Remote Account Opening and Virtual Banks: Who Can Open by App, Identity Verification and the New Regulatory Position

Remote account opening (remote on-boarding) means the customer does not need to visit a bank counter, but submits identity documents, completes identity verification and applies for an account through a mobile app or online channel. In Hong Kong, remote and face-to-face account opening are subject to the same customer due diligence (CDD) requirements; the only difference is "how the bank confirms that the person on the other side of the screen is the person named on the document". Whether you can open an account remotely, and which functions you can use afterwards, is decided by each bank on the basis of its risk assessment; regulators do not guarantee that anyone can open an account through an app.

This article applies to Hong Kong (bank and regulatory position) and Singapore (for comparison).

The regulatory framework for remote on-boarding: the new circular of September 2026

On 2026-09-03 the Hong Kong Monetary Authority (HKMA) issued a circular titled Remote on-boarding of individual customers to all authorized institutions and stored value facility licensees. The circular states that it supersedes the circular of the same name dated 2019-02-01 and the "Remote on-boarding and iAM Smart" circular of 2021-05-24; the circular of 2020-09-24 on remote on-boarding of corporate customers continues to apply.

The circular sets out two core principles:

The circular also notes that AI-driven automation and deepfake technology have increased the scale of impersonation, online fraud and related mule account networks. The HKMA and the Hong Kong Police Force will share the latest methods with the industry, and banks must continue to update and recalibrate their remote on-boarding arrangements accordingly and carry out a comprehensive review of those arrangements and their monitoring. For readers, this means that from the second half of 2026 some banks' app account opening may become stricter, for example with extra verification steps or a narrower range of accepted documents or locations; each bank's announcements prevail.

Tiered accounts: open first, add functions later

Beyond the two principles, the circular expects banks to design products and services on a risk-based approach, giving a "tiered approach" as an example: account features, functions and transaction limits can be adjusted dynamically according to actual usage and ongoing customer behaviour. This explains several situations readers often encounter:

1. After opening an account through an app, transfer or Faster Payment System (FPS) limits are low and can be raised only after a period of time or after providing further information;
2. Savings and current account functions are enabled first, while investment functions such as securities and funds must be applied for separately, with suitability and investor identification procedures completed;
3. If ongoing monitoring shows that the pattern of transactions does not match the purpose declared at account opening, the bank may ask for more information or even narrow the account's functions.

Tiering is not a uniform set of levels defined by the regulator; names and limits differ from bank to bank and may change. Read the bank's account terms and fee schedule before opening an account, and do not assume that because "the app account is open", every service is available. Investment functions for Chinese Mainland investors are also subject to the written declaration and own-name settlement requirements from May 2026; see Investment account changes from 2026.

App account opening at traditional banks: eligibility, using one bank as an example

Banks' published positions on whether non-HKID holders can open an account remotely vary widely. The table below uses the published conditions on the website of The Hongkong and Shanghai Banking Corporation (HSBC) purely to show "what such conditions look like"; it does not represent other banks or indicate that an application will be approved (accessed 2026-10-24; the bank's website prevails):

The additional balance requirements and fees that apply to non-HKID holders are covered in Main banks.

The HKMA's "Account Opening – What's New?" page reproduces service announcements from a number of banks; for example, Bank of China (Hong Kong) (BOCHK) announced on 2020-07-16 that it had extended mobile account opening to countries or regions outside Hong Kong. The page states that its content is provided by the banks, so it shows only that "a bank once launched a certain type of service"; it is neither a regulatory requirement nor a promise about timing, and the scope of the service may since have changed.

Virtual banks (digital banks): what they are, how many there are and how to open an account

A virtual bank is a licensed bank, authorised by the HKMA, that delivers retail banking services mainly over the internet. The HKMA granted 8 virtual bank licences between March and May 2019. Its review report published on 2024-08-06 lists Airstar, Ant Bank (Hong Kong), Fusion, Livi, Mox, PAO Bank (formerly Ping An OneConnect Bank (Hong Kong)), WeLab and ZA Bank, and states that all virtual banks open accounts remotely. The relevant authorisation guideline was revised on 2024-10-25 and renamed the Guideline on Authorization of Digital Banks, defining these as banks that deliver banking services wholly or primarily through the internet. The current list is in the HKMA's Register of Authorized Institutions.

Deposits with virtual banks are likewise protected by the Deposit Protection Scheme (subject to the member list); the limit and scope are covered in Deposit protection.

When you still need to attend in person: common situations

The range of people that remote channels can serve is widening, but in practice the following situations often require a branch visit or an additional interview; the bank's notice prevails:

1. Your identity document is not supported by the app: for example, the document type, place of issue or version is not supported by the system;
2. Identity verification fails or identity matching is in doubt: repeated recognition failures or a failed liveness check;
3. Non-HKID holders opening certain accounts: some banks require an appointment first, followed by a visit to a designated branch (see the example in Main banks);
4. Applying for investment functions or a higher account tier: a risk assessment, the investor identification consent or the Chinese Mainland investor written declaration is needed;
5. Information needs further explanation: where account purpose, source of funds, occupation and expected transactions do not line up, the bank may ask for an interview (how to prepare is covered in Source of funds).

Do not borrow someone else's identity document, use an agent's device or have another person complete facial recognition for you. These are exactly the impersonation and mule account risks the new circular targets, and they may lead to rejection, account closure and a report to law enforcement agencies. What to do after a rejection is covered in Rejections and document requests.

How Singapore compares: the Singpass route and remote opening for non-residents

Paragraph 6.29 of Monetary Authority of Singapore (MAS) Notice 626 (current version revised 2025-06-30) requires due diligence for non-face-to-face account opening to be "at least as robust" as for face-to-face opening; the HKMA's formulation is two principles, identity authentication and identity matching, plus risk-based tiering. The main difference lies in identity infrastructure: Singapore banks generally complete remote account opening by retrieving government-verified data through Singpass / Myinfo, and Singpass registration is open to Singapore citizens, permanent residents and pass (FIN) holders aged 15 and above (GovTech registration guide, 2026-06). For non-residents without Singpass, remote opening depends on each bank's dedicated channels: for example, OCBC's published scheme for foreigners to open a Premier account remotely requires applicants to be at least 21 and to deposit or invest at least S$350,000 in new funds (accessed 2026-10-23; the bank's website prevails).

Singapore-only details are on the remote account opening page of our sister site bankaccount.sg. If you would like help interpreting how this applies to you, you can register your enquiry through this site's contact details.