2026 Authoritative Guide

Hong Kong License No. 2
Futures contract trading

An authoritative application guide based on SFC's official guidelines and Aiying's practical experience. It comprehensively analyzes application requirements, business functions, capital needs, application process, and acquisition pathways.

What is license plate number 2?

The Hong Kong Securities and Futures Commission's Type 2 license (Dealing in Futures Contracts) is a license for regulated activities issued under the Securities and Futures Ordinance.

Under Part V of the Securities and Futures Ordinance (SFO), a Type 2 license authorizes the licensee to conduct futures contract trading business. It is directly regulated by the Securities and Futures Commission (SFC) of Hong Kong.

It covers services including futures brokerage, futures trading advisory, and proprietary futures trading. It allows trading of various futures contracts, including commodity futures, financial futures, and index futures.

As a leading financial center in Asia, Hong Kong's Type 2 license is an essential qualification for entering the futures market, and it enjoys high international recognition and regulatory credibility.

Business Function Breakdown

License Type 2 covers a variety of futures trading-related business functions, and companies can choose to apply for it according to their own needs.

Futures broker

Acting as an agent for clients to buy and sell futures contracts and collecting commissions. A robust client management and risk control system is necessary.

Futures trading advisor

Provide clients with futures investment advice and strategy analysis. Must possess professional market analysis capabilities and compliance consulting qualifications.

Futures proprietary trading

Using one's own funds for futures trading requires meeting higher capital requirements and risk management standards.

Futures asset management

Managing client funds for futures investment. This typically requires holding a Type 9 license (asset management).

  • For startups: it is recommended to start with futures brokerage business, which has relatively low capital requirements and a clear business model.
  • Established institutions can apply for a combination of multiple business functions, such as brokerage + consulting + self-operated, to provide comprehensive services.
  • Asset management platform: It is recommended to apply for both Type 2 and Type 9 licenses simultaneously, covering futures and securities asset management.

Business Scenario Matching Guide

Choose the most suitable application plan based on different capital sizes and business types.

Scene 1

New futures brokerage

Capital size: HK$8M-10M
Recommended allocation: Brokerage business (holding client assets)
Application path: Apply directly
Suitable for startups that want to build a brand from scratch

Scene 2

Crypto asset trading platform

Capital size: HK$10M-15M
Recommended configuration: Brokerage + Self-operated
Application path: Acquisition or application
Additional regulatory requirements related to crypto assets must be met.

Scene 3

Traditional financial institutions expand

Capital size: HK$10M+
Recommended configuration: Full service portfolio
Application path: Acquisition preferred
Quickly enter the market and supplement the product line

Scene 4

asset management company

Capital size: HK$8M-12M
Recommended configuration: License plates No. 2 + No. 9
Application path: Apply simultaneously
Covering the entire business chain of futures and securities asset management

Scene 5

High-frequency trading institutions

Capital size: HK$8M-15M
Recommended configuration: Primarily self-operated
Application path: Apply directly
Requires a robust technical system and risk control capabilities

Scene Six

Multinational financial groups

Capital size: HK$20M+
Recommended configuration: Multi-card combination
Application path: Acquisition preferred
Establish a Hong Kong regional headquarters to radiate across the Asia-Pacific region.

Application Requirement

Understand the full requirements for a Type 2 license to ensure your business complies with SFC regulatory standards.

Futures broker (does not hold client assets)

HK$100,000

Futures broker (holding client assets)

HK$3,000,000

Futures proprietary trading

HK$3,000,000

Application Requirements Comparison Table

Item Broker (does not hold assets) Broker (Asset Holding) proprietary trading
Minimum capital HK$100,000 HK$3,000,000 HK$3,000,000
RO quantity At least 2 people At least 2 people At least 2 people
Experience requirements more than 3 years more than 3 years More than 3 years of experience, and must have proprietary trading experience.
Compliance System Basic compliance architecture Complete customer asset management system Complete risk management system
Expected approval time 6–9 months 8–12 months 8–12 months

Self-assessment checklist

Check the following items to assess your application preparation.

Capital and Finance

  • Sufficient registered capital has been prepared (depending on the type of business).
  • The company is in good financial condition and has no significant debt.
  • Detailed business plans and financial forecasts have been developed.
  • Have sufficient funds to support continuous operation (12-24 months).

Personnel and experience

  • At least two RO candidates have been confirmed.
  • RO has at least 3 years of experience in futures/financial markets.
  • RO has passed the HKSI Paper 1 + Paper 2 exams.
  • At least one RO can be stationed in Hong Kong.

Compliance System

  • A complete internal control manual has been developed.
  • Anti-money laundering/counter-terrorism financing policies have been established.
  • A compliance officer and MLRO have been appointed.
  • Customer due diligence (KYC) process is ready.

Operational preparation

  • Hong Kong office address has been leased.
  • Trading system and risk control system have been configured.
  • Professional indemnity insurance has been purchased.
  • A business continuity plan has been developed.

If you selected more than 10 items, it indicates that you have a good foundation for your application. We recommend contacting Aiying for a professional assessment.

application process

The complete process from preparation to approval is broken down, with an estimated total time of 6-12 months.

Cost Structure

SFC application fee

HK$4,740/RA

Legal counsel fees

HK$80,000-150,000

Compliance advisory fees

HK$100,000-200,000

Total estimated cost

HK$250,000-700,000+

Annual continuing expenses

Annual license fee (licensed corporation)
RO Annual Fee

HK$4,740/RA
HK$4,740/person/RA

Total estimated annual cost

HK$150,000-400,000+

Application process broken down in detail

  • Incorporating a Hong Kong limited company and preparing registered capital
  • Decide on the RO candidate and arrange the HKSI exam (if necessary).
  • Lease office space in Hong Kong and configure infrastructure
  • Drafting business plans, internal control manuals, and AML/CFT policies.
  • Prepare application forms and supporting documents (company documents, financial statements, RO resume, etc.).
  • Contact a legal/compliance advisor for document review.
  • Submit your application online through the SFC WINGS system
  • Upload all required support files.
  • Pay the application fee (HK$4,740 per RA).
  • Waiting for SFC to confirm receipt of the application and assign a case number.
  • The SFC will conduct a preliminary review and may issue a request for supplementary information.
  • Conduct background checks and suitability assessments for RO.
  • Arrange interviews (usually with ROs and key management).
  • Review internal control manual, compliance policies and business plans
  • You may be required to modify the document or provide additional information (multiple rounds of requests).
  • Received SFC's approval letter and license certificate
  • Published in the SFC Public Register
  • Purchase Professional Indemnity Insurance (PI Insurance).
  • Complete system configuration and employee training
  • Officially commence business operations and establish a continuous compliance mechanism.

Acquisition vs. Direct Application

A comprehensive comparison of the two paths will help you choose the optimal solution.

direct application

Building your own licensed entity from scratch

Advantage

The cost is relatively low, estimated at HK$250K-700K.
Complete control over the company structure and business direction
No historical issues or potential risks
Compliance systems can be customized to meet individual needs.

Inferiority

× The approval process is lengthy (6-12 months).
× There is a risk that the application will be rejected.
× A completely new customer base and market reputation need to be established.
× More preparation and document drafting are needed.

Acquisition of existing licenses

Purchase of approved Type 2 license entities

Advantage

Rapid market entry (2-4 months)
No risk of application rejection, high certainty
It may involve existing customers and business relationships.
Established compliance framework and operational experience

Inferiority

× High cost, typically HK$2M-10M+
× Due diligence is required and may uncover hidden risks.
× SFC approval is required for equity change and RO replacement.
× Potential compliance issues arising from historical inheritance

Select suggestions

If you choose to apply directly:
  • Limited budget (
  • Ample time (6-12 months)
  • Desire for complete control
If the acquisition is chosen:
  • Need to enter the market quickly
  • Sufficient funds (>HK$3M)
  • Emphasis on Certainty
Hybrid solution:
  • First acquire the basic licenses
  • Apply for additional services later
  • Balancing speed and cost

Reference for licensed companies

The following showcases representative Type 2 license holders from different categories. Hong Kong boasts a large number of Type 2 license holders, encompassing various types including international investment banks, Chinese financial institutions, local securities firms, and independent futures brokers.

Source: SFC Public Register

Disclaimer: The following company information is for reference only and is used to showcase different types of Type 2 license holders. Specific license types and business scopes are subject to change at any time. For the latest and most accurate information, please visit the SFC Public Register for verification.

International Investment Bank

The Hong Kong subsidiaries of top global investment banks typically hold a full range of licenses, covering a comprehensive range of financial services including securities, futures, and asset management. These institutions possess strong capital bases, robust compliance systems, and serve as industry benchmarks.

Full license

Goldman Sachs (Asia) Securities Limited

Goldman Sachs (Asia) Securities Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Comprehensive investment banking services

Full license

Morgan Stanley Asia Limited

Morgan Stanley Asia Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Comprehensive investment banking services

Full license

UBS Securities (Hong Kong) Limited

UBS Securities Hong Kong Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Comprehensive investment banking services

Chinese financial institutions

The Hong Kong subsidiaries of major Chinese banks and financial groups, relying on the strong capital strength and customer resources of their parent companies, occupy an important position in the Hong Kong financial market.

Comprehensive license

BOC International Securities Limited

BOCI Securities Limited
Includes Type 2 licenses and other regulated activities

parent company:
China Bank

Comprehensive license

ICBC International Securities Limited

ICBC International Securities Limited
Includes Type 2 licenses and other regulated activities

parent company:
Industrial and Commercial Bank of China

Comprehensive license

CCB International Securities Limited

CCB International Securities Limited
Includes Type 2 licenses and other regulated activities

parent company:
China Construction Bank

Hong Kong local brokerage

A securities and futures company established and developed in Hong Kong, with years of experience in the Hong Kong market and a stable local client base.

Securities + Futures

Yiu Choi Securities & Finance Limited

Bright Smart Securities & Commodities Group Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Retail broker

Securities + Futures

Phillip Securities (Hong Kong) Limited

Phillip Securities (Hong Kong) Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Comprehensive brokerage

Securities + Futures

KGI Securities Asia Limited

KGI Asia Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Comprehensive brokerage

Online brokerage

A new generation of online securities and futures companies, driven by technology, providing online trading platforms and mobile applications.

Technology-driven

Futu Securities International (Hong Kong) Limited

Futu Securities International (Hong Kong) Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Online brokerage

Technology-driven

Tiger Brokers (Hong Kong) Limited

Tiger Brokers (Hong Kong) Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Online brokerage

Technology-driven

Interactive Brokers (Hong Kong) Limited

Interactive Brokers Hong Kong Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Global trading platform

Independent futures brokers

Independent brokerage firms that specialize in futures trading typically hold only a Type 2 license and provide professional services to institutional clients and professional investors.

Futures major

PanShi Financial Co., Ltd.

Bands Financial Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Futures broker

Futures major

Galaxy Futures (Hong Kong) Limited

China Galaxy International Futures (Hong Kong) Co., Ltd
Includes Type 2 licenses and other regulated activities

parent company:
Galaxy Securities

Futures major

Maike Futures Asia Limited

Marex Asia Limited
Includes Type 2 licenses and other regulated activities

Business Features:
Commodity futures

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.

FAQs

Provide strategic and actionable solutions to the most critical pain points.

Based on publicly available data from the SFC and Aiying's practical experience, a well-prepared application has a success rate of approximately 75-85%. Key factors influencing approval include the actual involvement of the RO, the feasibility of the business plan, capital adequacy, and the completeness of the compliance system.

SFC offers some flexibility in its requirements for Operational Response (RO) experience. A non-sole RO approach can be adopted, where less experienced ROs work under the supervision of more experienced ones. Alternatively, additional training (such as CVAP) can be provided to supplement futures trading expertise.

Yes, but additional conditions must be met: trading can only be conducted on licensed exchanges recognized by the SFC, providing services to retail clients requires a more stringent suitability assessment, capital requirements may be increased to at least HK$5 million, and special risk control measures for crypto assets must be established.

License Type 1 is for securities trading, while license Type 2 is for futures contract trading. The main difference lies in the trading instruments: License Type 1 involves spot securities such as stocks and bonds, while license Type 2 involves derivatives such as futures contracts and options.

Whether you need to apply for both depends on your business needs. If you only engage in futures trading, you only need to apply for License No. 2. However, if you wish to provide comprehensive financial trading services, it is recommended to apply for both License No. 1 and License No. 2 simultaneously, so that you can provide clients with one-stop services for securities and futures.

You can reapply, but it's recommended to carefully analyze the reasons for rejection first. The SFC usually explains the reasons in the rejection letter. Common reasons for rejection include: insufficient RO experience, unclear business plan, inadequate compliance system, and insufficient capital.

Reapplication timeline: There is no mandatory waiting period, but it is recommended to wait at least 3-6 months to fully resolve the issues that led to the rejection. Reapplying without addressing the root cause greatly increases the chances of being rejected again.

Key risk points:

  • Historical compliance issues: Check for any unresolved SFC warnings, fines, or complaints.
  • Hidden liabilities: A comprehensive review of the financial situation is essential during due diligence.
  • RO turnover risk: Ensure existing ROs are willing to stay or have replacements ready.
  • Customer churn: Changes in equity ownership may lead to the loss of existing customers.
  • SFC Approval Risk: Equity changes require SFC approval, which typically takes 2-4 months.

Recommendation: Hire professional legal and compliance advisors to conduct due diligence and include reasonable safeguards in the purchase agreement.

Key continuing obligations include:

  • Annual filing: Submit financial statements and business reports annually.
  • Capital adequacy: Continuously meeting minimum capital requirements
  • RO Management: Maintain at least 2 ROs; any changes must be reported to SFC.
  • Compliance Training: Provide employees with regular compliance training.
  • Record retention: Transaction records must be retained for at least 7 years.
  • Customer Complaint Handling: Establish an effective complaint handling mechanism
  • Internal audit: Conduct internal audits and compliance checks regularly.
  • Reporting of significant events: Reporting significant changes or events to the SFC.

Mainland companies applying for Hong Kong Type 2 licenses should pay special attention to the following:

  • Architectural design: Typically, a subsidiary, rather than a branch office, needs to be established in Hong Kong.
  • RO Candidates: Mainland residents are eligible to serve as ROs, but must have a work visa in Hong Kong and be residing there regularly.
  • Cross-border business: Must comply with mainland China's foreign exchange management regulations.
  • Tax planning: Considering tax arrangements between Hong Kong and Mainland China

Advantages: Mainland Chinese companies typically possess stronger capital and customer resources, giving them an advantage in the application process. It is recommended to collaborate with consultants like Aiying, who are familiar with the regulations in both regions.