The Hong Kong Monetary Authority (HKMA) recently announced that phase 2 of the Mandatory Reference Checking Scheme (MRC Scheme) will be implemented on 30 September 2025. This follows the launch of phase 1 of the MRC Scheme back in May 2023.
In short, the MRC Scheme seeks to roll out the “bad apples” from the banking sector, by requiring authorised institutions under the supervision of the HKMA (AIs), when recruiting for certain specified positions, to approach the former and current AI employer(s) of a prospective employee and request conduct-related information covering the seven years prior to the application for such position. We previously wrote this article providing details as to the type of misconduct information that has to be reported under the MRC Scheme.
Phase 2 of the MRC Scheme will cover a substantially wider scope of employees, including those who are licensed or registered to carry on securities, insurance, or Mandatory Provident Fund regulated activities.
The HKMA says that it will “continue to monitor AIs’ observance of the Scheme in Phase 2 during its ongoing supervisory efforts and may initiate follow-up actions with the AIs concerned as appropriate”.
Regardless of whether you are an AI, this is a good chance to review your employment contract templates, so as to ensure that the employment is clearly conditional upon you obtaining satisfactory MRC (or other background check) results regarding the candidate.
