The answer first
If your business deals in precious metals, precious stones or products containing them, and any single transaction or set of linked transactions reaches HK$120,000, you must register with the Customs and Excise Department (C&ED) as a Dealer in Precious Metals and Stones (DPMS) before carrying on that business. The regime sits under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
There are two categories, and which one you need depends on one question: will you accept cash at or above the threshold? Trading above the threshold without the correct registration is a criminal offence.
At a glance (government fees)
- Category A (non-cash only)
- HK$260 to apply; HK$195 a year; about 12 working days; no interview
- Category B (any cash)
- HK$1,970 to apply plus HK$650 per person assessed; HK$1,060 renewal every 3 years; about 33 working days; interview required
- Threshold
- HK$120,000 per transaction or linked transactions
Do you need to register?
Registration is triggered by transaction value, not business size. Splitting a sale into smaller invoices does not avoid the threshold if the transactions are genuinely linked, for example one customer buying several items in one visit, or a group of buyers directed by one person.
Choose the category that matches reality, not intentRegistering as Category A and then accepting a large cash payment puts the business in breach; it does not convert you to Category B. If there is a realistic chance of taking cash at or above the threshold, even occasionally, Category B is almost always the right starting point.
Category A vs Category B
| Category A | Category B | |
|---|---|---|
| Payment types | Non-cash only | Cash, with or without non-cash |
| Fit-and-proper test | Not required | Every sole proprietor, partner, director and ultimate owner (over 25%) |
| Written AML/CTF policy | Not required | Required |
| Compliance Officer and MLRO | Not required | Required (one person may hold both, depending on size) |
| Customer due diligence | Not required by the registration regime itself | Required for cash transactions at or above the threshold |
| New partners, directors or owners | Notify | Prior approval from C&ED |
| Annual return to C&ED | Not required | Required every year |
Documents you will need
Both categories
- A valid Business Registration Certificate (or hawker licence).
- Details of every business premises and a correspondence address, with proof of each premises (stamped tenancy, proof of ownership, or an address proof issued within 3 months).
- Signed consent from every occupant where a premises is a domestic address.
- A declaration that the business is carried out for a lawful purpose.
Category B, in addition
- Fit-and-proper declarations (Form 3A for individuals, with Appendices I and II, or Form 3B for corporates) for every principal and ultimate owner.
- A description of the AML/CTF systems and controls, in the format C&ED specifies.
- Identity documents for the individuals declared.
The application, step by step
| Step | What happens |
|---|---|
| 1. Confirm your category | Decide honestly whether you will handle cash at or above HK$120,000 |
| 2. Gather documents | For Category B, brief every person who will make a fit-and-proper declaration |
| 3. Submit | Form 1A (Category A) or Form 1B (Category B), through the DPMS Registration System or to the DPMS Supervision Bureau |
| 4. Interview (Category B) | Sole proprietor, an authorised partner, or the sole or an authorised director attends in person |
| 5. Fee and processing | About 12 working days (A) or 33 working days (B) from a complete application |
| 6. Certificate | Display at the principal place of business and each branch, or by registration number or QR code online |
Government fees
| Item | Category A (HK$) | Category B (HK$) |
|---|---|---|
| New application | 260 | 1,970 |
| Fit-and-proper assessment | Not applicable | 650 per person |
| Annual fee / renewal fee | 195 per year | 1,060 every 3 years |
| Renewal fit-and-proper assessment | Not applicable | 650 per person |
These are government charges as published by C&ED; our professional fees are quoted separately in writing.
After registration
- Notify changes (business name, premises, occupants, partners, directors or owners) within 1 month, on Form 6A or 6B.
- Prior approval (Category B): new partners, directors or ultimate owners need C&ED approval on Form 4 before the change takes effect.
- Annual return (Category B): mandatory every year for the preceding calendar year, by the date C&ED specifies.
- Branches and cessation: apply in advance for a branch certificate (Form 5); notify intended cessation in advance (Form 7).
- Renewal: Category A continues while the annual fee is paid; Category B is valid for 3 years and must be renewed at least 60 days before expiry (Form 2), with fresh fit-and-proper declarations.
Please confirmThe Category B annual return date is not a single fixed calendar date for every registrant; confirm yours with the DPMS Supervision Bureau or with us.
If you do not register, or get it wrong
| Failure | Consequence |
|---|---|
| Trading above the threshold without the correct registration | Criminal offence: fine up to HK$100,000 and up to 6 months' imprisonment |
| Not displaying the certificate, or not notifying a change or cessation | Fine up to HK$50,000 |
| Category B: no prior approval for a new partner, director or owner | Fine up to HK$50,000 and up to 6 months' imprisonment |
| Category B: serious or ongoing non-compliance | Reprimand, corrective orders, suspension or cancellation, or a penalty up to HK$500,000 plus up to HK$10,000 per day |
Key takeawayGetting the category right at the outset is the biggest factor in a smooth application. The wrong category almost always means starting again.
How DBMS Global can help
- Confirming which category genuinely fits your business before you apply.
- Preparing the full document set and fit-and-proper paperwork.
- Submitting and managing the application and liaising with C&ED.
- Preparing you for the Category B interview.
- Tracking change notifications, prior approvals, the annual return and renewal.
- Setting up your Compliance Officer and MLRO framework and written AML/CTF policy.
In summary
- Register before trading at HK$120,000 or more.
- Category A for non-cash only; Category B wherever cash is accepted.
- Registration is the start: Category B carries ongoing filings and deadlines.
Read also: DPMS Category B pre-transaction checklist.
Official references
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), Part 5C
- Customs and Excise Department: Registration Guide for Dealers in Precious Metals and Stones, www.customs.gov.hk