Asset management licence in Hong KongOverview
Under the Securities and Futures Ordinance, a corporation that carries on a business of managing a portfolio of securities or futures contracts for another person must be licensed for Type 9 regulated activity. This covers discretionary account managers, managers of private funds and managers of SFC-authorised funds. Firms that also market funds they do not manage, or deal for clients outside their mandates, may need Type 1 (dealing in securities) or Type 4 (advising on securities) licences as well, although incidental exemptions apply in defined circumstances. Leveraged foreign exchange trading is licensed separately as Type 3 and carries considerably higher financial and fee obligations.
Financial resources depend on whether the firm holds client assets. A Type 9 firm subject to a licensing condition that it will not hold client assets needs liquid capital of at least HK$100,000 and has no minimum paid-up capital requirement. In all other cases, the firm needs HK$5 million paid-up share capital and HK$3 million liquid capital. Applicants should also show they can cover operating expenses for at least the first six months.
People are at the centre of the regime. At least two responsible officers must be approved for each regulated activity; one must be an executive director, and at least one must be available at all times and ordinarily resident in Hong Kong. The SFC also requires the firm to identify managers-in-charge for eight core functions: overall management oversight, key business line, operational control and review, risk management, finance and accounting, information technology, compliance, and AML/CFT. Responsible officers must satisfy competence requirements based on qualifications, relevant industry experience, management experience and a local regulatory framework examination.
The SFC estimates around 15 weeks to process a complete corporate licence application, 10 weeks for a responsible officer and 8 weeks for a representative, with applications filed and tracked through its WINGS platform. After a waiver period, the SFC resumed collection of annual licensing fees from 1 April 2025. Licensees must maintain financial resources at all times, submit financial returns and audited accounts, and comply with the Code of Conduct and Fund Manager Code of Conduct.
Key benefits
- Access to one of Asia's deepest capital markets and investor bases
- Credible regulatory status valued by institutional investors and family offices
- Low capital entry point for managers that do not hold client assets
- Clear, published competence and financial resources requirements
- Ability to manage private funds, including Hong Kong Limited Partnership Funds and Open-ended Fund Companies
- Strong legal system and professional services ecosystem
- Pathway to add Type 1 or Type 4 activities as the business grows
Requirements
- A company incorporated in Hong Kong or an overseas company registered in Hong Kong
- Financial resources of HK$100,000 liquid capital, or HK$5m paid-up and HK$3m liquid capital where client assets are held
- At least two approved responsible officers, one an executive director and one resident in Hong Kong
- Managers-in-charge identified for all eight core functions
- Fit and proper substantial shareholders, directors and licensed individuals
- Competence of responsible officers, including the local regulatory framework paper unless exempt
- Adequate premises, internal controls and record-keeping in Hong Kong
- Appointment of an auditor and compliance with ongoing financial reporting
- AML/CFT systems in line with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance
Licence options & capital
Type 9 without client assets
HK$100,000 liquid capital
The most common route for discretionary managers and private fund managers whose assets are held by independent custodians.
Type 9 holding client assets
HK$5m paid-up, HK$3m liquid capital
For firms that hold client money or securities. Higher capital and stronger controls apply.
Type 9 with Type 1 and/or Type 4
Highest applicable requirement
For managers that also distribute third-party funds or advise outside their mandates, where incidental exemptions do not apply.
Type 3 leveraged FX trading
Separate, higher requirements
Required for retail leveraged forex. The annual licensing fee for a licensed corporation is HK$129,730, reflecting the demanding regime.
Step-by-step process
- 1
Scope analysis
Confirm which regulated activities are needed and whether incidental exemptions apply.
- 2
Corporate and premises
Set up the Hong Kong entity, office and bank account, and inject capital.
- 3
People
Identify responsible officers and managers-in-charge, and confirm competence and examination status.
- 4
Policies and business plan
Prepare the business plan, compliance manual, AML/CFT manual and operational policies.
- 5
Submission via WINGS
File corporate and individual applications and answer the SFC's requisitions.
- 6
Approval and launch
Satisfy any conditions, receive the licence electronically and start regulated business.
Typical documents
- Corporate licence application and individual applications for responsible officers
- Certificate of incorporation, articles and shareholding structure chart
- Business plan and financial projections covering at least six months of expenses
- Evidence of financial resources and bank statements
- CVs, qualifications and employment references for responsible officers
- Managers-in-charge organisational chart and confirmations
- Compliance manual and AML/CFT policies
- Office tenancy agreement
- Fit and proper information for substantial shareholders and directors
How Legal Wealth helps
Legal Wealth works with founders and family offices to determine the right licensing scope in Hong Kong, design the governance around responsible officers and managers-in-charge, and prepare a submission that answers the SFC's likely questions in advance. We treat shareholder and investor information discreetly and coordinate the licensed manager with any fund vehicles, holding structures and succession arrangements. Contact info@legalwealthglobal.com for a confidential review.
Enquire with Legal WealthFrequently asked questions
Do single family offices need a Type 9 licence?
A single family office that manages only the assets of one family and its own group entities may fall outside the licensing requirement, but the analysis depends on the exact structure. Multi-family offices managing third-party assets generally need a licence.
What is the minimum capital?
HK$100,000 liquid capital if the firm will not hold client assets. Otherwise, HK$5 million paid-up share capital and HK$3 million liquid capital.
How many responsible officers are required?
At least two for each regulated activity, one of whom must be an executive director. At least one must be available at all times and ordinarily resident in Hong Kong.
How long does the SFC take?
The SFC estimates about 15 weeks for a corporate licence once a complete application is received. Complex structures or incomplete answers can extend this.
Does a Type 9 licence allow retail forex trading?
No. Leveraged foreign exchange trading is a separate Type 3 regulated activity with substantially higher requirements.
Are annual fees payable?
Yes. The SFC resumed annual licensing fees from 1 April 2025, at HK$4,740 per regulated activity for a corporation and HK$4,740 per activity for each responsible officer.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
