sources of funds

The Customs and Excise Department’s current DPMS registration guidelines do not prescribe a uniform minimum amount of paid-up share capital, working capital or security deposit for Category A or Category B. Separate budgets must be made for procurement, rent, staffing and compliance expenses. The registration application fee and fit-and-proper assessment fee are not capital requirements; nor should working capital recommended by a consultant be presented as a statutory threshold. [1][3]

Statutory share capital, net assets, liquid capital and other financial resources are not the same concept. Capital is not a government fee or consultancy fee, and must not be conflated with client assets or reserve funds.

Hong Kong Business Address and Substantive Operations

• Reportable premises include not only retail outlets but also premises used for business administration, transaction processing, or the storage of documents, data and records. Distinguish correspondence addresses from actual business premises; providing only a company-secretarial mailing address must not conceal where business is actually conducted or information is stored.[1][2]
• A purely online shop or a business conducted at customers’ premises is not exempt from registration merely because it has no physical retail shop. The actual business premises must still be declared in the application, together with proof of address that meets the guidelines. Whether additional premises arrangements are needed should be determined by the actual administrative, transaction and record-keeping processes.[1][2]
• If residential or mixed-use premises are used for business, obtain the written consent of every occupier so that authorised Customs officers may lawfully enter for inspection. An occupier’s withdrawal of consent or a new occupier’s refusal to consent may affect the maintenance of the registration; the owner’s permission alone is not sufficient. [1]
• The registration certificate must be displayed prominently at the principal place of business, and the corresponding branch certificate must be displayed at each other branch that conducts face-to-face transactions. The same legal entity generally applies for one registration and declares its branches. The registration obligation must be assessed separately for different companies or different sole proprietors.[1][2]
• For a new permanent branch or temporary exhibition booth, Form 5 may be used to apply in advance for a branch certificate. Customs guidance recommends giving 7 working days' advance notice to allow the certificate to be issued in time. This recommendation must not be misrepresented as a statutory requirement that all business changes be notified 7 days in advance.[1]
• Websites and other electronic platforms must prominently display the name recorded in the Register, together with the QR code or registration number provided by Customs for verification. Electronic certificates may be downloaded and printed, but their display on a webpage must not imply that registration is an endorsement of the authenticity of goods or an investment endorsement.[1]

05 / APPLICATION DOSSIER

Application Document Checklist

• For Class A, depending on whether the business holds a Business Registration Certificate or a hawker licence, choose Form 1A(BR) or 1A(H), attach the entity’s registration documents, relevant identity documents, details of all business premises and the correspondence address, and make a declaration of lawful business operations. Prepare the specific attachments in accordance with the official checklist applicable to the entity type. [1]
• For Category B, use Form 1B(BR) or 1B(H). A local company generally needs to prepare its business registration certificate, certificate of incorporation, articles of association, latest NAR1 and subsequent change documents. A newly incorporated company must submit the incorporation form as required by the checklist; it cannot be required to provide an annual return that has not yet become due.[1][5]
• Category B applicants must provide the complete group structure and the shareholding percentage at each level, and, where applicable, submit a significant controllers register. Non-Hong Kong companies and companies continued into Hong Kong must use the corresponding certificates of registration and filing documents; the document checklist for a newly incorporated local company cannot simply be applied.[1]
• Each natural person subject to assessment should submit Form 3A together with Appendices I and II and the particulars page of their identity card or travel document. A corporate partner or corporate director should use Form 3B and attach the relevant entity information. Cross-check the personnel list against the register of directors and the shareholding chart.[1][5]
• Appendix I to Form 3A must be signed in the presence of a witness as required. A witness may include an authorised Customs officer, a practising professional, a notary public or a Justice of the Peace, and must check the original identity document. An ordinary electronic signature or an unwitnessed scanned copy should not be assumed to satisfy the requirements.[1]
• For each premises, prepare a stamped lease, title records or recent proof of address that meets the guidelines. Where proof of address is used, the guidelines specify that it must have been issued within the preceding three months. For residential or mixed residential-commercial premises, also attach written consent from each occupant.[1]
• A partnership must provide an authorisation letter signed by all partners, and a corporation must provide a board authorisation letter. Authorisation to operate the application system, authority to sign forms and eligibility to attend an interview must be checked separately. Avoid relying solely on an adviser’s engagement letter without valid internal authorisation from the applicant.[1]
• Class B applicants must submit information describing the business and their anti-money laundering measures. They may use the Customs template or prepare their own document covering every item in the template. The submission should describe the goods, customers, sales channels, cash volume, CO and MLRO arrangements, and include corresponding due diligence forms and an escalation process for unusual activity. [1][4]
• For a Category B interview, bring the original supporting documents and records of payment of the registration fee, as instructed by Customs, and explain the application information and business arrangements. The payment record is evidence of fees relating to the application; it should not be described as a requirement for every new applicant to have existing cash transaction records with clients.[1]

06 / APPLICATION ROADMAP

Application process and required time

The Customs and Excise Department’s May 2026 guidelines state that, after receipt of all required documents and information, processing generally takes 12 working days for Category A and 33 working days for Category B. These are not guaranteed approval periods. Requests for additional documents, external fit-and-proper-person checks and interview arrangements affect the overall timeline. The outdated position that both categories take 33 days should not be used. [1]

1. Step 1: Determine whether the goods and activities fall within the scope of DPMS business, check for exemptions, and then calculate cash and non-cash related payments separately. Customs iPASS may be used for a pre-application self-assessment, but it is not an approval decision or a separate statutory licence. [1][2]
2. Step 2: Determine the applicant and the Category A or Category B route, and put in place the business registration, all business premises, internal authorisations and website-display arrangements. Anyone intending to conduct specified cash transactions must prepare directly for Category B and must not treat a Category A application acknowledgement as permission to conduct cash transactions.[1][6]
3. Step 3: Organise the documents in accordance with the latest forms and attachment checklist. For Category B, also verify the backgrounds of directors and ultimate owners, appoint the CO and MLRO, and establish a risk-based anti-money laundering system. Documents must reflect the business intended to be conducted; do not fabricate clients, employees, or past transactions.[1][4]
4. Step 4: Submit online through DRS, or submit by post or in person in accordance with the official guidelines. Class A applicants pay the fee after receiving a notice; Class B applicants follow the Customs process for fee payment and interview arrangements once the required documents are complete. Fees collected are non-refundable if an application is refused.[1][3]
5. The fifth step is to respond to requests for further documents within the period specified by Customs. After being notified, Category B applicants should arrange for a qualified senior management officer to attend, verify originals, confirm signatures and explain the systems. Category A cases may also be required to attend an interview; do not claim that Category A applicants are never interviewed.[1]
6. Step 6: Based on all the information, its fit and proper checks for Class B and the compliance capability, Customs decides whether to register the business or impose conditions. The general processing references are 12 working days for Class A and 33 working days for Class B after the information is complete; the consultant’s preparation period and any period for providing further documents are not fixed approval commitments.[1]
7. Step 7: After approval, download and display the registration and branch certificates, display the name and QR code or number on electronic channels, and set up a calendar for fees, renewals and changes. Category B registrants must actually carry out customer due diligence and record-keeping; approval does not mean that compliance obligations have been completed.[1][4]

07 / ACQUISITION & CHANGES

Acquisitions, Changes to Shareholders and Directors, and Completion

• Acquiring shares in a registered company is not the same as handing the seller’s registration certificate to a new entity to operate. Due diligence should first confirm the transaction entity, legal entity, and registration number. If another company or individual will operate the business, reassess the position and obtain the registrations required for that operator.[1][2]
• When acquiring a Class B company, if the buyer or new controller will become an ultimate owner, any new directors or partners must also first obtain written Customs approval. Make the relevant approval a condition precedent to completion; company registration of directors with the Companies Registry cannot replace Customs approval.[1]
• Regulatory due diligence should verify the registration category, validity period, additional conditions, annual fee or renewal status, and records of suspension, cancellation and disciplinary action. A Class A licence must not be valued as if it were a Class B cash business, and a seller’s promise that an upgrade application has been submitted does not mean that Class B approval has been granted.[1][6]
• For Category B historical due diligence, sample-check customer and transaction files, annual returns, internal handling of suspicious transactions, employee training and remediation following independent reviews. A transfer of shareholding does not automatically eliminate the company’s existing liability for non-compliance, and missing records may also affect the ongoing fit-and-proper assessment.[1][4]
• Closing arrangements must address whether existing compliance personnel will remain, the employment and authority of successor personnel, updates to premises and website information, and access to records. Continued registration does not mean that existing bank accounts may continue to be used unconditionally; banks may independently review changes in ownership and business. [1][4]
• There is no uniform Customs-set price or guaranteed completion period for an acquisition. The official fee for an application for approval of an additional director, partner or ultimate owner is HKD 690 per relevant person, and should be disclosed separately from the equity purchase price, tax and professional due-diligence fees.[1][3]

Shareholders, Directors and Other Material Changes

• Changes to specified particulars, including the name, addition or closure of a place of business or relocation, and the occupier of residential premises, must be notified to Customs in writing within one month from the date of the change using the applicable Category A Form 6A or Category B Form 6B. Select the version according to whether the holder has a Business Registration Certificate or a hawker licence.[1]
• If a person proposes to become a director, partner or ultimate owner of a Class B registrant, they must first apply using Form 4 and obtain written approval from Customs, and also provide the fit-and-proper information. A transfer of shares or appointment must not be completed first and then treated as covered by a one-month notice of change in place of prior approval.[1][3]
• Changes to the identity details of Category B relevant persons, a member's departure, or the status of a fit and proper person declaration must also be notified in accordance with the guidelines. Prior approval for a new person and notification of a subsequent change are separate obligations and should be covered by separate completion conditions and notification checklists.[1]
• Changes to other details, such as the contact email address or telephone number, types of goods, business activities, operating model or website, may be notified to Customs by email in accordance with the guidance. State the registrant’s name, number and details of the changes. If a face-to-face trading branch is added, arrangements for displaying the branch certificate must also be addressed. [1]
• A Class A registrant intending to commence specified cash transactions must first obtain Class B registration. It cannot do so merely by changing the business description on its Business Registration or notifying Customs of its cash-acceptance policy. A Class B registrant intending to stop cash transactions but retain non-cash specified transactions should apply for Class A registration; once Class A registration is completed, the Class B registration will lapse.[1]
• If you intend to cease business, or to cease all specified transactions in a particular category, you must notify Customs using Form 7 before the intended cessation date. A Category B licensee that stops cash transactions but retains qualifying non-cash transactions must not mistakenly use the full cessation-of-business notice; it must follow the category-conversion process.[1]

08 / ONGOING COMPLIANCE

Post-approval maintenance and ongoing responsibilities

• There is no general requirement for Class A registration to be reapplied for every year. However, the annual fee of HKD 195 must be paid on or before each anniversary of the registration’s effective date, and a valid Business Registration and compliance with the registration conditions must be maintained. Late payment may result in suspension or cancellation of the registration; it is incorrect to say that no ongoing maintenance is ever required. [1][3]
• Category B is generally valid for three years. An application for renewal must be made at least 60 days before expiry, with Form 2, updated fit and proper declarations and business compliance information prepared. The basic renewal fee is HK$1,060, plus HK$650 for each person who must be assessed. Late renewal may cause the registration to lapse.[1][3]
• Class B applicants must submit an annual return each year, containing specified data and information for the preceding calendar year, in the format, manner and within the timeframe specified by Customs. This is different from the Companies Registry’s NAR1 and the registration renewal every three years; neither can replace the other, and no uniform deadline should be invented.[1]
• For Category B, before establishing a business relationship or conducting an occasional transaction involving a specified cash transaction, identify and verify the customer, beneficial owner and agent as required, and understand the relevant purpose. Suspicions of money laundering or doubts about identity information must also be handled in accordance with the guidance; decisions must not be made mechanically based only on the amount.[4]
• Customer due diligence information must be retained throughout the business relationship and for at least five years after it ends. Due diligence information and transaction records relating to occasional specified cash transactions must generally be retained for at least five years from completion of the relevant transaction. Records should be readily retrievable and retained for longer where required.[4]
• Class B registrants should continuously monitor customers and transactions, identify politically exposed persons and high-risk relationships, and implement sanctions and terrorist-financing screening. Potential name matches must be investigated, and genuine restrictions or reporting obligations must be dealt with in accordance with the law; not every customer with the same name or every politically exposed person should be treated as a criminal.[4]
• If known or suspected proceeds of crime or terrorist property are identified, a report must be made to the Joint Financial Intelligence Unit as soon as practicable in accordance with the law, and tipping off must be avoided. This general criminal-law obligation is not limited to Category B or amounts above HKD 120,000; Category A must not be promoted as being entirely exempt from anti-money laundering requirements. [1] [4]
• A Class B holder must periodically review its institutional risk assessment, policies, staff training and independent review arrangements at a frequency and scope proportionate to the scale and risks of the business. New risks should be assessed when systems are changed, products added or higher-risk markets entered; templates should not be updated only before renewal.[4]
• Both classes must continue to comply with requirements for physical and online displays, notification of changes to particulars and cessation of business, and must cooperate with Customs and Excise inspections. A Class B breach of specified requirements may result in public reprimand, a remediation order or a disciplinary fine of up to HK$500,000, and may also involve criminal liability.[1][4]

09 / FREQUENTLY ASKED

Frequently asked questions

10 / OFFICIAL REFERENCES

Official references and information verification

Information compilation date:3 November 2026The regulatory websites below are used to verify applicable laws, the latest forms, fees and registration status. Primary legislation, current requirements of the competent authorities and case-specific decisions take precedence.

Prepared by Rengangyongsheng (Hong Kong) Limited; professional explanation provided by Business Manager Tang Shangyong (Drew). This does not constitute legal, tax or investment advice for any specific case.