SFC Licence Requirements for Representatives

Passing Paper 1 is one of four things the SFC looks at before it licenses you as a representative. The other three are whether you are fit and proper, whether you are attached to a licensed firm, and whether you will keep your knowledge current once licensed. This is a summary of each, with the SFC source, checked on sfc.hk on 11 October 2026. Topic 4 of Paper 1 tests the same rules, so it doubles as revision.

Who needs a representative licence

Under section 114 of the Securities and Futures Ordinance (Cap. 571), an individual who performs a regulated function for a licensed corporation, in a regulated activity it carries on as a business, must be a licensed representative accredited to that corporation. The SFC’s Licensing Handbook (July 2025) explains the test, and the SFC’s licensing pages cover who needs a licence.

Banks are different. A bank registers with the SFC, and its staff are entered on the HKMA register rather than licensed by the SFC. They must still meet the same competence standard (Guidelines on Competence, para 2.2).

1. Fit and proper

Section 129 of the SFO lists what the SFC must consider: your financial status or solvency; your qualifications and experience; your ability to carry on the activity competently, honestly and fairly; and your reputation, character, reliability and financial integrity. The SFC’s Fit and Proper Guidelines (January 2022) give examples of what fails the test, such as:

• Being an undischarged bankrupt or subject to bankruptcy proceedings (para 4.1.1).
• Being under 18 when applying for a representative licence (para 5.1.1).
• Failing to show competence for the activity, which the Guidelines on Competence then define (para 5.1.1).

Disclose fully. The Licensing Handbook says even a spent conviction must be reported: you may tick “No” on the form to keep it confidential, but you must send the details directly to the SFC within two business days of submitting the application (paras 7.11.9 and 7.11.10).

2. Competence

The Guidelines on Competence (October 2024) expect a representative to have basic education, to pass a local regulatory framework paper, and, depending on education and experience, to hold a recognised industry qualification:

The SFC may, at its discretion, approve an application on condition that you pass the regulatory paper within six months of approval (para 4.4.1.2). This grace period is usually granted only once per paper. For the full routes, see do I need Paper 7 and 8? and which papers you need.

3. Accreditation to a firm

A representative licence is tied to a principal: the licensed corporation you work for. You cannot hold a representative licence on your own. In practice your firm’s licensing team prepares the application with you.

• How you apply: online through the SFC’s WINGS licensing platform (WINGS-LIC), per the Licensing Handbook para 7.2.1.
• Provisional licence: you can apply for one alongside the full application. It carries an extra HK$800 application fee, the SFC generally decides within seven business days of a complete application, and it ends when the full application is approved or refused (Licensing Handbook paras 5.3.3 to 5.3.5).
• Changing firms: you have 180 days after leaving a principal to transfer your accreditation to a new one (SFO s.122).

4. Staying licensed: CPT

The full text is in the SFC’s Guidelines on Continuous Professional Training. Your licence also carries an annual fee and annual return, due within one month after each licence anniversary (SFO s.138).

The order most people follow

• Receive a job offer from a licensed corporation.
• Confirm with the firm which papers you need, then pass Paper 1 (and any others).
• The firm submits your application on WINGS, with a provisional licence request if you need to start sooner.
• The SFC assesses fitness and properness and competence, then grants the licence.
• You complete your CPT ethics hours in the first 12 months.

Start with the Paper 1 exam guide, revise the licensing note, and test yourself with the free mock.

HKSI Prep is an independent study tool, not affiliated with or endorsed by HKSI Institute or the SFC. This is a summary, not legal or licensing advice; the SFC decides each application. Exam details are on hksi.org.