Effective 30 September 2025, the Hong Kong Monetary Authority (HKMA) will implement Phase 2 of its Mandatory Reference Checking (MRC) Scheme.
It was formally announced by the HKMA in its 24 July 2025 circular, which outlines the expanded scope, updated operational details, and implementation timeline.
This marks a significant expansion from Phase 1, which focused on senior management, to now include:
- Staff licensed or registered to conduct securities, insurance, and Mandatory Provident Fund (MPF) regulated activities.
What’s Changing?
- Expanded Scope: The scheme now applies to a broader group of regulated roles.
- Seven-Year Look-Back: Employers must request conduct-related reference information covering the past seven years.
- Standardised Response Format: Reference-providing institutions must respond within one month using the HKMA’s MRC template.
- Updated Guidance: Includes practical examples and clarifies what constitutes reportable misconduct.
What This Means for You
These changes may require updates to your hiring processes, employment contracts, consent forms, and internal workflows. HR, compliance, and recruitment teams should begin reviewing current practices and preparing for implementation.
While the MRC Scheme is not a formal supervisory requirement, repeated non-compliance may raise concerns about governance and internal controls.
How RMI Can Support You
RMI works with financial institutions across Asia to help them adapt to evolving regulatory requirements. We can assist with aligning your background screening processes to meet the new MRC obligations, ensuring readiness ahead of the September deadline.
Whether you’re an existing client or exploring screening solutions for the first time, feel free to reach out to your RMI account manager or contact us directly to discuss how we can support your transition into Phase 2.
