Which HKSI papers do I need for my SFC licence?
Almost every applicant sits Paper 1, the common paper on securities and futures regulation. On top of that you sit a practical paper matched to your regulated activity, and responsible officers face an additional requirement. Recognised alternative qualifications can replace papers. HKSI publishes the current pairings; confirm yours before enrolling.
This is the question that sends people round in circles for a fortnight, usually because they are asking it in the wrong order. You cannot pick papers first. You pick papers last, after you know three things: which regulated activity you will carry on, whether you are going in as a representative or a responsible officer, and whether anything you already hold counts as a recognised alternative.
The requirement has layers, not a lookup table
The SFC sets competence. HKSI sets and marks the papers that satisfy part of it. What the SFC publishes is a framework with several routes through, and the examination route is only one of them. Get the shape right and the specifics fall out easily.
| Layer | What it covers | Who it applies to |
|---|---|---|
| Common paper - Paper 1 | Fundamentals of securities and futures regulation: the Ordinance, the SFC codes, licensing, conduct, market misconduct | Almost every applicant taking the examination route, representative or responsible officer |
| Practical paper | The mechanics and rules of the specific activity you will carry on | Matched to your regulated activity type |
| Responsible officer requirement | Regulatory knowledge at supervisory level, plus management experience the SFC assesses separately | Anyone applying for RO approval |
| Recognised alternatives | Named degrees, professional designations and overseas qualifications the SFC accepts instead of papers | Applicants who hold one - the SFC publishes the accepted list |
| Exemptions | Relief from one or more papers on the basis of qualification or industry background | Assessed case by case; do not assume you have one |
Notice what is not in that table. There is no column of paper numbers. That is deliberate, and I will explain why below.
What the practical paper is about, by activity type
The practical paper follows the activity. If you will be executing securities trades, it covers dealing practice for securities. If you will be running money, it covers asset management. The subject matter is predictable even when the paper number is not, so here is the mapping by topic rather than by number.
| Type | Regulated activity | What your practical paper will be about |
|---|---|---|
| 1 | Dealing in securities | Securities dealing practice: order handling, the exchange rules, client agreements, settlement |
| 2 | Dealing in futures contracts | Futures dealing practice: margin, contract specifications, HKFE rules, client positions |
| 3 | Leveraged foreign exchange trading | Leveraged FX practice and the specific conduct rules for that business |
| 4 | Advising on securities | Advisory practice: suitability, research standards, conflicts, disclosure |
| 5 | Advising on futures contracts | Futures advisory practice and the derivatives conduct rules |
| 6 | Advising on corporate finance | Corporate finance practice: listing rules, sponsor duties, takeovers |
| 8 | Securities margin financing | Margin lending practice and the client money and securities rules |
| 9 | Asset management | Asset management practice: the Fund Manager Code of Conduct, discretionary mandates, valuation |
| Others | Types 7, 10, 11, 12 and 13 | Specialist regimes. Requirements differ and several are handled outside the standard paper route |
HKSI changes its paper structure and its recognised-qualification mapping from time to time. A confident wrong table on this page would cost you an enrolment fee and a sitting cycle. Check the current pairing on the HKSI Institute's licensing examination pages, or ask your firm's compliance team to confirm it in writing, before you pay for anything.
Representative or responsible officer?
These are not two grades of the same licence. A responsible officer is a representative who has additionally been approved to supervise a regulated activity, and the SFC looks at management experience and industry background as well as examinations. The examination burden is higher. The evidential burden about what you have actually done in your career is much higher.
Most people reading this are going in as a representative. If you are aiming higher, the detail sits in our note on becoming a responsible officer in Hong Kong.
Before you enrol, do these four checks
- Confirm the activity types on the application. Ask your sponsoring firm which types you are being accredited to, in writing. Not the job title. The types.
- Check the SFC's recognised alternatives against what you already hold. A relevant degree or a professional designation may cover part of the requirement. This is the check people skip, and it is the one that saves the most money.
- Ask compliance whether the firm has a view on exemptions. They deal with the SFC regularly and will know what has and has not been accepted for people in your position.
- Only then look up the current HKSI paper for your activity, and enrol.
Which paper to sit first
Paper 1 first. Almost always. It is the paper whose content underpins everything in the practical papers, it is the one your compliance team will chase you on, and the regulatory vocabulary it drills makes the practical paper materially easier to read. Sitting the practical paper cold, before you know what the Ordinance actually requires, is doing the work twice.
There is a reasonable counter-argument if your practical paper is close to your day job and Paper 1 is not. Somebody who has traded futures for years may find the futures paper almost free and Paper 1 a genuine slog. Banking a quick pass first can be good for morale. We have set the two orderings against each other in which HKSI paper to take first.
What this costs you in total
Paper 1 alone is HKD 1,800 a sitting, and about half of candidates do not pass first time, so budget for the possibility of two. Add the practical paper, add annual licensing costs your employer may or may not absorb, and the number gets real. The full arithmetic is in our breakdown of the total cost of getting licensed.
One thing worth conceding: for a large share of candidates this whole question resolves in a single email. Your compliance team already knows the answer for your seat, because they have licensed six people into it before you. Ask them before you spend an evening reading forum threads written by strangers about a different regulated activity.
Common questions
Do I need Paper 1 for every SFC regulated activity?
Paper 1 is the common paper and applies to almost everyone taking the examination route, across activity types. The exceptions come from recognised alternative qualifications or exemptions rather than from the activity itself. Check the SFC's competence requirements against your own qualifications before assuming you are covered.
How many HKSI papers do I have to pass?
The usual pattern for a representative is two: Paper 1 plus one practical paper matched to your regulated activity. Responsible officers face an additional requirement. If you are being accredited to several activity types, the number can rise. Your sponsoring firm should confirm the exact set.
Can a degree replace an HKSI paper?
Sometimes. The SFC publishes a list of recognised industry qualifications and academic qualifications that can satisfy part of the competence requirement. Whether yours counts depends on the specific qualification and the specific activity, so check the SFC's current list rather than relying on what a colleague was told.
Which HKSI paper should I sit first?
Paper 1, in most cases. Its content sits underneath the practical papers, and the regulatory vocabulary makes everything afterwards easier to read. The exception is a candidate whose day job maps directly onto the practical paper, who may prefer to bank an easier pass first.
Do I need papers before applying, or can I apply first?
The competence requirement has to be satisfied for the SFC to grant the licence, so in practice the examinations come first or run alongside a firm's onboarding. Employers routinely make a start date conditional on passes. Ask your sponsoring firm what their sequence is before you plan around it.