HKSI Paper 1 vs the HKMA exams: they are not alternatives
HKSI Paper 1 is the examination route to SFC competence for regulated activity. The HKMA's Enhanced Competency Framework sets competency benchmarks for banking roles and does not license you for securities work. Bank staff doing regulated activity generally need Paper 1 as well, not instead.
People at banks ask this in a specific way: my employer is supervised by the HKMA, so surely I sit an HKMA exam rather than an HKSI one. Reasonable question. Wrong conclusion, and the reason is worth understanding because it explains a lot about how Hong Kong splits regulatory work.
The two bodies are not competing to qualify you. They regulate different things.
| HKSI Licensing Examination, Paper 1 | HKMA competency framework examinations | |
|---|---|---|
| Who sets the requirement | The Securities and Futures Commission, through its competence requirements | The Hong Kong Monetary Authority, through the Enhanced Competency Framework |
| Who administers the exam | HKSI Institute | Largely the Hong Kong Institute of Bankers and other approved bodies |
| What it is for | Being licensed or registered to carry on a regulated activity | Benchmarking competence for banking job families |
| Applies to | Individuals seeking to be licensed by the SFC or registered as relevant individuals of banks | Banking practitioners in the covered job families |
| Subject matter | The Securities and Futures Ordinance, SFC codes, licensing, client assets, market conduct | Banking specialisms such as anti-money laundering, wealth management, credit risk, compliance and treasury |
| Is it a licence? | It is the exam component of becoming licensable. The licence comes from the SFC | No. It is a competency benchmark |
| Format we can verify | 60 questions, 90 minutes, 70% pass mark, HKD 1,800, closed book | Varies by module. Check the administering body |
| Do you need both? | If you carry on regulated activity at a bank, generally yes | If your job family is covered, generally yes |
Why bank staff still sit an HKSI paper
Because the securities work a bank does is regulated under the Securities and Futures Ordinance, not under the banking rules. A bank carrying on regulated activity is a registered institution rather than a licensed corporation, and the individuals doing that work are entered on the register the HKMA maintains as relevant individuals.
The label is different. The competence expectation comes from the same place: the SFC's requirements for the activity. So the examination route runs through HKSI in both cases, and being on the bank side changes the paperwork rather than the syllabus.
This catches people out at the worst moment, usually a week into a new role when compliance asks for a result letter nobody mentioned at interview.
What the HKMA framework is actually doing
Raising and standardising competence across banking job families. Anti-money laundering and counter-financing of terrorism, retail wealth management, credit risk, compliance, treasury and others have their own modules and benchmarks, and they exist because the HKMA wanted a common floor across the industry rather than each bank inventing its own.
It is not a licensing gate for securities activity and does not pretend to be. If your role is entirely deposit-taking, credit or operations, it may be the only framework you ever meet.
Whether you personally need Paper 1, an ECF module, both, or neither depends on the exact activities in your job description and on the register you will sit on. Your firm's compliance function answers this question all the time and their answer is the one that binds. Ours is background.
Does the material overlap?
A little, in one place. Topic 6 of the Paper 1 syllabus covers anti-money laundering and counter-terrorist financing, which is also the subject of one of the better-known banking modules. Somebody who has done the banking version will find that slice of Paper 1 familiar.
That is one topic out of nine. The rest of Paper 1 is the Ordinance, licensing and registration, client money and client securities, the SFC conduct codes, the exchanges, listings and market misconduct, and none of that appears in a banking competency module in any recognisable form. Do not budget your study time on the assumption of transfer.
Which is harder?
Not comparable, and we will not pretend to rank them. What we can give you is the Paper 1 number, because HKSI publishes it: a mean of 51.9% over the twelve months to June 2026, with monthly figures between 47.4% and 61.84%. Roughly 48.1% of candidates did not pass.
Our opinion, aimed squarely at bank employees: Paper 1 is the one you are most likely to underestimate, and the reason is cultural rather than intellectual. Internal training at a large bank is generally good, well organised and handed to you. Paper 1 is none of those things by default. It is a self-directed exam with a 70% pass mark, and candidates used to being taught tend to under-plan it.
The concession: if your bank does run internal Paper 1 preparation, it is often excellent and it is free, and you should use it before you spend money anywhere else. That advice costs us sales and it is still the right advice.
Practical sequence for someone at a bank
- Get your compliance team to confirm, in writing, which register you will be on and which examinations that requires.
- If regulated activity is in scope, treat Paper 1 as the blocking item and book it early.
- Use internal training first. Then add timed practice, which internal programmes are usually light on.
- Handle the banking competency modules on their own timeline. They matter for your career, but they rarely gate a start date the way licensing does.
For the licensing side of this, which HKSI papers each regulated activity needs is the page to read next, and the SFC licence types explained covers the difference between a licensed corporation and a registered institution properly.
Common questions
Do I need HKSI Paper 1 if I work at a bank?
If your role involves carrying on a regulated activity under the Securities and Futures Ordinance, generally yes. Banks are registered institutions rather than licensed corporations, and their staff doing that work are relevant individuals, but the SFC competence expectation still applies.
Does an HKMA ECF qualification replace HKSI Paper 1?
No. The Enhanced Competency Framework benchmarks competence for banking job families. It is not the examination route to SFC competence for regulated activity, and holding one does not remove the licensing requirement for securities work.
Does the HKMA run its own licensing exam?
Not in the sense people mean. The HKMA supervises authorised institutions and maintains the register of relevant individuals, and it sets competency benchmarks delivered largely through the Hong Kong Institute of Bankers. Licensing for regulated activity sits with the SFC.
Is there any overlap between the two sets of exams?
One meaningful slice. Topic 6 of the Paper 1 syllabus covers anti-money laundering and counter-terrorist financing, which is also a well-known banking module subject. That is one topic of nine, so treat it as a small bonus rather than a shortcut.