Hong Kong SFC License 2026 — Type 1, Type 4 & Type 9 Regulated Activity Authorization Guide
The Securities and Futures Commission (SFC) is Hong Kong's primary regulator for capital markets and investment activities. Under the Securities and Futures Ordinance (SFO), any person carrying on a regulated activity in Hong Kong by way of business must be licensed by the SFC. The SFC currently supervises 10 types of regulated activities — the four most commercially relevant for international investment firms are Type 1 (Dealing in Securities), Type 4 (Advising on Securities), Type 9 (Asset Management), and Type 13 (Providing Depositary Services for Authorized Collective Investment Schemes, effective October 2024). SFC licensing is the institutional standard for asset managers targeting Greater China, ASEAN, and global institutional capital — it carries the same credibility as an FCA or ASIC license and significantly more credibility than any offshore alternative for institutional counterparties in Asia. Capital requirement for Type 9 without client asset custody: HKD $100,000 liquid capital only — making it one of the most accessible institutional-grade licenses globally for fund managers using third-party custodians.
The 10 SFC Regulated Activity Types
| Type | Activity | Who needs it |
|---|---|---|
| Type 1 | Dealing in Securities | Securities brokers, online trading platforms |
| Type 2 | Dealing in Futures Contracts | Futures brokers |
| Type 3 | Leveraged Forex Trading | Retail leveraged FX dealers |
| Type 4 | Advising on Securities | Investment advisors, research firms |
| Type 5 | Advising on Futures Contracts | Futures advisors |
| Type 6 | Advising on Corporate Finance | M&A advisors, IPO sponsors |
| Type 7 | Providing Automated Trading Services | ATS/exchange operators |
| Type 9 | Asset Management | Fund managers, portfolio managers |
| Type 10 | Providing Credit Rating Services | Rating agencies |
| Type 13 | Providing Depositary Services | Fund depositaries (from Oct 2024) |
Most international firms apply for Type 9 alone, or Type 1 + Type 9 combined. A Type 9 fund manager does not need a separate Type 4 (advisory) license for advice given to the funds it manages — the incidental exemption applies.
Capital Requirements by License Type
Type 1 (Dealing in Securities)
- •Paid-up share capital: HKD $5,000,000
- •Liquid capital: HKD $3,000,000 (floor) OR 5% of adjusted liabilities if higher
Type 4 (Advising on Securities)
- •Paid-up share capital: HKD $100,000 (if not holding client assets)
- •Liquid capital: HKD $100,000
Type 9 — NOT holding client assets
- •Paid-up share capital: No requirement
- •Liquid capital: HKD $100,000
- •Most cost-efficient entry point — for fund managers using a licensed custodian or prime broker
Type 9 — HOLDING client assets directly
- •Paid-up share capital: HKD $5,000,000
- •Liquid capital: HKD $3,000,000
Personnel Requirements
Every SFC-licensed corporation must appoint:
Responsible Officers (ROs)
Minimum 2 per licensed activity. At least 1 must be an executive director. ROs must meet SFC competence requirements — relevant qualifications and experience in the specific regulated activity.
Licensed Representatives
Individuals conducting regulated activities on behalf of the corporation must be separately licensed as representatives.
Managers-in-charge (MICs)
Key management functions including Overall Management Oversight, Operational Control, Risk Management, Finance & Accounting, Information Technology, and Compliance must each have a named MIC. Larger firms need additional MIC appointments.
Compliance Officer
Named compliance officer with documented reporting lines to the board.
Type 9 Asset Management — The Accessible Institutional License
The SFC Type 9 license is one of the most commercially valuable institutional licenses globally for fund managers at the growth stage. The reason is capital efficiency: a fund manager that uses a licensed custodian (prime broker or fund depositary) to hold client assets does not need to hold client assets itself — and therefore qualifies for the "Does Not Hold Client Assets" capital framework. This means:
- •No paid-up capital requirement
- •HKD $100,000 (approximately USD $13,000) liquid capital only
- •Full Type 9 authorization — discretionary portfolio management, fund management, managing private equity vehicles
For private equity firms, hedge fund managers, family office managers, and boutique asset managers accessing institutional capital from Greater China and Asia — the Type 9 license at HKD $100K liquid capital is an exceptional value proposition.
SFC License + Hong Kong VASP
In 2026, the SFC is also the regulator for virtual asset trading platforms (VATP) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO). The SFC is developing additional licensing for virtual asset dealers and custodians, with legislative proposals expected to be introduced to the Legislative Council in 2026 (confirmed December 2025 by FSTB and SFC jointly).
For firms seeking both SFC Type 9 and VATP authorization — or building digital asset fund management structures in Hong Kong — Zitadelle AG advises on combined licensing strategy.
How the Process Works
Initial Consultation
1–2 daysFree scoping call — jurisdiction selection, structure, capital requirements, and timeline assessment.
Document Collection
2–4 weeksGather all required KYC, corporate, and background documentation for all directors, shareholders, and UBOs.
Application Preparation
4–12 weeksPreparation of the full application package — business plan, compliance programme, financial projections, and regulatory documentation.
Submission & Review
6–12 monthsSubmission to the regulator. Our team manages all follow-up queries and information requests during the assessment period.
License Issued
6–12 monthsAuthorization granted. Post-licensing support covers compliance setup, banking introductions, and ongoing regulatory obligations.
Application Timeline
- Step 1:Corporate structure — Hong Kong limited company incorporation (or registration of overseas company).
- Step 2:Personnel appointment — identify ROs with qualifying competence (SFC assesses industry experience, professional qualifications, and fit and proper history for each RO).
- Step 3:Application preparation — business plan, compliance manual, AML/CFT policies, financial projections, internal control system questionnaire, risk management framework.
- Step 4:SFC submission — application forms + HKD $4,720 fee.
- Step 5:SFC review — acceptance letter issued after preliminary review. Further queries are common. SFC interviews ROs as part of the review process.
- Step 6:Authorization — SFC issues license. Firm added to public SFC register of licensees.
Timeline: 6–12 months. Applications with well-documented RO competence, clean compliance manuals, and clear business plans process faster.
Frequently Asked Questions
For a Type 9 (Asset Management) license where the firm does NOT hold client assets directly — using a licensed custodian or prime broker instead — the minimum is HKD $100,000 in liquid capital (approximately USD $13,000) with no paid-up share capital requirement. For firms that DO hold client assets directly, HKD $5,000,000 paid-up share capital and HKD $3,000,000 liquid capital are required.
Ready to Obtain Your Hong Kong SFC License?
The SFC Type 9 license — from HKD $100,000 liquid capital — is one of the most capital-efficient institutional asset management authorizations in the world for fund managers using third-party custodians. Contact Zitadelle AG to assess your activity types, Responsible Officer requirements, and application strategy.
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Read more →Disclaimer: This page is provided for informational purposes only and does not constitute legal or regulatory advice. SFC requirements and the Securities and Futures Ordinance framework may change. Always consult a qualified advisor before initiating a licensing process. Last updated: June 2026.