SFC License Types 1 to 13: What Is in Operation?

A claim that someone is “SFC licensed” leaves out the useful details. Check the regulated activity, the person’s capacity, and the firm to which an individual is accredited. An approval for Type 1 dealing does not automatically cover Type 9 asset management. Equally, the thirteen entries in the statute are not thirteen activity licenses that an applicant can obtain today: the SFC says Types 11 and 12 are not yet in operation for licensing purposes.

What the SFC actually licenses

Part V of the Securities and Futures Ordinance sets out Hong Kong’s activity-based licensing regime. Schedule 5 lists thirteen regulated activity categories. A firm that carries on an in-force activity as a business in Hong Kong generally needs the relevant license or registration unless a statutory exclusion or exemption applies. The numbered types are a useful vocabulary, but the number alone does not settle whether a particular product, service, person, or firm falls within a definition. Read the SFC’s current licensing page alongside the statute.

The examples in the table are illustrations, not a substitute for the legal definitions. A firm can deal, advise, manage assets, or perform more than one activity. The SFC’s page currently places a footnote beside Types 11 and 12 saying they are “not yet in operation for licensing purposes.” They remain on the statutory list, but the SFC does not treat them as currently available licensing categories.

This distinction matters in an exam question and in a real application. If an item asks how many categories Schedule 5 names, the answer is thirteen. If it asks whether a firm can now obtain a Type 11 or Type 12 license, the SFC’s current answer is no. A firm active in OTC derivatives may still have duties under other current licenses and separate reporting or clearing rules. The non-commencement of these two licensing categories is not an across-the-board exclusion from regulation.

Type 13 is different. It covers depositary services for certain collective investment schemes and is already in operation. It should not be grouped with Types 11 and 12 merely because its number is higher. For a fund trustee or custodian, the exact meaning of “relevant CIS,” the position in the custody chain, and the SFC’s Type 13 guidance matter more than the simple label. A student of Paper 1 should learn the category while leaving an actual licensing assessment to the current SFC requirements.

One firm or person can hold several types

A corporation may apply for more than one activity, and a representative can be accredited for more than one activity where the firm and individual meet the relevant requirements. For example, a securities broker considering advisory work must assess whether Type 4 is needed alongside Type 1. Some activity definitions contain exclusions that can affect the result, so “we also give advice” is a prompt to check the SFC’s rules, not an automatic conclusion that every broker needs Type 4. Likewise, an asset manager should test whether its distribution activity fits an existing exemption before assuming it needs another type.

For a candidate, the practical point is to identify the intended activity before choosing an exam. Competence is assessed for the activity and role in the application. Two people with a similar job title may face different requirements because their actual work and level of responsibility differ. The SFC may also consider recognized qualifications, experience, and exemptions; a title-to-paper shortcut can lead to paying for the wrong exam.

Consider a candidate offered a role at a firm that trades listed shares for clients and publishes research. First establish what the person will actually do: taking orders, preparing advice, supervising colleagues, or several of these. Then confirm which activity types the firm holds and whether an exclusion applies. Only then should the candidate check the SFC competence guidelines and the HKSI paper mapping. The firm’s licensing team should be able to explain the proposed accreditation in concrete terms.

Another common case is a firm that runs a discretionary portfolio for clients. Type 9 is the central asset-management category. A sale or distribution channel might raise another activity question, but the answer depends on its conduct and any applicable exemption. A person should avoid buying a stack of study manuals from a generic “finance license” list. The SFC evaluates applications against the activity actually proposed, while HKSI publishes the current examinations that can meet particular competence components.

Corporation, representative, responsible officer

Three different things get licensed, and confusing them is the single most common misunderstanding among people new to the regime.

A licensed representative is accredited to a licensed corporation and acts for it in the approved activity. The SFC describes an individual application as a joint application by the person and the corporation to which the person is, or proposes to be, accredited. Changing firms therefore calls for a licensing process; an exam pass alone does not authorize independent client work. See our licensed-representative guide for the route.

Do not merge a licensed corporation with a registered institution. The SFC licenses qualifying corporations that are not authorized financial institutions. An authorized institution, such as a bank, is registered to carry on its regulated activities and its relevant individuals sit within a different supervisory arrangement involving the HKMA. The SFC’s public register covers both licensed persons and registered institutions, so you can check the actual status rather than infer it from a company’s name.

Responsible officer is also a distinct role. The SFC says a licensed corporation should appoint at least two responsible officers for each regulated activity, with at least one of them an executive director. At least one responsible officer must be available at all times to supervise the business of that activity. A person can be approved for more than one activity where they meet the requirements and roles do not conflict. A candidate applying as a representative should not assume that passing Paper 1 also qualifies them to supervise an entire business line.

Where HKSI Paper 1 fits

The SFC assesses whether an applicant is fit and proper and competent for the proposed activity and role. Its Guidelines on Competence distinguish local regulatory framework papers from recognized industry qualifications, with the relevant requirements varying by activity. HKSI Paper 1 tests fundamentals of securities and futures regulation and can serve as a local regulatory framework paper for relevant routes. It is not a universal paper for every type or every applicant, and the SFC may grant specified exemptions where its criteria are met.

Which practical paper depends on the activity, and the mapping is HKSI's to publish, not ours to guess. We have set out the shape of the requirement in which HKSI papers you actually need and pointed you at the current list. If you want the exam itself first, start with what HKSI Paper 1 covers.

The safest exam-planning sequence is short. Confirm whether you will seek an individual license or act as a relevant individual of a registered institution. Identify the regulated activity and whether you are applying as a representative or responsible officer. Then consult the current SFC competence guidelines and HKSI’s examination mapping for that combination. Ask the prospective firm’s licensing or compliance team about any recognized qualification or exemption before paying an examination fee.

An exam pass and a license are different milestones. You can prepare for and pass an HKSI examination, but the SFC still decides the application, which involves the firm and checks beyond examination results. Conversely, an applicant with qualifying experience or another accepted qualification may have an exemption from a particular examination component. This is why a useful study page should explain Paper 1 without implying that it is the same as permission to carry on Type 1, Type 9, or any other activity.

How to see what somebody actually holds

The SFC runs a free public register of licensed persons and registered institutions. Search a name or a firm and you get the regulated activity types, the accreditation, the responsible officer flag, and any public disciplinary history. It takes about a minute. Use it on a prospective employer before you accept a role - if the firm does not hold the Type the job description implies, you have a problem to raise at interview rather than after you resign.

How to use the list without misreading it

For study, learn the names and broad distinctions of the operative activity types. Type 1 deals in securities; Type 4 advises on securities; Type 9 manages assets. Keep separate the statutory count of thirteen and the present licensing status of Types 11 and 12. That single distinction prevents the table from turning into an incorrect claim about licenses available today.

For a job or business decision, start with the work rather than the title on a vacancy. Write down what service will be offered, to whom, by which entity, and in what capacity. Check the SFC activity definitions and public register, then ask the firm’s licensing team for the proposed activity and role. A person joining an existing firm should also confirm which corporation will sponsor the application and whether the firm holds the relevant activity.

The table is a map, not an answer to every borderline case. Dealing and advising can overlap in ordinary language while the legal definitions, exclusions, and facts produce a more specific result. Depositary services also involve a defined category of collective investment schemes rather than every custody arrangement. When a product or service sits near a boundary, use the current SFC guidance and obtain professional advice before acting. For exam purposes, use the wording and reference date given in the question.

If you need to prepare for the regulatory paper itself, use the Paper 1 exam guide and compare the current HKSI study guide. HKSI says its Version 3.5 Paper 1 guide applies to examinations from 30 June 2026. Checking the applicable study-guide version helps you avoid practicing against an old syllabus even when the broad licensing categories have familiar names.