Contents

License Application
4. Introduction to the functions of Hong Kong Securities Adviser Type XNUMX License
II. Basic Qualification Requirements
III. Application Process
IV. Application Period
License Acquisition
Acquisition process and time
Service Introduction
Customer type
License Case
team introduction
FAQ

4. Introduction to the functions of Hong Kong Securities Adviser Type XNUMX License

The Hong Kong Securities Advisor Type 4 License (Type XNUMX Regulated Activity License) is issued by the Hong Kong Securities and Futures Commission (SFC) under the Securities and Futures Ordinance to regulate the activity of "providing advice on securities". The following is a detailed description of its functions:

Main functions of the No. 4 card

  1. Provide securities investment advice :
    • Providing clients with investment advice on securities such as stocks, bonds, exchange-traded funds (ETFs), security tokens, etc.
    • Recommendations may include buying, selling or holding specific securities, or investment strategies that respond to market trends.
    • Applicable to individual investors, institutional clients or other financial intermediaries.
  2. Writing and distributing research reports :
    • Prepare and publish securities-related analytical reports, such as stock research, bond ratings, or market analysis.
    • The report can be used as a reference by clients, the public or institutions to support investment decisions.
    • For example, an analyst at a securities firm might issue a "buy" or "sell" rating for a stock.
  3. Portfolio and Strategy Consulting :
    • Providing advice on the construction, management or optimization of securities portfolios.
    • Recommend security allocation or investment strategy based on the client's risk tolerance, financial goals or market environment.
    • It may involve asset allocation, risk management or long-term investment planning.
  4. Market Commentary and Investment Education :
    • Share securities market insights or provide investment education through the media, seminars or publications.
    • Help investors understand market dynamics or securities product features.

Virtual asset related functions

  • Securities virtual assets :
    • If virtual assets (such as security tokens) are deemed to be “securities” under the Securities and Futures Ordinance, License No. 4 allows:
      • Provide investment advice on security-type virtual assets (such as buying and selling advice).
      • Publish relevant research reports or market analysis.
      • Design an investment portfolio that includes security-type virtual assets.
    • For example, tokens representing equity or debt are securities and licensees can provide related advisory services.
  • Non-Securities Virtual Assets :
    • The proposal for non-securities virtual assets such as Bitcoin and Ethereum does not fall within the scope of the Type 4 license and may be subject to the SFC’s Virtual Asset Service Provider (VASP) framework or other regulations.

Functional limitations

  • Recommendations only: License No. 4 only allows the provision of advice, not the execution of securities transactions (License No. 1 "Securities Trading" is required).
  • Does not cover corporate financing: Corporate financing proposals involving listing, mergers and acquisitions, etc. require a Type 6 license.
  • Excluding asset management: Direct management of client funds or investment portfolios requires a No. 9 license.
  • Product range: Limited to securities as defined in the Securities and Futures Ordinance, excluding futures contracts (requiring a Type 5 license) or non-securities products.

Practical application

  • Securities firm analysts provide stock recommendations or research reports to clients.
  • Independent financial advisors design securities investment strategies for high net worth clients.
  • Investment advisory firms provide market analysis or asset allocation advice.
  • Financial education institutions share insights into securities markets.

4. Companies applying for Hong Kong Type XNUMX License (Securities Advisor) need to meet the following basic eligibility requirements:

1. Fit and Proper Requirements

The SFC requires that the applicant company and its relevant personnel (such as major shareholders, directors, responsible personnel) are "fit and proper persons", including:
  • financial soundness :
    • The company needs to prove that it is in good financial condition and has no bankruptcy or major financial problems.
    • Minimum Liquid Capital Requirement: Depending on the size of the business, usually HK$100,000 to HK$3,000,000 (depending on whether it involves client asset management or just providing advice).
  • Character and Integrity :
    • The company and its key personnel have no criminal record or violations of financial regulatory requirements.
    • Any past regulatory penalties or legal proceedings need to be disclosed.
  • Professional ability :
    • The company needs to demonstrate that it has the expertise and operational capabilities to engage in securities advisory activities.
    • Responsible Officers (RO) are required to pass the Hong Kong Securities and Investment Institute (HKSI) qualification examinations (such as Paper 1 “Basic Securities and Futures Regulation” and Paper 6 “Securities and Corporate Finance Advisory”) or obtain exemptions.

2. Company establishment requirements

  • Hong Kong registered company :
    • The applicant company must be incorporated in Hong Kong (such as a limited company) or an overseas company registered in Hong Kong.
    • Documents such as the company's incorporation certificate, memorandum of association and articles of association are required.
  • Actual Operation :
    • The company must have actual business operations in Hong Kong, such as setting up an office and hiring local employees or responsible persons.
    • The SFC may require proof that the company’s business activities in Hong Kong are genuine and ongoing.

3. Responsible Officer (RO) Requirements

  • Appointment of RO :
    • The company is required to appoint at least two Responsible Officers (RO) to oversee the regulated activities of License IV.
    • At least one RO must be an executive director and be based in Hong Kong to perform supervisory duties.
  • RO Qualification :
    • Have at least 3 years of relevant industry experience (2 years of which must be management experience).
    • Pass the HKSI qualifying examinations (e.g. Paper 1 and Paper 6), or possess a recognised professional qualification (e.g. CFA, CPA) and apply for exemption.
    • No bad record and meets the "fit and proper candidate" standard.
  • RO Responsibilities :
    • Ensure the company complies with the regulations and compliance requirements of the Securities and Futures Commission.
    • Responsible for overseeing the operations and risk management of securities advisory activities.

4. Compliance and Internal Control

  • Compliance Framework :
    • Companies need to establish comprehensive compliance policies and internal control mechanisms, such as anti-money laundering (AML) and customer knowledge (KYC) procedures.
    • Submit a compliance manual outlining how conflicts of interest, client data protection and fairness of advice are managed.
  • Risk Management :
    • Risk management policies need to be formulated to ensure sound business operations and protect customer interests.
  • independent audit :
    • The company needs to appoint an independent auditor to audit its financial statements regularly and submit them to the Securities and Futures Commission.

5. Business Plan

  • Detailed business plan :
    • Submit a business plan describing the scope of the Company's activities (e.g., providing securities advice, research reports, or investment strategies).
    • Including target customer groups, market positioning, revenue model and operating structure.
    • If security-type virtual assets (such as security tokens) are involved, the relevant business model and compliance measures must be clearly stated.
  • Technology and System :
    • Demonstrate that the firm has technology systems in place to support securities advisory activities, such as data analytics tools or client management systems.

6. Application documents and fees

  • needed file :
    • A completed SFC prescribed form (Form A or other relevant form).
    • Audited financial statements of the company.
    • Educational background, experience and examination results of the responsible person (if applicable).
    • Compliance manual, business plan and internal control policy.
    • Background information and criminal record certificates of major shareholders and directors.
  • Application Fee :
    • The application fee for a Type 4,740 license is approximately HK$XNUMX (the fee is set by the SFC and may be adjusted over time).
  • Other expenses :
    • This may involve service fees from intermediaries (such as lawyers or consultants), as well as HKSI examination or training fees.

7. Education and examination requirements

  • Education :
    • Responsible officers are usually required to possess relevant academic qualifications (such as finance, economics, law or accounting), or equivalent professional qualifications.
    • The SFC may accept extensive industry experience in lieu of formal academic qualifications, subject to individual case approval.
  • HKSI Examination :
    • Responsible officers and relevant employees are required to pass HKSI’s Licensing Examination, which usually includes:
      • Paper 1: Basic securities and futures regulation.
      • Paper 6: Securities and corporate finance advisers.
    • Exempt: If you have a CFA, CPA or equivalent overseas license and are experienced, you can apply for partial exam exemptions, but you must submit supporting documents.

8. Other things to note

  • application time :
    • The CSRC's approval process usually takes 3-6 months, depending on the completeness and complexity of the application materials.
    • If the information is insufficient, the CSRC may request additional information and extend the approval time.

       
  • Continuous Compliance :
    • After approval, the company must comply with the CSRC's ongoing regulatory requirements, such as submitting annual financial statements and completing continuing professional training (CPT).
  • Virtual asset related :
    • If the business involves security-type virtual assets (such as security tokens), it is necessary to ensure compliance with the CSRC’s virtual asset regulatory guidelines and may be required to provide additional proof of compliance capabilities.
Summary
Companies applying for Hong Kong's Type 4 license must meet requirements such as financial soundness, compliance framework, professional capabilities and substantial operations. The key is to prove that the company and its responsible persons are "fit and proper persons" and have the ability to engage in securities advisory activities. Submission of a detailed business plan, compliance policy and proof of qualifications of responsible personnel is key.

3. Application Steps Guide

Before formally submitting an application, the applicant company must complete the following preparations:
  • Company establishment :
    • Make sure the company is incorporated in Hong Kong (such as a limited company) or is an overseas company registered in Hong Kong.
    • Preparation of documents such as Certificate of Incorporation, Memorandum and Articles of Association.
  • Business Plan :
    • Prepare a detailed business plan that describes the scope of the activities to be carried out (such as securities investment advice, research reports or investment strategies), including target customers, revenue model and operating structure.
    • If securities-type virtual assets are involved, the relevant business model and compliance measures must be clarified.
  • Responsible Officer (RO) :
    • Appoint at least two Responsible Officers (ROs), at least one of whom shall be an executive director and shall be resident in Hong Kong.
    • Ensure that the RO has at least 3 years of relevant industry experience and has passed the Hong Kong Securities and Investment Institute (HKSI) qualification examinations (such as Paper 1 “Basic Securities and Futures Regulation” and Paper 6 “Securities and Corporate Finance Advisers”), or obtained exemptions.
  • Compliance and Internal Control :
    • Develop a compliance manual covering policies such as Anti-Money Laundering (AML), Know Your Customer (KYC), conflict of interest management and customer data protection.
    • Establish risk management mechanisms and internal control systems.
  • financial preparation :
    • Ensure the company meets the minimum liquid capital requirement (usually HK$100,000 to HK$3,000,000, depending on the size of the business).
    • Prepare audited financial statements to demonstrate financial soundness.
  • Exams and Qualifications :
    • ROs and related staff are required to complete the HKSI qualification examination or submit an application for exemption (e.g. holding CFA, CPA or overseas equivalent qualifications).
    • Ensure that key personnel have relevant academic qualifications or industry experience.
The applicant company needs to prepare the following documents and submit them to the CSRC:
  • SFC Prescribed Forms :
    • Fill in Form A (corporation application) or related forms, detailing the company information, business scope and responsible personnel information.
  • Company Documents :
    • Certificate of Incorporation, Memorandum and Articles of Association.
    • Most recent audited financial statements and proof of working capital.
  • Responsible Personnel Information :
    • RO’s resume, academic qualifications, industry experience and HKSI examination results (or exemption certificate).
    • Proof of no criminal record (such as a “Certificate of No Criminal Record” issued by the Hong Kong Police Force or an overseas equivalent document).
  • Business Plan :
    • Describe in detail the business model, market positioning and operational plan of the No. 4 card activity.
  • Compliance Documents :
    • Compliance manual, anti-money laundering policy, risk management policy and internal control procedures.
  • Other supporting documents :
    • Background information and criminal record certificates of major shareholders and directors.
    • Certificate of appointment of independent auditor.
    • If securities-type virtual assets are involved, relevant compliance plans must be submitted.
  • Submission method :
    • Submit application documents through the CSRC's online application system (WINGS, Web-based INterface for Submission).
    • Ensure that all documents are complete and comply with the SFC format requirements.
  • Application Fee :
    • The application fee for a Type 4,740 license is approximately HK$XNUMX (based on the latest fee schedule of the Securities and Futures Commission, the fee may be adjusted over time).
    • Fees are payable when submitting your application, via the WINGS system.
  • Points to note :
    • It is recommended to hire a professional advisor (such as a lawyer or compliance consultant) to review the application documents to ensure that they comply with the requirements of the CSRC.
    • If the documents are incomplete, the SFC may refuse to accept the application or request additional information.
After submitting the application, the CSRC will proceed with the following review and approval steps:
  • Initial review(1-2 weeks):
    • The CSRC confirms whether the application documents are complete and checks whether they meet the basic requirements.
    • If the documents are missing or in the wrong format, the applicant will be asked to supplement them within a specified time.
  • Detailed review(2-4 months):
    • The SFC assesses the applicant company’s “fit and proper” qualifications, including financial status, character integrity and professional ability.
    • Review business plans, compliance frameworks and internal control systems.
    • Verify RO's qualifications, experience and examination records.
  • background check :
    • The CSRC may conduct background checks on the company, major shareholders, directors and ROs to confirm that there are no criminal records or regulatory violations.
  • Interview or clarification(depending on the situation):
    • The CSRC may require the applicant company or RO to attend an interview to further explain the business model or compliance arrangements.
    • Additional information may be requested, such as more detailed financial projections or risk management plans.
  • Approval Result :
    • If the application is approved, the SFC will issue a license approval notice and require payment of the annual license fee (approximately HK$4,290, depending on the latest standards).
    • If the application is rejected, the SFC will provide reasons for the rejection and the applicant may choose to reapply after submitting additional information or lodge an appeal.
After the license is approved, the company needs to fulfill the following ongoing obligations:
  • Compliance supervision :
    • Comply with the regulatory requirements of the Securities and Exchange Commission, such as filing annual financial statements and maintaining compliance records.
    • Ensure advice is fair, independent and free from conflicts of interest.
  • Continuing Professional Training (CPT) :
    • ROs and related staff are required to complete a specified number of hours of CPT courses each year (usually 5-10 hours, depending on the role).
  • License renewal and fees :
    • Pay license renewal fees every year and file an annual return.
  • reporting obligations :
    • Major business changes (such as shareholder changes, RO resignation) must be notified to the CSRC in a timely manner.

IV. Application period for Hong Kong Securities Advisor (VA) Type 4 license

Stairs Main tasks Estimated time Remark
1. Preparation 2-6 months Depends on the company's existing resources and professional support
Company establishment and restructuring

– Establish a Hong Kong limited company or register an overseas company

– Adjust shareholder/director structure, background check

 1-2 months New companies need 1-4 weeks to register; existing companies can shorten the time
Responsible Officer (RO) Preparation

– Appoint at least 2 ROs (3 years of experience)

– RO must pass the HKSI examination (Paper 1, Paper 6) or apply for exemption

 1-3 months Exam preparation takes about 1-2 months; waiver application takes 2-4 weeks
Compliance and Business Planning

– Develop compliance manuals (AML, KYC, etc.)

– Write a business plan (scope of activities, market positioning)

 1-3 months Virtual asset businesses need an additional 1-2 months to prepare compliance plans
Finance and Documentation Preparation

– Audited financial statements (to meet working capital requirements)

– Collect RO resume, criminal record certificate, etc.

 1-2 months Liquid capital requirement: HK$100,000 to HK$3,000,000
2. Submission and approval stage 3-6 months Depends on the quality of the application and the complexity of the business
Initial review

– CSRC checks the completeness of documents

 1-2 weeks Missing documents need to be supplemented, about 1-2 weeks
Detailed review

- Assessing “fit and proper person” (financial, character, professional ability)

– Review business plans, compliance frameworks

 2-4 months Virtual asset business may be extended by 1-2 months
Background Check and Clarification

– Investigate company/RO background

- Interview or additional information

 2-8 weeks Depending on the requirements of the Securities Regulatory Commission, it will take 2-4 weeks to submit additional information
Final Approval

- Issue approval notice and pay annual license fee

 1-2 weeks Annual fee: approximately HK$4,290
3. Post-approval follow-up 1-2 weeks Quick start of business
Licence effective

- Pay the fee and the license will become effective

 multiple days Confirmation of payment required
Compliance Startup

– Launch compliance system and arrange CPT training

 1-2 weeks 5-10 hours of CPT required per year
Business Development

- Provide securities advisory services and adjust operations

 1-2 weeks Depending on business readiness

Total time estimate

situation Total time Explain
Fastest case 5-6 months Mature company, RO has passed the exam, hired professional consultants, simple business
General situation 6-12 months New companies may need to take exams, have moderately complex businesses, and have limited professional support
complications 12-18 months Involving securities-type virtual assets, multiple types of licenses, and multiple supplementary documents

Factors Affecting the Timetable

factor 影響
Application quality If all documents are complete, the time can be shortened by 1-2 months; if missing documents need to be supplemented, the time can be extended by 1-2 months
Business complexity Simple business (such as stock recommendations) is faster; virtual asset business takes 1-2 months longer
RO Preparation Add 1-2 months to the exam or exemption application
Workload of the Securities Regulatory Commission The peak application period (such as the end of the year) may be extended by 1-2 months
Professional support Hiring a lawyer/consultant can save 1-2 months
Suggest
  • Plan ahead: Start at least 6-12 months in advance to allow time for exams and supplementary materials.
  • Professional assistance: Hire a compliance consultant or lawyer to speed up document preparation and review response.
  • Virtual asset business: An additional 1-2 months is required to prepare a compliance plan, and the approval process is more stringent.
  • Regular follow-up: Contact the SFC through WINGS system or consultants and respond to requests in a timely manner.

Hong Kong Securities Advisor (VA) Type 4 License Acquisition Process and Timetable

Stairs Substeps Estimated time Shortening strategy
Preliminary preparation – Demand analysis: confirm business goals and budget

– Target screening: Screening of No. 4 companies

– Due diligence: review compliance, finance, and legal

– Letter of Intent: Negotiation and signing of LOI

 1-3 months – Clarify the needs in advance and shorten the time to 1-2 weeks

– Choose a company with a clean compliance record and shorten the time to 2-3 weeks

– Parallel financial/legal review, shortened to 3-4 weeks
Trade Execution – Final negotiation: negotiate price and terms

– Transaction agreement: Signing of SPA

– Funding preparation: complete funding approval

– Application documents: prepare change materials for the Securities and Futures Commission

 1-2 months – Using standardized templates, shortening the time to 1-2 weeks

– Prepare for RO qualification in advance, shortened to 1 week

– Quick funding, shortened to 3-5 days
CSRC approval – Submit application: Submit change information

– Preliminary review: Checking the completeness of the documents

- Detailed review: assessing “fit and proper person”

- Supplementary/interview: respond to the requirements of the CSRC

- Approval: Issue approval notice

 2-4 months – Ensure all documents are complete and shorten the time to 1-2 weeks

– Simulate problems in advance, shorten the time to 4-6 weeks

- Avoid virtual asset business and shorten to 2 months
Subsequent compliance – Compliance start-up: system update and CPT training

– Business integration: integrating customer base/system

– Operation start-up: Provide consulting services

 2 weeks - 2 months – Using existing systems, shortened to 1-2 weeks

– Plan integration in advance, shorten it to 1-2 weeks
Total 4-12 months
(The fastest is 4-6 months, and the most complicated is 12-18 months)		 – Professional consultant saves 1-3 months

– Simple business can take up to 4-5 months

Customer service type

Asset Management Institutions

Asset Manager

Lending Institutions

loan provider

Exchange

cryptocurrency exchange

traditional finance

Traditional Financial

Brokerage Institutions

broker-dealer

OTC institutions

OTC provider

License Case

business planning

Conducting overseas financial business requires comprehensive planning

Corporate Framework

資金
  • Total treasury requirements
  • Liquidity requirements
  • Regulatory agencies’ external requirements
  • Are the funds already overseas?
Background of shareholders and directors
  • Suitable person
  • Industry background
  • Reputation and qualifications
  • Do Hong Kong/offshore license companies need to increase?
Professionals
  • Company person in charge
  • Professional staff (RO)
  • Other financial professionals: sales, compliance, settlement, etc.
  • Do the personnel match the business needs?
Office location
  • Business Location
  • Separation of front office, back office and back office in compliance with regulatory requirements
  • Connections to exchanges
  • Purchase office furniture

Corporate Compliance

license
  • What is the operating area itself?
  • The various laws and regulations that media business must comply with and the Securities and Futures Commission
  • Various periodic and prudent declarations

! The Jingbiantong team will assist customers in making the most appropriate plans and provide corresponding services in various fields according to their actual background and business needs.

我們的團隊

Director and Founder

▶ Honorary Fellow of Hong Kong Baptist University
▶ Served as executive director and independent non-executive director of several listed companies
▶ Manage the regulated business of comprehensive financial enterprises (listed and unlisted):
-Securities business (CSRC No. 1 license)
-Futures business (CSRC license No. 2)
-Investment Banking Business (China Securities Regulatory Commission License No. 6)
-Asset management business (CSRC license No. 4 and 9)
-Insurance Brokerage Business (PIBA Member)
-Money Lending Business (Money Lenders Licence)
▶ Served as the head of the legal and compliance department of a listed financial company, dealing with different regulatory agencies

Director and Founder

▶ Bachelor of Science, Master of Business Administration, Master of Financial Engineering, Hong Kong University of Science and Technology
▶ Long-term management of regulated businesses of comprehensive financial enterprises:
-Securities business (CSRC No. 1 license)
-Futures investment business (CSRC license No. 2, 5)
-Investment Banking Business (China Securities Regulatory Commission License No. 6)
-Automated Trading (CSRC License No. 7)
-Asset management business (CSRC license No. 4 and 9)
-Insurance Brokerage Business (IA Member)
-Money Lending Business (Money Lenders Licence)
▶ He has over 15 years of experience in asset management, investment research and compliance management and is a senior consultant in the industry.

General Manager

Bachelor of Arts from the Chinese University of Hong Kong, Master of Social Sciences in Communication from the Chinese University of Hong Kong, Master of Professional Accounting and Corporate Governance from the City University of Hong Kong.
She is a member of the Hong Kong Institute of Corporate Governance and the Institute of Chartered Secretaries and Administrators in the United Kingdom, and possesses the professional qualifications of Chartered Secretary (CS) and Corporate Governance (ACG).
Active in the compliance industry for over ten years.

Senior Vice President

Master of Finance from the Hong Kong Polytechnic University. Chartered Financial Analyst (CFA) charterholder.
He has nearly ten years of experience in the Hong Kong securities and asset management industry, managing assets worth over HK$30 billion.
Possess the qualification of Responsible Officer (RO) of a licensed company. Familiar with the products and compliance operations of Hong Kong securities firms and asset management companies.

Vice President

Bachelor of Science from the University of Hong Kong. With nearly ten years of experience in applying for various financial-related licenses and establishing software and hardware supporting facilities,
The clients we have served are located in many regions around the world, spanning different backgrounds, and their licensing needs are comprehensive and complex.

※ The list of professional team members is not exhaustive. There is also an advisory team including professional accountants from licensed institutions, lawyers, and former management members of regulatory agencies.

🏆 The team is more than 100 Different types of financial licenses provide various compliance-related services. Including but not limited to:

-State-owned enterprise group affiliated companies
-Subsidiary of China's Top 500 Private Enterprises
-Subsidiaries of major domestic real estate developers
-Hong Kong Main Board listed financial group

-Former fund manager of a large investment bank
-Algorithmic Trading Hedge Fund Firms
-Fin-tech companies under listed technology companies
-Top domestic law firms

🏆 The founder has managed listed financial companies and handled securities regulatory affairs.experienceRich, other team members have practical management and operation experience in well-known financial industries,Practical operationlevelWe provide feasible compliance ideas and compliance solutions to help customers develop their business.

🏆 The team has served mainland enterprises and entrepreneurs for many years.FamiliarDomestic conditions and customer needs, can assist customersadaptThere are many differences between the two places in terms of culture, supervision, system, business environment, etc.

FAQs

  • Hiding liabilities or compliance issues: The target company may have undisclosed financial liabilities or regulatory penalties that may affect post-acquisition operations.
  • RO resignation: If the original RO is not willing to stay on, a new RO will be appointed (requires 3 years of experience and exams), which will add 1-2 months.
  • Business mismatch：The target company’s customer base or operating model does not match customer needs and requires additional integration time.
    solution: Conduct thorough due diligence, secure RO retention agreements, and screen companies with business matches.
  • Only partially covered. If virtual assets are classified as securities (such as security tokens), License No. 4 allows the provision of investment advice, research reports or strategic consulting; non-security virtual assets (such as Bitcoin) are not within the scope of License No. 4 and may require a Virtual Asset Service Provider (VASP) license or no license (if there is no trading). You need to hire a lawyer to distinguish the types, as incorrect classification may violate regulations.
  • Case: In 2023, a company was asked by the China Securities Regulatory Commission to rectify its mistakes for including non-securities virtual assets in its No. XNUMX license business.
  • solution: Hire a lawyer familiar with the 2023 virtual asset guidance to ensure business compliance.
Special risks include:
  1. Compliance records are complex：The target company may have outstanding regulatory issues due to its virtual asset business (such as failure to comply with the 2023 Guidance), increasing the due diligence time (6-8 weeks).
  2. Technical system requirements：Virtual asset business requires a dedicated transaction monitoring and data security system. If the target company’s system is insufficient, integration will take 2-3 months.
  3. market volatility： Fluctuations in the virtual asset market may affect the financial stability of the target company and increase the difficulty of financial audits.
    Case: In 2024, a No. 2 company involved in the acquisition of virtual assets renegotiated the price and extended the transaction by XNUMX months due to the discovery of undisclosed compliance violations.
    solution: Hire a dedicated blockchain compliance consultant to thoroughly review technical systems and regulatory records.
  • The most common obstacles in the application process include insufficient qualifications of the Responsible Officer (RO), incomplete documentation and difficult financial requirements.
  • detail：RO需具備至少3年相關經驗並通過HKSI考試（Paper 1「基礎證券及期貨規管」、Paper 6「證券及企業融資顧問」），若無資格或需臨時委任新RO，可能延長準備時間1-3個月。文件不完整（如業務計劃、合規手冊或財務證明缺失）可能導致證監會要求補充，延長審批2-4週。財務要求需維持最低流動資本（通常10萬至300萬港幣），新設立公司可能難以滿足。
  • Case: In 2024, a new company’s application was delayed by 3 months because the RO failed the exam.
  • solution: Prepare for RO qualifications in advance, hire a compliance consultant to review documents, and ensure financial stability.
  • On February 2025, 2, the SFC launched the "ASPI-Re" regulatory roadmap (Access, Safeguards, Products, Infrastructure, Relationships), which includes 18 measures aimed at enhancing the security, innovation and growth of Hong Kong's virtual asset market. Although it is mainly aimed at virtual asset trading platforms (VATP), OTC transactions and custody services, it also has indirect impacts on Type 12 licensees:
    • Access: Simplifying market access and establishing a licensing framework for OTC trading and custodial services may provide Type 4 licensees with more recommended objects and product choices.
    • Safeguards: Strengthening investor protection and market integrity may require Category 4 licensees to adhere to stricter compliance standards when providing virtual asset advice.
    • Products：To promote innovation in virtual asset products (such as token listings and derivatives), Type 4 licensees need to understand the characteristics and risks of these new products.
    • Infrastructure: Modernizing supervision and using technology to improve risk management may require Type 4 licensees to improve their technical capabilities.
    • Relationships: Enhanced collaboration with industry stakeholders and international regulators to potentially impact compliance requirements for cross-border virtual asset proposals.
  • Case: In 2025, the roadmap proposes a new licensing framework, which may affect Type XNUMX licensees to update their compliance plans.
  • solution: Pay attention to updates on the CSRC official website to ensure that the advisory services meet the new standards.
  • Problem Details：The SFC may conduct surprise inspections (such as on-site interviews or requests for temporary submission of information) during the application or acquisition approval process, especially for new applicants or companies involved in acquisitions, to ensure the "fit and proper person" standard. The inquiry may focus on the RO’s actual experience, the feasibility of the business plan, or the integrity of the compliance framework.
  • challenge: Insufficient preparation (e.g. the RO cannot clearly explain the business model or the compliance manual is incomplete) may result in a 2-4 week delay in approval or even rejection.
  • Case: In 2024, a company applying for a No. 1 license was asked to supplement a detailed plan and its approval was delayed by one month because the RO failed to fully explain the virtual asset business model during the interview.
  • solution :
    • Simulate CSRC inquiries in advance and prepare answers to common questions (such as business model and risk management).
    • Ensure that ROs receive mock interview training and are familiar with the business details.
    • Hire a compliance consultant to improve documents and ensure that you are ready to respond to inspections at any time.
  • According to the SFC’s 2023 Virtual Assets Guidelines, when providing advice on security-type virtual assets (such as tokenized securities), Type 800 licensees must ensure that their clients are professional investors (personal assets of at least HK$XNUMX million or institutions) and pass a virtual asset knowledge test.
  • challenge：Suitability assessment requires detailed records of the client’s financial situation and knowledge level. If it is not properly performed, it may be considered a violation by the CSRC, and may result in fines or business restrictions. Small and medium-sized companies may lack systematic assessment tools.
  • Case: In 2024, a company was warned by the China Securities Regulatory Commission and asked to rectify its situation for failing to verify the customer's knowledge level.
  • solution :
    • Develop a standardized suitability assessment process and use digital tools to record client profiles.
    • Provide customer education materials to help pass knowledge tests.
    • Regular audits are conducted to ensure compliance.
  • : The market for virtual assets (such as security tokens) is highly volatile, which may cause customers to lose money on their investments and complain about inappropriate advice. The SFC requires licensees to provide risk disclosures and ensure that advice is suitable for clients’ risk tolerance.
  • challenge：High volatility increases the risk of complaints, and small and medium-sized companies may find it difficult to cope with frequent risk assessment updates due to limited resources.
  • Case: In 2024, a company was complained by customers for failing to update the virtual asset risk disclosure in a timely manner and was required to pay a settlement fee of HK$10.
  • solution :
    • Implement a dynamic risk assessment system and regularly update market analysis.
    • Provide clear volatility risk warnings to clients and document communications.
    • Invest in market data tools (such as blockchain analysis platforms) to improve the accuracy of recommendations.

Recent articles

AiYing provides the latest and most professional Hong Kong regulatory policy information for the industry, just for more professional services

[Aiying license] Must-read for Hong Kong financial license holders: The Ultimate Guide to Upgrading from Type 1 License to VA License (2025 Edition)

With the Hong Kong Special Administrative Region Government issuing policy declarations in October 2022 and June 10, it has clearly stated its goal of building a world-leading virtual asset (Virt

16
June
Hong Kong’s virtual asset regulation evolution and a practical guide to license applications

(PDF document obtained by private message) Contents Introduction: Embracing change, a new era of virtual asset regulation in Hong Kong Part I: The evolution of Hong Kong’s virtual asset regulatory framework

09
June
Comparison of the stablecoin bills in Hong Kong, the United States, and the European Union

The Stablecoin Bill of Hong Kong, China was passed by the Legislative Council of Hong Kong on May 2025, 5. It still needs to be signed by the Chief Executive and published in the Gazette.

31
June
Web3 lawyers’ in-depth analysis: How can mainland companies successfully issue RWA products in Hong Kong?

The global asset tokenization process is accelerating. According to data from the RWA.xyz platform, by April 2025, the global on-chain

31
June
Comparative Analysis of Hong Kong and US Stablecoin Bills: How Will They Affect the Global Web3 Ecosystem?

The U.S. Senate and Hong Kong Legislative Council took key steps on stablecoin regulation almost at the same time this week: the former passed the GENIUS Act with an overwhelming majority

31
June
Interpreting the Hong Kong Stablecoin Bill: The starting point for building Greater China’s Web3 infrastructure?

On May 2025, 5, the Hong Kong Legislative Council officially passed the Stablecoin Issuer Bill in its third reading, which provides the first complete regulation for stablecoins.

31
June
Hong Kong passes the Stablecoin Bill, JD CoinChain Technology interprets the "milestone moment"

On May 5, the Hong Kong Legislative Council passed the Stablecoin Bill (hereinafter referred to as the "Bill"). Based on this ordinance, Hong Kong will formally establish a legal currency stablecoin

31
June
The passage of Hong Kong's "Stablecoin Ordinance" directly cuts off the path for small and medium-sized players to issue stablecoins?

In the past two days, the team’s circle of friends has been flooded with a message: According to the Hong Kong Government News Network, on May 5, the Hong Kong Legislative Council passed the Stablecoin Bill

31
June