SFC Licensed Corporation Application
Professional Financial Advisory Services
Licensed corporations under the SFC are the primary type of licensed intermediaries. We assist with all 13 categories of regulated activities (RAs).
Key Requirements for Corporate License Application
Incorporation: Applicant must be a company incorporated in Hong Kong or an overseas company registered with the Companies Registry under Part 16 of the Companies Ordinance.
Capital Requirements: Minimum liquid capital and paid-up share capital vary by RA (see table below for reference).
Management and Governance: Robust internal controls, include but not limited to segregation of duties, risk management, and proper manager-in-charge (MIC) structure.
Premises and Operations: Secure and suitable office premises in Hong Kong, with adequate IT systems and business continuity plans.
Fit and Proper Assessment: Applies to the corporation, substantial shareholders, directors, and ROs. Factors include criminal records, disciplinary history, and relevant experience.
Responsible Officer (RO) Requirements
Responsible officer (“RO”), in relation to a licensed corporation, means an individual who is approved by the SFC under section 125 of the SFO as a RO of the licensed corporation. A RO of a licensed corporation is also a licensed representative of that corporation for the regulated activities under his or her supervision.
Number of RO Required: At least two ROs per RA, with at least one being an executive director of the corporation. This ensures continuous supervision; additional ROs may be needed for complex operations.
Relevant Industry Experience: At least 3 years over past 6 years. For certain RAs (e.g. Type 6 if apply with takeovers codes; VA-related License etc.) additional experience is required.
Local regulatory framework paper (“LRP”) Requirements: ROs must pass related Exam Papers, set out in clause 4.2.3.1 of the Guidelines on Competence.
Role and Responsibility: ROs must be available at all times to oversee the RA, demonstrate industry knowledge.
Minimum Paid-up Share Capital and Liquid Capital Requirements
| RAs Number | RAs | Minimum Paid-up Share Capital (HKD) | Minimum Liquid Capital (HKD) |
|---|---|---|---|
| 1 | As approved introducing agent | N/A | 500,000 |
| 1 | Provides securities margin financing; or Acts as custodian of private OFC | 10,000,000 | 3,000,000 |
| 1 | in any other case | 5,000,000 | 3,000,000 |
| 2 | Acts as approved introducing agent, trader, or futures non-clearing dealer. | N/A | 500,000 |
| 2 | in any other case | 5,000,000 | 3,000,000 |
| 3 | As approved introducing agent | 5,000,000 | 3,000,000 |
| 3 | in any other case | 30,000,000 | 15,000,000 |
| 4 | Not hold client assets | N/A | 100,000 |
| 4 | in any other case | 5,000,000 | 3,000,000 |
| 5 | Not hold client assets | N/A | 100,000 |
| 5 | in any other case | 5,000,000 | 3,000,000 |
| 6 | Act as sponsor; and hold client assets | 10,000,000 | 3,000,000 |
| 6 | Act as sponsor; and not hold client assets | 10,000,000 | 100,000 |
| 6 | Not act as sponsor; and hold client assets | 5,000,000 | 3,000,000 |
| 6 | Not act as sponsor; and not hold client assets | N/A | 100,000 |
| 7 | N/A | 5,000,000 | 3,000,000 |
| 8 | N/A | 10,000,000 | 3,000,000 |
| 9 | Not hold client assets | N/A | 100,000 |
| 9 | in any other case | 5,000,000 | 3,000,000 |
| 10 | Not hold client assets | N/A | 100,000 |
| 10 | in any other case | 5,000,000 | 3,000,000 |
| 11 | N/A | (To be determined) | (To be determined) |
| 12 | N/A | (To be determined) | (To be determined) |
| 13 | N/A | 10,000,000 | 3,000,000 |
Virtual Asset-Related Activities
Virtual assets (“VAs") include cryptocurrencies and tokens that may or may not qualify as securities under the SFO. Table below fall under existing RAs but have Virtual asset-related activities:
| Regulated Activities (RAs) | Virtual Asset-related Activities |
|---|---|
| RA1 and RA7 | *Operating a Virtual Asset Trading Platform (“VATP”) |
| RA1 | *Providing VA Dealing Services under an Omnibus Account Arrangement |
| RA1 | *Acting as an Introducing Agent for a VATP |
| RA4 | *Providing VAs Advisory Services |
| RA9 | *Managing Portfolios that Invest More than 10% in VAs |
| RA9 | #Managing Portfolios that Invest Less than 10% in VAs |
*subject as licensing condition
#not subject as licensing condition
Before You Start
Define a shareholding structure and incorporate a Hong Kong limited company.
Appoint 2 proposed ROs who meet the competence requirements.
Establish the organizational structure and MICs of Core Functions.
Develop your business plan and line of business.
Design the internal controls that fits your proposed business.
Timeline
Under normal circumstances, the entire process takes approximately 5 to 9 months.
Preliminary Preparations: Approximately 1 to 2 months.
RO Recruitment (if needed): Approximately 1 month.
SFC Review: Upon submission, typically 4 to 7 months. timeframe may extend based on factors including complexity and volume of applications.