SFC Licence Applications

The Securities and Futures Commission licenses ten categories of regulated activity under the Securities and Futures Ordinance. Carrying on a regulated activity without the required licence is a criminal offence, exposing the firm and its officers to fines, prosecution and disqualification.

Licensees include securities brokers, investment advisers, wealth managers and portfolio managers: any business offering regulated investment services or advice. Some internal functions may fall outside the regime, but the SFC applies these distinctions strictly, and firms should obtain formal confirmation rather than assume an exemption.

Type 1: dealing in securities. Required for placing orders, brokering and OTC trades in listed and unlisted securities. It applies to brokerages, trading platforms and agents, and is frequently paired with a Type 4 licence.

Type 4: advising on securities. Required where a firm or individual gives client-facing recommendations, as distinct from research-only roles. It applies to financial advisers, wealth managers and portfolio consultants who issue opinions tied to securities transactions.

Type 9: asset management. Required for discretionary portfolio or fund management, covering hedge funds, family offices and robo-advisors. Capital thresholds, internal controls and responsible officer appointments are the usual pressure points.

Confirm the regulated activity, then identify responsible officers who meet the SFC's experience and competence requirements for each activity applied for.

Put the internal structure in place before filing: segregation of duties, compliance protocols, AML and CFT systems and risk controls.

Submit the corporate and responsible officer applications with supporting documents including group structure charts and business plans, together with the applicable licence fees, then respond promptly to SFC queries to avoid delay or resubmission.

On approval the licence is published on the SFC register and operations can begin, with CPT logs, responsible officer designations, internal audits and policy documentation established from day one. Most applications take 15 to 20 weeks; delays are usually caused by incomplete disclosure or unsuitable responsible officer profiles.

A licence brings continuing obligations: annual continuing professional training monitoring for every licensed individual, ongoing fit-and-proper assessment and role alignment for responsible officers, AML and risk management procedures, internal governance documentation and operating manuals, preparation for statutory annual audits, and regulatory reporting of any material change in structure, activity or staffing.

We also monitor licence scope so operations do not drift outside the approved activities, and support onboarding of new licensed representatives. Non-compliance can lead to suspension, public reprimand or revocation, and governance failures, audit lapses and underqualified personnel are the common triggers.