1. Step one: pick the right regulated activities
Schedule 5 of the Securities and Futures Ordinance (Cap.571) defines every regulated activity. Picking the wrong types — or missing one — is the single biggest source of slow applications. Map each part of your business to the list:
| Type | Activity | Typical applicants |
|---|---|---|
| Type 1 | Dealing in securities | Brokers, placing agents, fund-distribution platforms |
| Type 2 | Dealing in futures contracts | Futures brokers |
| Type 4 | Advising on securities | Research houses, investment advisers, intermediaries giving advice during placements |
| Type 6 | Advising on corporate finance | Financial advisers, sponsors |
| Type 9 | Asset management | Fund managers, discretionary portfolio managers |
| Type 7 | Automated trading services (ATS) | Platform operators (also required for VATPs) |
2. Corporate-level requirements
- HK-incorporated company (or overseas company registered with the Companies Registry)
- At least two Responsible Officers, at least one an executive director — see the RO eligibility guide
- Financial resources: minimum paid-up capital and liquid capital under the Securities and Futures (Financial Resources) Rules (Cap.571N); thresholds differ by RA and whether you hold client assets — holding client assets raises the bar substantially
- Competence: the corporation's structure, internal controls and compliance function must convince the SFC you can actually run this
- Fit and proper: the corporation, substantial shareholders, directors and ROs are all vetted under the Fit and Proper Guidelines
- MIC structure: Manager-in-Charge appointments and reporting lines designed up front
3. Process and timeline
Internal mapping: RA classes, RO candidates, capital, business plan, internal control manuals — get this right and the rest goes smoothly
Submit via WINGS (the SFC's e-services portal): corporate licence + RO applications + substantial shareholder approvals in parallel
The SFC issues requisitions (question lists); each round of supplementary filings takes as long as you let it — reply speed drives total time
Approval-in-principle: remaining conditions (premises, systems, personnel evidence) satisfied, then licensed
Licence takes effect with any conditions; the ~15-week pledge runs from formal acceptance
4. Most common delay and rejection causes
- Wrong or missing RA classification — e.g. missing Type 4 (advising) or blurring the Type 1 / Type 9 boundary
- Weak RO competence evidence — unclear relevant-experience years, thin management experience, missing qualification records; non-sole condition negotiations add rounds
- Boilerplate business plan — no concrete client segment, revenue model, or firm-specific internal controls
- Substantial shareholder issues — complex shareholding, unexplained funding sources, unnotarised overseas documents
- Compliance arrangements unclear — who performs the compliance function, what external consultants actually do
5. Official sources
| Document | Link |
|---|---|
| SFC application procedures page (incl. processing pledges) | sfc.hk ↗ |
| Licensing Handbook | sfc.hk ↗ |
| Guidelines on Competence | sfc.hk ↗ |
| Fit and Proper Guidelines | sfc.hk ↗ |
| Securities and Futures Ordinance (Cap.571), Schedule 5 — RA definitions | elegislation.gov.hk ↗ |
| Securities and Futures (Financial Resources) Rules (Cap.571N) | elegislation.gov.hk ↗ |
| WINGS e-filing portal | wings.sfc.hk ↗ |
6. FAQ
How long does it take?
~15 weeks from formal acceptance per the SFC pledge, but requisitions, RO condition talks and shareholder vetting stretch it — 6–12 months is common in practice.
Minimum number of ROs?
Two per RA type, at least one an executive director. Details in the RO guide.
Buy a shelf licensed company?
Possible, but substantial-shareholder change needs prior SFC approval under similar scrutiny, and you inherit the company's history — liabilities, licence conditions, compliance record. Not a shortcut.
Can an individual get licensed without a company?
No — licences go to corporations. Individuals are licensed representatives accredited to a licensed corporation, or nominated as ROs by it.