Funds & Private Wealth

SFC Type 4 Licence: Advising on Securities

Type 4 permits investment advice on securities, research reports and verbal recommendations to clients in Hong Kong. It does not permit discretionary portfolio management; that is Type 9. We position the application, prepare the sample reports and evidence the competence the SFC looks for.

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  • TCSP licence TC000446
  • Xero Silver Partner
  • Established 2002
  • HKFRS statutory accounts
  • Hong Kong and mainland China
  • One in-house team

How we help

SFC Type 4 with Primasia

Application and structure

Filing through WINGS-LIC, coordination with lawyers, auditors and compliance specialists, and the corporate structure required of a Type 4 licensee.

Personnel

Two or more responsible officers, one an executive director and one with securities advisory experience, prepared for SFC background checks and interviews.

Compliance

Advisory agreement templates, client onboarding, AML and KYC procedures, books and records, and regular reporting to the SFC.

Corporate support

Incorporation, physical office, registered office and company secretarial services, bank account opening, professional indemnity insurance and accounting.

What's included

  • Type 4 application and WINGS-LIC filing
  • Business plan, fee structure and sample advisory reports
  • Responsible officer identification and qualification
  • AML, KYC and client onboarding procedures
  • Capital structuring against the client-asset test
  • Annual filings, CPT monitoring and audit preparation

Who needs a Type 4 licence

Type 4 is one of the ten regulated activities in Schedule 5 of the Securities and Futures Ordinance and covers advising on securities: investment advice to clients, research reports, and verbal recommendations to securities clients in Hong Kong.

Most investment research firms, wealth management advisers and portfolio consultants need it. Equity research, bond research, structured product advice and investment strategy consulting all sit inside the licence. Discretionary account management, dealing and managing client portfolios do not: discretionary management requires a Type 9 licence and is prohibited under a Type 4 licence alone.

Why the licence is worth the effort

It gives the legal right to advise on securities in Hong Kong without exposure to penalties for unlicensed advisory activity, and it signals to professional investors that the firm meets the SFC's competence, financial stability and internal control standards.

It also opens access to Hong Kong's capital market and to cross-border advisory work linked to mainland China's securities and futures markets (the SFC recognises industry experience gained in the mainland in certain circumstances), and it allows the firm to charge for advisory services within a recognised regime.

Virtual asset advisory can be offered under a Type 4 licence in some cases. Firms advising on tokenised securities, security token offerings or virtual asset fund distribution need to show mature technology and compliance systems, and detailed record keeping across every advisory category.

TYPE 1TYPE 4TYPE 9

How long does it take to get an SFC Type 4 license?

According to the published service commitment of the SFC, it takes approximately 15 weeks from the date of receipt of a complete licensing application, but it is a service target, not a statutory deadline, and depends on various factors including complexity of the case, workload of the case officer and response of the applicant to queries on the business plan, sample reports and responsible officer qualifications. On average, an applicant can expect 3.5-4 months to obtain a license. Detailed documentation and preparedness of responsible officers facilitate the process. We make sure that your application is complete and help you to avoid any delays.

Requirements

What a Type 4 licence asks of you

Fit-and-proper criteria under section 129 of the SFO cover financial status, qualifications, experience, competence and reputation.

Capital

  • Not holding client assets: liquid capital of HK$100,000, no minimum paid-up capital
  • Holding client assets: paid-up capital of HK$5,000,000 and liquid capital of HK$3,000,000
  • Notify the SFC if liquid capital falls to or below the required minimum

Competence

  • Responsible officers: HKSI papers 1, 2, 7 and 8, or a recognised equivalent such as a CFA charter with waiver
  • Licensed representatives: papers 1, 7 and 8
  • Continuous professional training tracked for every licensed individual

Exemptions

  • Advice wholly incidental to a Type 1 dealing business
  • Solicitors and in-house legal advisers, where advice is incidental to legal practice
  • Group company, trustee and certain professional investor exemptions

Type 4 licensing

Start an investment advisory business in Hong Kong

From first consultation to licence, and on through annual filings, CPT management and audit preparation.

FAQs

SFC Type 4: questions we are asked most

What does a Type 4 licence allow me to do?+

Provide investment advice on securities, issue research reports and make verbal recommendations to clients in Hong Kong. It covers equity and bond research, structured product advice and investment strategy consulting. It does not permit discretionary portfolio management, which requires a Type 9 licence.

How much capital do I need?+

If the firm does not hold client assets, there is no minimum paid-up capital and liquid capital of HK$100,000. If it holds client assets, paid-up capital of HK$5,000,000 and liquid capital of HK$3,000,000 apply. The SFC must be notified if liquid capital falls to or below the required minimum.

What qualifications do responsible officers need?+

Responsible officers generally pass HKSI papers 1, 2, 7 and 8, or hold a recognised equivalent such as a CFA charter with the appropriate waiver. Licensed representatives take papers 1, 7 and 8. All licensed individuals must meet continuous professional training obligations, and the firm needs at least two responsible officers, one of whom is an executive director.

Are there exemptions from the Type 4 requirement?+

Yes. Advice wholly incidental to a Type 1 dealing business, advice by solicitors and in-house legal advisers incidental to legal practice, certain group company and trustee arrangements, and some professional investor situations can fall outside the requirement. We assess this before an application is prepared.

Can I advise on virtual assets under a Type 4 licence?+

In some cases. Firms advising on tokenised securities, security token offerings or virtual asset fund distribution need to demonstrate mature technology and compliance systems and maintain detailed records across every advisory category.

Let's start a conversation

Tell us where the business is heading. We will tell you what it takes to get the structure, books and filings in order.