Based on the SFC official "Dealing Manual" (2025 edition)

Hong Kong License No. 7
Provide automated trading services

Complete Guide to Application and Acquisition

This comprehensive analysis of the application requirements, capital requirements, technical system requirements, and application process for Type 7 regulated activities (RA7) under the Hong Kong Securities and Futures Commission (SFC) will help you complete your license application efficiently.

15 weeks

SFC official review weeks

5,000,000+

Minimum paid-up share capital (HKD)

12+

Representative licensed institutions (examples)

From the beginning of 2,016

AIYING is deeply involved in the compliance field.

License Definition

What is a Hong Kong Type 7 license plate?

Type 7 regulated activities (RA7) are issued by the Securities and Futures Commission (SFC) of Hong Kong under the Securities and Futures Ordinance.

Legal Definitions • Schedule 5 to the Securities and Futures Ordinance (Chapter 571)

Category 7 regulated activity (RA7): Providing Automated Trading Services

This refers to operating a system through which people can trade or make offers for securities or futures contracts without going through traditional manual matching methods. The system must be able to automatically match or execute buy and sell orders.

Source: Schedule 5 of the Securities and Futures Ordinance (Chapter 571) · SFC Licensing Manual (2025 Edition)

Main business activities covered

Electronic trading platform operation

Operate a multilateral trading facility (MTF) or electronic trading system to match buyers and sellers in securities or futures transactions.

Algorithmic trading system

Provides automated algorithmic trading execution systems, including high-frequency trading (HFT) infrastructure.

Dark Pool Operations

Operating a private trading system with non-public quotes to provide block trade matching services for institutional investors.

Trading system technical services

Provide core technology services such as trading matching engines and order management systems to licensed exchanges or brokers.

Business Boundary Description

Permitted business activities

✓ Operating electronic transaction matching system
✓ Provide automated order fulfillment services
✓ Operating the Multilateral Trading Facility (MTF)
✓ Provide algorithmic trading infrastructure for institutional clients

Prohibited business activities (require other licenses)

✗ Executing securities trading on behalf of clients (Type 1 required)
✗ Providing investment advice on securities (Type 4 required)
✗ Managing a securities portfolio (Class 9 required)
✗ Provide advice on futures contracts (Category 5 required)

Relationship with relevant licenses and associated exemptions

Category 1 (Securities Trading)

A common combination is that brokers operating automated trading platforms typically hold both Type 1 and Type 7 licenses.

Category 2 (Futures Contract Trading)

If the platform covers futures products, it usually needs to hold a Type 2 license as well.

Category 8 (Securities Margin Financing)

If the platform offers leveraged trading services, it may be required to hold a Type 8 license.

Exemption Explanation:Institutions holding membership in an accredited exchange may be exempt from applying for a Type 7 license under certain conditions (Section 1.3.4 of the Licensing Manual).

Adaptation assessment

Does your business require a Type 7 license?

Understanding the license combination options under different business models, as well as typical business scenario matching, will help you determine whether you need to apply for a Class 7 license.

Business model and license combination selection

Choose the appropriate license combination based on your business functions. Different combinations correspond to different business boundaries and compliance requirements.

Single license
Starter

Category 7 (Single Type 7 License)

Focus on transaction matching technology services

Holding only a Type 7 license, focusing on operating electronic trading matching platforms or providing automated trading infrastructure for institutional clients. Business functions are limited to system-level trading matching; execution of trades on behalf of clients is prohibited.

Permissible business scope:

✓ Operate the electronic trading matching system (ATS/MTF)
✓ Provides algorithmic trading engines and high-frequency trading infrastructure
✓ Provide trading system technical services to institutional clients

Note: Securities trading cannot be executed on behalf of clients. If execution is required, a separate Type 1 license is required.
Minimum paid-up capital: HK$5,000,000 (without holding client assets)

Dual license combination
Growth

Category 1 + Category 7

Integrated trading service platform

Holding both securities trading (Type 1) and automated trading services (Type 7) allows a broker to provide both trade execution and automated platform services, which is a common combination for integrated brokers.

Permissible business scope:

✓ Executing securities trading on behalf of clients (Category 1 function)
✓ Operating an automated transaction matching platform (Category 7 function)
✓ Provide complete trading channels and system services

Note: The qualification requirements for the responsible personnel must be met for both types of licenses, with the higher capital requirement taking precedence.
Minimum paid-up capital: whichever is higher of the two categories.

Multi-license combination
Enterprise

Category 1 + Category 2 + Category 7

Comprehensive transaction service provider

Holding licenses for securities trading, futures contract trading, and automated trading services, covering the securities and derivatives markets, it is suitable for large financial institutions that provide comprehensive trading services.

Permissible business scope:

✓ Executing securities and futures contracts on behalf of clients
✓ Operating an automated trading platform covering multiple asset classes
✓ Provides a complete trading infrastructure across markets

Note: This requires meeting the personnel and compliance requirements of all three types of licenses simultaneously, making it the most complex to manage.
Minimum paid-up capital: based on the highest of the three categories.

Analysis of common factors causing application failure

The following four types of issues are the most common reasons why applications are returned or delayed during the SFC approval process. It is recommended to check each of these issues before submitting your application.

Capital and financial aspects

  • Insufficient quick cash to cover operating expenses for the first six months
  • Financial forecasts lack a reasonable basis and are inconsistent with business plans.
  • Unable to provide audited financial statements

Personnel Qualifications

  • The person in charge lacks relevant work experience (must have ≥3 years of direct relevant experience).
  • The HKSI exam subjects do not meet the requirements of Category 7 (Paper 1 and Paper 7).
  • The responsible personnel are unable to be stationed in Hong Kong for an extended period and fulfill their supervisory duties.

Compliance architecture level

  • The AML/CFT policy is inadequate and fails to reflect the characteristics of RA7's business.
  • The lack of internal control systems and the absence of a complete compliance management framework
  • Failure to appoint a Compliance Officer (CO) or Money Laundering Reporting Officer (MLRO)

Personnel Qualifications

  • The person in charge lacks relevant work experience (must have ≥3 years of direct relevant experience).
  • The HKSI exam subjects do not meet the requirements of Category 7 (Paper 1 and Paper 7).
  • The responsible personnel are unable to be stationed in Hong Kong for an extended period and fulfill their supervisory duties.

Interactive application eligibility self-assessment checklist

Check your application preparation status item by item and stay informed about the steps you need to take before submitting your application.

Completion rate: 0/17

It is recommended to consult a professional advisor to assess the direction of preparation first.

Structure of company

  • Limited Company has been incorporated in Hong Kong
  • The company's articles of association have covered the scope of automated trading services.
  • The shareholding structure is clear, and the actual controller is clearly identified and traceable.

Capital requirements

  • Minimum paid-up capital has been prepared (excluding client assets: HK$5,000,000)
  • Sufficient quick cash reserves are available to cover operating expenses for the first six months.
  • Audited financial statements prepared or arranged to be issued by an independent auditor

Personnel Qualifications

  • There must be at least two responsible persons (ROs), at least one of whom must be an executive director.
  • The responsible personnel must have ≥3 years of relevant direct work experience in Category 7.
  • The personnel in charge have passed or are preparing to take HKSI Paper 1 and Paper 7.
  • At least one responsible person can be stationed in Hong Kong for an extended period.

Technical System

  • The automated trading system has completed internal testing and is running stably.
  • The system has a complete risk management mechanism (including circuit breaker and abnormal transaction monitoring).
  • System architecture documents, technical specifications, and cybersecurity policies have been prepared.
  • A Disaster Recovery Plan (DRP) and a Business Continuity Plan (BCP) have been developed.

Compliance Architecture

  • AML/CFT policies and operating procedures have been established.
  • A Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO) have been appointed.
  • A customer due diligence (KYC) and continuous monitoring mechanism has been established.

Structure of company

  • Limited Company has been incorporated in Hong Kong
  • The company's articles of association have covered the scope of automated trading services.
  • The shareholding structure is clear, and the actual controller is clearly identified and traceable.

Capital requirements

  • Minimum paid-up capital has been prepared (excluding client assets: HK$5,000,000)
  • Sufficient quick cash reserves are available to cover operating expenses for the first six months.
  • Audited financial statements prepared or arranged to be issued by an independent auditor

Personnel Qualifications

  • There must be at least two responsible persons (ROs), at least one of whom must be an executive director.
  • The responsible personnel must have ≥3 years of relevant direct work experience in Category 7.
  • The personnel in charge have passed or are preparing to take HKSI Paper 1 and Paper 7.
  • At least one responsible person can be stationed in Hong Kong for an extended period.

Technical System

  • The automated trading system has completed internal testing and is running stably.
  • The system has a complete risk management mechanism (including circuit breaker and abnormal transaction monitoring).
  • System architecture documents, technical specifications, and cybersecurity policies have been prepared.
  • A Disaster Recovery Plan (DRP) and a Business Continuity Plan (BCP) have been developed.

Compliance Architecture

  • AML/CFT policies and operating procedures have been established.
  • A Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO) have been appointed.
  • A customer due diligence (KYC) and continuous monitoring mechanism has been established.

Note: The above list is for reference only. Actual application requirements are subject to the SFC's official "License Issuance Manual" (2025 edition). It is recommended to consult a professional compliance advisor before submitting your application to ensure the completeness and accuracy of your application materials.

Application Requirement

Core conditions for applying for a Type 7 license plate

Based on the SFC's official "License Issuance Manual" (2025 edition), it covers basic requirements, capital requirements, personnel qualifications, and technical system requirements.

basic requirements

Company registration

Limited company that must be incorporated in Hong Kong

company policy

The scope of business must explicitly include providing automated trading services.

Physical office

Must have a physical office in Hong Kong

Compliance Officer

A compliance officer must be appointed (this role may be held concurrently by the RO).

Internal Audit

An internal audit function must be established.

External auditors

An independent external auditor accredited by the SFC must be appointed.

Capital requirements

Business Situation Minimum Paid-up Capital Minimum quick capital Remark
Do not hold client assets HK$5,000,000 HK$3,000,000 Standard Case
Holding client assets HK$5,000,000 HK$5,000,000 Increased requirements for quick capital
ATS controller approved HK$10,000,000 HK$10,000,000 Operational Approval Automated Trading System

Source: SFC Licensing Manual Appendix 1 (2025 Edition). If holding multiple license types simultaneously, the capital requirement will be based on the highest among all types.

RO (Responsible Personnel) Qualification Requirements

work experience

At least 3 years of work experience directly related to RA7 (SFC has stricter criteria for "directly related").

Ability Requirements

Must possess sufficient technical knowledge and professional skills to meet the requirements of the SFC Competency Guidelines.

Garrison Requirements

At least one responsible person must be stationed in Hong Kong.

Minimum number of people

A licensed corporation must have at least two approved responsible persons.

Regarding competency requirements: There are currently no mandatory qualification examinations (RIQ/LRP) specified by the SFC/HKSI for Category 7 regulated activities (RA7). The SFC focuses more on whether the applicant's practical work experience and professional competence meet the requirements of the Competency Guidelines. For specific competency standards, it is recommended to consult the SFC or a professional compliance advisor directly to obtain the latest and most accurate requirements.

Important Note: The SFC has strict requirements for "directly relevant experience," typically requiring applicants to have practical experience working in a licensed organization in a related field. If applying for other license categories (such as RA1/RA2), applicants must also meet the examination and competency requirements for those categories. It is recommended to consult a professional advisor in advance to assess your eligibility.

Technical system requirements (specific to Category 7)

System architecture

  • System architecture documents and technical specifications (including flowcharts)
  • System capacity planning and performance test report
  • Third-party technology vendor agreements (if applicable)

Risk Management

  • A complete risk management mechanism (including circuit breaker/fuse mechanism)
  • Order limit and position limit control system
  • Real-time market monitoring and abnormal transaction detection system

Internet security

  • Cybersecurity policies and procedures
  • Penetration test report (recommended annually)
  • Data encryption and access control mechanisms

Business continuity

  • Disaster Recovery Program (DRP)
  • Business Continuity Plan (BCP)
  • Regular drill records and test reports

Technical review instructions:The SFC will conduct a thorough review of the applicant's technical system and may require a live demonstration or a system test report. It is recommended to ensure that the system has been fully tested and meets the SFC's technical standards before applying.

Application vs. Acquisition

New application vs. acquisition of licensed company

Both paths have their advantages and disadvantages; make the best choice based on your timeline, capital situation, and business needs.

Contrast Dimensions New application Acquisition of licensed companies Explain
time required 6–12 months 3–6 months The acquisition could save approximately 3–6 months of SFC approval time.
Total cost HK$50–120 (including consultant fees) HK$300 million – 1,500 million (market reference price, subject to significant variation) Official fees for new applications are relatively low; acquisition costs vary significantly depending on the target company's circumstances, and are for reference only.
歷史包袱 No historical compliance risks A thorough due diligence investigation is required. Acquisitions require careful review of the target company's historical compliance record.
SFC Approval New approval process, approximately 15 weeks. Approval for change of controlling shareholder takes approximately 8–12 weeks. Changes in controlling shareholder approval are typically processed faster than new applications.
Business continuity Build from scratch Existing business relationships can be inherited. The acquisition can preserve existing customers and business relationships.
Capital requirements SFC minimum capital requirements must be met. The target company must have met the capital requirements. Both methods must meet the SFC capital requirements.
Brand Building Establish a brand independently Possibly inheriting the target company's brand The new applicant has complete control over the brand image.
Suitable for the scene Long-term planning and sufficient capital Urgent need for rapid market entry, strong capital Select based on specific business needs

Note: The acquisition cost is a market reference price. The actual cost varies significantly due to factors such as the target company's size, compliance status, and market supply and demand. It is for reference only.

It is recommended to choose the scenario of applying for a completely new application.

✓ Ample time for planning (6-12 months or more)

✓ Hoping to have complete control over the company structure and brand

✓ Limited capital budget (HK$500 million - HK$1,000 million)

✓ The business model is quite innovative, making it difficult to find a suitable shell company.

Situations where acquisition is recommended

✓ Need to enter the market quickly (start business within 3-6 months).

✓ Sufficient capital (budget of HK$500 million or more)

✓ Hoping to inherit the target company's existing business relationships

✓ The target company has a good compliance record.

Acquisition process timeline

Target screening

Screen shell companies holding Type 7 licenses and assess their compliance record, capital status, and historical risks.

2–4 weeks

due diligence

Conduct comprehensive legal, financial, and compliance due diligence on the target company to identify potential risks.

4–8 weeks

SFC pre-communication

We held preliminary discussions with the SFC regarding the change of controlling shareholder to understand the audit requirements and timeline.

2–4 weeks

Submit a change request

Submit an application for change of controller to SFC, including information on the new controller and business plan.

8–12 weeks

SFC Approval

After obtaining SFC approval, the share transfer and change of company management will be completed.

1–2 weeks
application process

Full process of applying for license plate No. 7

From initial preparation to license issuance, the entire process takes approximately 6-12 months, with the SFC official review taking about 15 weeks (SFC performance commitment).

Preliminary preparation

4–8 weeks

The first stage
  • Determine the business model and technical system architecture
  • Form a management team and confirm the qualifications of the responsible personnel.
  • Prepare company registration documents and equity structure
  • Draft business plan and compliance policy documents
  • Complete technical system testing and document preparation
  • Register an account in the WINGS system

Application material preparation

2–4 weeks

second stage
  • Complete the licensed corporation application form (Form 1)
  • Complete the application form for responsible personnel (Form 3).
  • Prepare financial statements and capital verification documents
  • Prepare system architecture documents and technical specifications
  • Prepare AML/KYC policy documents
  • Prepare a Disaster Recovery Plan (DRP).

SFC Approval

Approximately 15 weeks

The third phase
  • Submitting an application through the WINGS system
  • SFC conducts initial review (approximately 2-3 weeks).
  • Responding to SFC's request for supplementary information
  • SFC conducts in-depth review (including technical system review).
  • SFC may require an on-site inspection or system demonstration.
  • SFC issues notice of approval in principle

License issued

1–2 weeks

Phase 4
  • Pay the license application fee (if applicable).
  • Confirm that all application requirements have been met.
  • SFC officially issued licenses
  • Register in the SFC Licensee Register
  • Formal conduct of regulated activities
  • Establish a continuous compliance monitoring mechanism

Regarding the review time:The SFC's performance pledge is 15 weeks. The actual review time depends on the completeness of the application materials and the workload of the SFC, and may be longer. If the SFC requests supplementary materials, the time will be extended accordingly.

License Fee Overview

Expense items Amount of money Explain
Licensed corporation application fee HK$4,740 Each type of regulated activity (RA7 may be exempted when it is attached to RA1/RA2)
Application fee for responsible personnel HK$2,950 Each person in charge
Licensed representative application fee HK$1,790 Each licensed representative
Annual license fee for licensed corporations HK$4,740 Each type of regulated activity (resuming from April 1, 2025)
Annual license fee for responsible personnel HK$4,740 Each responsible person (reinstated from April 1, 2025)
Licensed representative annual license fee HK$1,790 Each licensed representative (reinstated from April 1, 2025)

Fee waiver:If an RA7 business is associated with a Type 1 (dealing in securities) or Type 2 (dealing in futures contracts) regulated activity, the licensed corporation's application fee may be waived.

Annual fee reinstatement:The annual license fee will resume on April 1, 2025 (it was previously temporarily waived due to special circumstances). The above is the official license fee and does not include professional consultant fees.

Source: SFC Official Fee Schedule (2025 Edition). Fees are subject to change; please refer to the official SFC announcement for the most up-to-date information.

Application Materials List

  • Certificate of Incorporation
  • Memorandum and Articles of Association
  • Shareholding structure diagram (including ultimate beneficial owner)
  • List of directors and shareholders
  • Company organizational chart
  • Audited financial statements for the most recent three years (if applicable)
  • Capital adequacy documentation
  • Bank account proof
  • Financial forecasts (next 3 years)
  • Resume and work experience certificate of the person in charge
  • Professional qualifications and licenses (if applicable)
  • Certificate of no criminal record
  • Letters of recommendation (if applicable)
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  • System architecture documents and technical specifications
  • Cybersecurity Policy and Penetration Testing Report
  • Disaster Recovery Planning (DRP) and Business Continuity Planning (BCP)
  • AML/KYC policies and procedures
  • Internal Compliance Manual
  • Risk Management Framework Document
Continuing compliance obligations

Continuing compliance obligations after obtaining a license

Obtaining a license is just the beginning; continuous compliance is the core requirement for maintaining license eligibility.

per month

  • Submit monthly financial reports (if applicable)
  • Conduct internal compliance checks
  • Update risk assessment report

quarterly

  • Submit quarterly financial reports
  • Conduct system security audit
  • Update AML/KYC policies (if necessary)

Per year

  • Pay the annual license fee (HK$4,740/class).
  • Submit audited annual financial statements
  • Conduct annual penetration testing
  • Update the Disaster Recovery Plan (DRP).
  • Submit annual compliance report

continued

  • Real-time monitoring of transaction anomalies
  • Maintain system availability (≥99.9%)
  • Keep transaction records (for at least 7 years).
  • Monitoring market manipulation

Significant changes that must be reported to the SFC

Change type Application Requirements Time requirement
Change of controller Prior approval from the SFC is required. 🔴 Beforehand
Change of responsible personnel SFC must be notified within 7 business days of the change. 🔵 Afterwards
Change of business scope Prior notification and approval from the SFC are required. 🔴 Beforehand
Change of registered address SFC must be notified within 7 business days of the change. 🔵 Afterwards
Major system changes You must notify the SFC in advance and submit a change description. 🔴 Beforehand
Capital level below requirements The SFC must be notified immediately and a remedial plan must be submitted. ⚠️ Immediately

Consequences of violations

Violations possible consequences Severity
Engaging in regulated activities without a license A maximum fine of HK$500 million and 7 years imprisonment. 🔴 Serious
Breach of Continuing Compliance Requirements Warning, reprimand, or suspension/revocation of license 🟠 Medium
Failure to submit financial reports on time Warnings and fines 🟢 Mild
No notification to SFC regarding major changes Reprimand and fine 🟠 Medium
Violation of AML/KYC requirements Maximum fine of HK$100 million 🔴 Serious

important hint:The SFC takes a strict approach to handling compliance violations. It is recommended to establish a comprehensive internal compliance monitoring system and conduct regular compliance training to reduce the risk of violations.

Licensed companies

Organizations holding Type 7 licenses

The data comes from the SFC's publicly available list of licensees. Below are some representative licensed organizations.

Exchanges/Brokerages
Hong Kong Exchanges and Clearing Limited

Hong Kong Exchanges and Clearing Limited

RA7

✓ Effective

Fintech
Bloomberg Trading Services Limited

Bloomberg Transaction Services

RA7

✓ Effective

Fintech
Thomson Reuters (Hong Kong) Limited

Thomson Reuters (Hong Kong) Limited

RA7

✓ Effective

Banks/Investment Banks
Morgan Stanley Asia Limited

Morgan Stanley Asia Limited

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
Goldman Sachs (Asia) LLC

Goldman Sachs (Asia) Limited

RA1 RA2 RA4 RA7

✓ Effective

Fintech
Futu Securities International (Hong Kong) Limited

Futu Securities International (Hong Kong) Limited

RA1 RA7

✓ Effective

Banks/Investment Banks

UBS AG

UBS Group

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
Citibank Hong Kong Limited

Citibank (Hong Kong) Limited

RA1 RA7

✓ Effective

Banks/Investment Banks
Deutsche Bank AG

Deutsche Bank Corporation

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
BNP Paribas Hong Kong Branch

BNP Paribas Hong Kong Branch

RA1 RA2 RA7

✓ Effective

asset Management
CICC Hong Kong Securities Limited

China International Capital Corporation (Hong Kong) Securities Limited

RA1 RA4 RA7

✓ Effective

Exchanges/Brokerages
China Merchants Securities (HK) Co., Limited

China Merchants Securities (Hong Kong) Limited

RA1 RA2 RA7

✓ Effective

Exchanges/Brokerages
Hong Kong Exchanges and Clearing Limited

Hong Kong Exchanges and Clearing Limited

RA7

✓ Effective

Exchanges/Brokerages
China Merchants Securities (HK) Co., Limited

China Merchants Securities (Hong Kong) Limited

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
Morgan Stanley Asia Limited

Morgan Stanley Asia Limited

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
Goldman Sachs (Asia) LLC

Goldman Sachs (Asia) Limited

RA1 RA2 RA4 RA7

✓ Effective

Banks/Investment Banks

UBS AG

UBS Group

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
Citibank Hong Kong Limited

Citibank (Hong Kong) Limited

RA1 RA7

✓ Effective

Banks/Investment Banks
Deutsche Bank AG

Deutsche Bank Corporation

RA1 RA2 RA7

✓ Effective

Banks/Investment Banks
BNP Paribas Hong Kong Branch

BNP Paribas Hong Kong Branch

RA1 RA2 RA7

✓ Effective

Fintech
Bloomberg Trading Services Limited

Bloomberg Transaction Services

RA7

✓ Effective

Fintech
Thomson Reuters (Hong Kong) Limited

Thomson Reuters (Hong Kong) Limited

RA7

✓ Effective

Fintech
Futu Securities International (Hong Kong) Limited

Futu Securities International (Hong Kong) Limited

RA1 RA7

✓ Effective

asset Management
CICC Hong Kong Securities Limited

China International Capital Corporation (Hong Kong) Securities Limited

RA1 RA4 RA7

✓ Effective

The information is from the SFC's publicly available list of licensees and may not reflect the latest status. Please refer to the SFC's official website for the most accurate information.

Check the official SFC licensee register.

FAQs

Frequently Asked Questions

13 Frequently Asked Questions about Hong Kong Type 7 License Applications, Compiled Based on Official SFC Documents

Type 7 regulated activities (RA7) refer to the provision of Automated Trading Services, which involves operating a system through which people can trade or make offers for securities or futures contracts without the need for traditional human matching. The difference between Type 7 and Type 1 (Securities Trading) is that Type 7 focuses on providing trading system infrastructure, rather than directly executing trades on behalf of clients. The difference between Type 7 and Type 9 (Asset Management) is that Type 7 does not involve investment decisions, but only provides a trading execution platform.

The SFC's requirements for Type 7 licenses emphasize practical work experience and professional competence, rather than specific qualification exams. Personnel in charge must have at least three years of work experience directly related to RA7 and must meet the SFC's Competency Guidelines, demonstrating sufficient technical knowledge and professional skills. Currently, there are no mandatory qualification exams (RIQ/LRP) specified by the SFC/HKSI for RA7. If applying for other types of licenses simultaneously (such as RA1/RA2), the exam requirements for those categories must also be met. For specific requirements, it is recommended to contact the SFC directly or consult a professional advisor.

Without holding client assets, the minimum paid-up share capital is HK$5,000,000 and the minimum quick capital is HK$3,000,000. If client assets are held, the quick capital requirement increases to HK$5,000,000. If operating an authorized automated trading system (such as an authorized exchange) as an authorized controller, the requirement further increases to HK$10,000,000. If holding multiple licenses, the highest capital requirement among all types will apply.

全程約6-12個月，包括前期準備4-8週及SFC核准約15週（SFC《發牌手冊》第7.7段）。實際時間視申請材料品質及SFC工作量而定。若申請資料完整、資質符合要求，審核時間可能縮短；若SFC提出補充資料要求，則可能延長。

Type 7 licenses have stringent requirements for the technical systems, including: submission of system architecture documents and technical specifications; a complete risk management mechanism (including circuit breaker/circuit breaker mechanisms); provision of a network security policy and penetration test report; and the development of a disaster recovery plan (DRP) and a business continuity plan (BCP). The SFC may require a system demonstration or on-site inspection. This is the core requirement that distinguishes Type 7 licenses from other categories.

The responsible personnel must have at least three years of work experience directly related to Type 7 regulated activities and must meet the requirements of the SFC's Competency Guidelines. At least one responsible personnel must be based in Hong Kong, and licensed corporations must have at least two approved responsible personnel. The SFC has strict requirements for "directly relevant experience," typically requiring practical experience in relevant business within a licensed organization. Currently, there are no mandatory qualification examinations for RA7; specific competency standards are recommended and should be consulted with the SFC or a professional advisor.

Yes. Acquiring a company holding a Type 7 license can typically shorten the timeframe to 3-6 months, but thorough due diligence is required, including reviewing the target company's historical compliance record, financial condition, and potential legal risks. A change of controlling shareholder application must be submitted to the SFC before the acquisition can be completed and the property can be handed over. Acquisition costs vary significantly depending on the target company's circumstances, with market reference prices ranging from approximately HK$300 million to HK$1,500 million. This is for reference only; the actual cost needs to be confirmed through due diligence. Acquisitions are not a shortcut to circumventing regulatory review; the SFC also conducts rigorous reviews of changes in controlling shareholders.

持牌法團年度牌照費為HK$4,740（每類受規管活動），每名已核准負責人員年度牌照費為HK$4,740，每名持牌代表年度牌照費為HK$1,790。年度牌照費自2025年4月1日起恢復徵收。除官方牌照費外，還需考慮年度審計費用、合規顧問費用、系統維護費用及員工薪資等營運成本。

Yes. In practice, institutions holding a Type 7 license typically also hold Type 1 (securities trading) and/or Type 2 (futures contract trading) licenses to provide a full range of trading services. If an institution holds multiple types of licenses, the capital requirement will be based on the highest of the three types, and the qualification requirements for the personnel responsible for each type of license must be met separately.

Members of accredited exchanges may be exempt from applying for a Type 7 license (Section 116 of the SFO) if their automated trading activities are entirely incidental to their activities as exchange members. Furthermore, accredited exchanges themselves and accredited clearinghouses may also be exempt under certain conditions. However, this exemption generally does not apply to independently operating automated trading systems and providing services to third parties.

WINGS (Web-based Interactive Gateway System) is SFC's online application and communication system, located at wings.sfc.hk. Applicants must first register an account on WINGS, then complete the application form (Form 1 for licensed corporations and Form 3 for responsible personnel) through the system, and upload all supporting documents. SFC will conduct all communication and information supplementation with applicants through the WINGS system. Applicants must log in to the system regularly to check the latest status.

Yes. If an application is rejected, the applicant can resubmit it after addressing the issues raised by the SFC. It is recommended to consult a professional advisor before resubmitting to comprehensively review and improve the application materials to increase the approval rate. If the applicant disagrees with the SFC's decision, they may appeal to the Securities and Futures Appeals Tribunal.

Based on practical experience, the SFC focuses on the following aspects when approving Type 7 licenses: First, the robustness and security of the technical system, including risk management mechanisms, network security measures, and disaster recovery capabilities; second, the qualifications and experience of the responsible personnel, especially practical work experience directly related to automated trading; third, the company's compliance culture and internal control system; and fourth, capital adequacy and financial soundness. Applicants are advised to prepare thoroughly in these four areas.

The above content is based on the SFC official "Dealing Manual" (2025 edition). Please consult a professional advisor if you have any questions.

About Aiying

Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring XNUMX/XNUMX professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.

Authoritative guidance

Based on SFC official guidelines and Aiying's practical experience, we provide the most authoritative application guidance.

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Aiying's "pre-screening mechanism"

To maximize your success rate, Aiying conducts an internal mock review of your application materials before formal submission. Our expert team acts as a regulator, scrutinizing each document from the most rigorous perspective to identify logical loopholes, data inconsistencies, and compliance gaps in advance.

Through this mechanism, we can ensure that the materials submitted to the regulatory authorities are highly professional, complete and impeccable, thereby minimizing the number of regulatory inquiries and significantly shortening the approval time.And reduced the license rejection rate by 67%.