COMPARE BEFORE YOU DECIDE
One comparison table to see the differences between the regimes.
Start with the business scope, competent authority and capital baseline. Specific requirements must still be checked item by item in the relevant guide against the business model and licence conditions.
LICENSING COMPARISON
Core comparison of Hong Kong financial qualifications
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| Licences / Qualifications | Regulatory authorities | Business and Applicable Scenarios | Capital and Financial Resources | Entry pathways |
|---|---|---|---|---|
| SFC Type 1 licence · Dealing in securities | Hong Kong Securities and Futures Commission (SFC) | Securities brokerage, placing and underwriting, building capital-markets transaction businesses. | All amounts are in HKD: an approved introducing agent or a dealer meeting the definition must have no specified minimum share capital and HKD 500,000 in liquid capital; providing margin financing or acting as the custodian of a private OFC requires HKD 10,000,000 in share capital and HKD 3,000,000 in liquid capital; other cases require HKD 5,000,000 in share capital and HKD 3,000,000 in liquid capital. Also check any variable requirements. [1] (3.2.18) [6] | New Application / Acquisition |
| SFC Type 2 licence · Dealing in futures contracts | Hong Kong Securities and Futures Commission (SFC) | Executing futures transactions for clients, assessing exchange and client-asset arrangements. | The general minimum paid-up share capital is HKD 5 million, with fixed required liquid capital of HKD 3 million. For an approved introducing agent, a dealer meeting the definition, or a futures non-clearing dealer, there is no specified minimum share capital and fixed required liquid capital is HKD 500,000. Applicable variable required liquid capital must also be calculated.[1] (3.2.18)[6] | New Application / Acquisition |
| SFC Type 3 Licence · Leveraged foreign exchange trading | Hong Kong Securities and Futures Commission (SFC) | Distinguishing leveraged foreign-exchange business from the general money-changing and remittance regimes. | An approved introducing agent must have minimum paid-up share capital of HK$5,000,000 and fixed liquid capital of HK$3,000,000. Other Type 3 business requires minimum paid-up share capital of HK$30,000,000 and fixed liquid capital of HK$15,000,000. The lower capital thresholds for ordinary brokers or firms not holding client assets must not be applied. [1] (3.2.18) | New Application / Acquisition |
| SFC Type 4 Licence · Advising on securities | Hong Kong Securities and Futures Commission (SFC) | Securities investment advice and research services, clarifying the boundary between recommendations and execution. | Where the licence condition prohibits holding client assets, there is no minimum paid-up share capital requirement, and fixed liquid capital is HK$100,000. In other cases, share capital of HK$5,000,000 and fixed liquid capital of HK$3,000,000 are required. Check the variable capital requirement and funding needs of the business as well, rather than considering only whether the firm receives funds directly. [1] (3.2.18) [6] | New Application / Acquisition |
| SFC Type 5 licence · Advising on futures contracts | Hong Kong Securities and Futures Commission (SFC) | Providing professional advice on futures trading and matching personnel to the required competence. | Where a condition prohibiting the holding of client assets is imposed, there is no specified minimum paid-up share capital and the fixed required liquid capital is HK$100,000. In other cases, the minimum paid-up share capital is HK$5 million and the fixed required liquid capital is HK$3 million. Applicable variable requirements and other financial conditions must continue to be met.[1]（3.2.18）[6] | New Application / Acquisition |
| SFC Type 6 licence · Advising on corporate finance | Hong Kong Securities and Futures Commission (SFC) | Assessment of business classifications for corporate finance, M&A financial advisory and sponsor business. | HKD share capital / fixed liquid capital: non-sponsor and not holding client assets: no specified share capital / 100,000; non-sponsor, other cases: 5,000,000 / 3,000,000; sponsor: share capital of 10,000,000, with fixed liquid capital of 100,000 if not holding client assets and 3,000,000 otherwise. Also check the variable requirement for liquid capital. [1] (3.2.18) | New Application / Acquisition |
| SFC Type 7 licence · Providing automated trading services | Hong Kong Securities and Futures Commission (SFC) | Technology and regulatory boundaries for automated trading facilities and platforms. | Obtain a Type 7 licensed corporation licence under Part V. The minimum paid-up share capital is HKD 5 million and fixed required liquid capital is HKD 3 million; applicable variable requirements must also be calculated. This table cannot be applied directly to automated trading services recognised under Part III, and virtual asset trading platforms may also be subject to separate financial requirements.[1] (3.2.18) | New Application / Acquisition |
| SFC Type 8 Licence · Securities margin financing | Hong Kong Securities and Futures Commission (SFC) | Financial resources and risk control requirements for securities margin financing. | A Type 8 licensed corporation must have minimum paid-up share capital of HKD 10 million and fixed liquid capital of HKD 3 million, and must calculate the applicable required liquid capital under the relevant requirements based on client loans, securities collateral and other risks. Actual funding needs vary with the scale of lending and the quality of collateral; a fixed HKD 3 million does not by itself suffice to lend. [1] [6] | New Application / Acquisition |
| SFC Type 9 licence · Asset management | Hong Kong Securities and Futures Commission (SFC) | Discretionary portfolio management, fund management and wealth management businesses. | Where a condition prohibits holding client assets, there is no specified minimum paid-up share capital, and the fixed required liquid capital is HKD 100,000; in other cases, the minimum paid-up share capital is HKD 5 million and the fixed required liquid capital is HKD 3 million. Also check variable requirements, the operating budget and any additional qualifications for products or specialised business activities.[1] (3.2.18) [6] | New Application / Acquisition |
| SFC Type 10 licence · Providing credit rating services | Hong Kong Securities and Futures Commission (SFC) | Providing credit rating services to the public or subscribers. | Where a licensing condition prohibits the holding of client assets, there is no specified minimum paid-up share capital, and the fixed liquid capital requirement is HKD 100,000. In other cases, the minimum paid-up share capital is HKD 5 million and the fixed liquid capital requirement is HKD 3 million. Variable capital and applicable financial requirements must also be checked separately.[1] (3.2.18) [6] | New Application / Acquisition |
| SFC Type 11 licence · Dealing in or advising on over-the-counter derivatives (not yet implemented) | Hong Kong Securities and Futures Commission (SFC) | Monitor the statutory implementation and licensing status of the OTC derivatives regime. | Type 11 cannot currently be presented as a category open for applications, and no definite minimum capital can be promised. This information does not treat historical consultation proposals, proposed financial resources rules or thresholds for other categories as requirements already in force for Type 11. The position in future will be governed by formally effective legislation and the SFC’s implementation arrangements.[1] [2] | Implementation Status Note |
| SFC Type 12 licence · Client clearing of OTC derivatives (not yet implemented) | Hong Kong Securities and Futures Commission (SFC) | Monitor the implementation and licensing status of client clearing for OTC derivatives. | Type 12 has not yet opened as a current licensing category. This material does not state fixed minimum paid-up capital or liquid capital figures that have not been verified as effective. Central counterparty participation requirements, bank prudential capital or proposed customer-clearing capital cannot directly replace the final legal requirements for future Type 12. [1] [2] [8] | Implementation Status Note |
| SFC Type 13 licence · Providing depositary services for relevant collective investment schemes | Hong Kong Securities and Futures Commission (SFC) | Applicable recognised-fund depositary, asset custody and independent oversight arrangements. | A Type 13 licensed corporation must have minimum paid-up share capital of HKD 10,000,000 and fixed liquid capital of HKD 3,000,000, and must comply with applicable variable required liquid capital and other Fund Manager Code of Conduct requirements. Where an authorised financial institution follows the registered institution route, its status should be assessed separately under the applicable banking prudential and regulatory framework. [1] (3.2.18) [7] | New Application / Acquisition |
| MSO Money Service Operator Licence | Hong Kong Customs and Excise Department (C&ED) | Money changing, cross-border remittances and online remittance businesses: the complete path from application to renewal. | The Customs and Excise Department’s current licensing guidelines reviewed do not specify a uniform minimum paid-up share capital or minimum liquid funds amount. However, applicants must have sufficient financial resources commensurate with the nature and scale of the business, and explain the source of funds and working capital for the next two years. The absence of a uniform figure does not mean that operating costs are zero, and adviser-recommended capital must not be presented as a statutory threshold. | New Application / Acquisition |
| Hong Kong Gold Exchange Membership Rights | Hong Kong Gold Exchange HKGX | Acquisition of membership rights, share transfers and trading eligibility: first verify identity and business permissions. | The official ordinary membership transfer and refiner transfer checklists both specify issued and fully paid ordinary share capital of at least HKD 5 million and net assets of at least HKD 5 million. They also require prescribed liquid funds of at least HKD 1.5 million, excluding client money. These three amounts are not simply added together to determine the acquisition price; the purchase price, fees and product margin should be budgeted separately. [3][4][5] | Acquisition of Membership Rights |
| DPMS Registration for Dealers in Precious Metals and Stones | Hong Kong Customs and Excise Department (C&ED) | Class A and Class B registrations: identify the applicable class by transaction amount, cash and business model. | The Customs and Excise Department’s current DPMS registration guidelines do not prescribe a uniform minimum amount of paid-up share capital, working capital or security deposit for Category A or Category B. Separate budgets must be made for procurement, rent, staffing and compliance expenses. The registration application fee and fit-and-proper assessment fee are not capital requirements; nor should working capital recommended by a consultant be presented as a statutory threshold. [1][3] | Category A / Category B Registration |
| IA insurance broker company licence | Insurance Authority (IA) | Insurance brokerage business, responsible persons, professional indemnity insurance and ongoing compliance. | The company must continuously maintain paid-up share capital of at least HKD 500,000 and net assets of at least HKD 500,000, satisfying both requirements at the same time; this does not mean that an additional total of HKD 1 million must be paid in. Net assets must be adjusted under Chapter 41L, excluding intangible assets and other items; the minimum threshold is not the total start-up budget, and losses may cause net assets to fall below the requirement.[3] | New Application / Acquisition |
| MLO Money Lender Licence | Licensing Tribunal / Companies Registry / Police | New applications, acquisitions and renewals for money lending businesses; clarify funding, premises and loan documents. | The current official application and fit-and-proper guidelines do not prescribe a uniform minimum paid-up capital or fixed security deposit amount. However, you must demonstrate that your financial position is suitable for conducting the business, that the source of funds for lending is lawful, and that working capital is sufficient. The business plan must explain the capital required for day-to-day operations and provide financial projections for the next two years. A budget recommended by a consultant must not be presented as a statutory threshold. | New application / acquisition / renewal |
| SVF Stored Value Facility Licence | Hong Kong Monetary Authority HKMA | Prudent access requirements for e-wallets, multi-purpose stored value facilities and float protection. | A non-bank applicant must have paid-up share capital of at least HKD 25 million, or an equivalent amount of foreign-currency capital that meets the requirements, and other financial resources of an equivalent or higher level. Alternative financial resources must be satisfactory to the HKMA; credit facilities or a group guarantee cannot be substituted at the applicant’s discretion. The HKMA may require a higher level based on business risks. Customer stored value and exit refund costs must be safeguarded separately. | New application / acquisition assessment |
| Stablecoin Issuer Licence | Hong Kong Monetary Authority HKMA | Requirements for fiat-referenced stablecoin issuance, reserve assets, redemption and governance. | Non-authorized institutions must continuously maintain at least HKD 25 million in paid-up share capital, or the prescribed equivalent in another currency and other equivalent financial resources approved by the Monetary Authority, and liquid net assets supported by sufficient equity funding. The HKMA may impose higher requirements on a case-by-case basis. Authorized institutions are subject to banking capital regulation, and reserve assets must be fully backed separately. [2, section 3.3] [3, chapter 5] | Prudent Licensing Regime |
| LPF Limited Partnership Fund Registration | Hong Kong Companies Registry CR | Roles of the general partner, investment manager and responsible persons, and fund registration arrangements. | The LPF registration regime does not prescribe a uniform statutory minimum fund size, paid-up capital or minimum contribution per limited partner. Contributions and capital-call arrangements are determined by the partnership agreement. This does not exempt a manager from separate licensing capital requirements, nor does it mean that the fund can operate without working capital or avoid legal, audit and government fees. | Fund Registration Regime |
| Trust companies and TCSP licences | Hong Kong Companies Registry CR | Distinguish trust company registration from TCSP licensing, and clarify service boundaries and ongoing maintenance responsibilities. | TCSP does not prescribe a uniform minimum paid-up share capital or statutory deposit, and providing trust services does not automatically require HKD 3 million. Trust registration requires issued share capital of at least HKD 3 million, with at least HKD 3 million paid up in cash, as well as a statutory deposit of at least HKD 1.5 million or an accepted bank guarantee. Operating resources must be budgeted separately; capital should not be counted repeatedly mechanically. [1] [2] | Incorporation / Licensing / Acquisition |
| Establishing a Hong Kong family office | Depending on the activities involved, including the SFC and the Inland Revenue Department | Single-family and multi-family office structures, licensing boundaries and substantive operations. | There is no uniform minimum paid-up share capital or asset-size requirement for a family office as such; where a licence is required, the applicable regime determines the calculation. For Type 9, a licence condition that does not involve holding client assets carries no minimum paid-up share capital requirement, and the minimum liquid capital is HKD 100,000. The HKD 240 million asset threshold for family office tax concessions is not start-up capital. | Assessment of structure and regulatory boundaries |
Capital is a regulatory resource threshold, not a service quotation. The absence of a stated uniform minimum capital requirement does not mean that sufficient operating funds are unnecessary. An acquisition does not remove regulatory review, and registration or membership does not amount to a general financial licence.
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