Pursuant to a guideline updated by the HKMA in December 2025, the HKMA set out its policy on granting specific consents under section 97(1) of the BO for non-bank persons to use banking names or descriptions.
Under section 97(1), it is an offence for any person other than a licensed bank or a recognized central bank, without the HKMA’s written consent, to use the word “bank” or its derivatives (including translations such as “銀行”), or to make any representation that it is a bank or carries on banking business in Hong Kong. This restriction also covers internet domain names and logos.
The guideline clarifies that the HKMA will not grant consent where the use of a banking name or description could mislead the public into believing that the company is a bank or is subject to banking supervision. In particular, names that are clearly misleading in their own right (e.g. “5454”, “ibank”, “cyberbank”, or specified terms such as “merchant bank” or “investment bank”) will not be approved. In assessing other applications, the HKMA will consider (i) how indicative the name is of banking activity, (ii) whether the company’s business is akin to banking, and (iii) whether the company is part of a larger group with an established brand name that includes a banking name. The first factor will be overriding.
The HKMA may attach conditions to any consent granted, including restrictions on engaging in banking‑like activities, requirements to provide information or audited accounts, and advance notice of any proposed change of name or description.
Applicants must submit detailed information to the HKMA’s Licensing Team, including the proposed name, business activities, corporate documents and particulars of key persons. Each application will be considered on its own merits, and non‑compliance with any attached conditions may result in withdrawal of consent.
Please click here for the guideline.
