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Securities and Futures Commission

Hong Kong SFC Type 6 sponsor and corporate finance application pack

A practical evidence pack map for Hong Kong Type 6 advising on corporate finance applications, sponsor eligibility, sponsor principals, sponsor representatives, takeovers advisers, transaction controls, and WINGS-LIC submission readiness.

Route focus

A Type 6 application should prove whether the firm will provide ordinary corporate finance advice, sponsor or compliance adviser work, takeovers/share buy-back advice, placing or capital raising services, or a combination. Sponsor and takeovers work add competence, principal, supervision, and transaction-control evidence beyond generic corporate finance advice.

Who this helps

  • - Corporate finance advisers preparing a first SFC Type 6 licensed corporation application
  • - IPO sponsor or compliance adviser teams checking sponsor eligibility, principals, representatives, and transaction team controls
  • - Existing Type 6 corporations adding sponsor work, takeovers work, or additional responsible officers
  • - Capital markets teams separating Type 6 advice from Type 1 placing/dealing and Type 4 securities advice

Licence scope

  • - Separate ordinary corporate finance advice from sponsor work, compliance adviser work, takeovers/share buy-back work, debt/equity placing, M&A introductions, and fund or securities distribution.
  • - Check whether the firm needs Type 6 only or also Type 1 dealing, Type 4 advising, Type 9 asset management, or a condition change before launch.
  • - For sponsor work, map the Sponsor Guidelines, paragraph 17 Code of Conduct expectations, sponsor principal eligibility, transaction team supervision, and ongoing sponsor eligibility checks.
  • - For takeovers or share buy-back work, map the TC adviser competence layer and whether Paper 17 or specialist experience evidence is relevant.

Pre-draft questions

  • - Will the firm advise on Listing Rules, Takeovers Code, restructuring, public offers, sponsor work, compliance adviser work, capital raising, placing, or several of these?
  • - Will any mandate involve sponsor appointment, IPO sponsor work, compliance adviser appointment, joint sponsors, or a team structure chart submitted through WINGS?
  • - Which responsible officers, sponsor principals, sponsor representatives, licensed representatives, analysts, transaction team members, and reviewers own each mandate type?
  • - Which HKSI papers or competence evidence are needed for Type 6, sponsor principal, sponsor representative, or takeovers work?
  • - Do engagement letters, deal checklists, due diligence files, verification notes, conflicts controls, wall-crossing procedures, and marketing material match the requested SFC scope?

Evidence pack

Type 6 route and mandate map

  • - Mandate taxonomy covering listed-company advice, public offers, restructuring, sponsor work, compliance adviser work, takeovers/share buy-backs, placing/dealing touchpoints, and cross-border work.
  • - Type 6 versus Type 1/Type 4 route memo for capital raising, investor introductions, research, transaction compensation, and public-market communications.
  • - SFC source packet covering application procedures, licensing forms, licensing handbook, Guidelines on Competence, Sponsor Regime FAQ, Corporate Finance Adviser Code, Code of Conduct, and public-register checks.

Sponsor, principal, and people evidence

  • - Responsible officer and licensed representative matrix with Type 6 authority, experience, competence, local regulatory framework evidence, deal history, supervision role, and time commitment.
  • - Sponsor principal file showing eligibility route, IPO sponsor experience or alternative support, Paper 15 where relevant, appointment evidence, and supervision responsibilities.
  • - Sponsor representative and transaction team file showing Paper 16 where relevant, work allocation, review line, issue escalation, verification responsibilities, and training.

Transaction controls and due diligence

  • - Sponsor and corporate finance procedures for mandate acceptance, conflicts, independence, due diligence planning, management interviews, expert reports, verification notes, disclosure review, committee approvals, and recordkeeping.
  • - Takeovers/share buy-back controls, including TC adviser competence, Paper 17 where relevant, Code timeline ownership, conflicts, announcements, and regulatory communication workflow.
  • - Deal-file sample pack showing how the firm records material issues, principal review, transaction team supervision, escalation, and final sign-off.

People and governance

  • - A Type 6 firm still needs responsible officers with authority and competence for the requested regulated activity; sponsor work adds a separate sponsor principal and transaction-supervision layer.
  • - The Sponsor Regime FAQ says a sponsor should at all times have at least two Principals, with at least one eligible under Option 1 of the Sponsor Guidelines.
  • - Sponsor management responsibility cannot be treated as outsourced to the deal team; board, senior management, responsible officers, principals, compliance, and transaction reviewers need named ownership.
  • - If the firm also places securities or introduces investors, document whether Type 1 dealing evidence is needed alongside Type 6.

Forms and submission

  • - Use WINGS-LIC and the current SFC application procedures/forms pages for the corporation, responsible officer, licensed representative, supplement, questionnaire, and fee sequence.
  • - For a new Type 6 licensed corporation, prepare Form 1, Forms 5 and 6 where relevant, Supplements 1, 2 and 3 as appropriate, Questionnaire 1, sponsor/corporate finance business plan, board approval evidence, and people files.
  • - For an existing Type 6 firm submitting to act as sponsor, SFC's application procedures page notes that Forms 5 and 6 and Supplement 3 may be required and that the submission to act as sponsor is listed separately from adding a regulated activity.
  • - Before sponsor launch or transaction assignment, verify Type 6 status, licence conditions, responsible officers, representatives, sponsor principal records, and public register details.

Timeline risks

  • - Sponsor work can stall if the application shows ordinary corporate finance experience but not sponsor eligibility, principal evidence, transaction team controls, and due diligence supervision.
  • - A firm with Type 6 conditions restricting Listing Rules or sponsor work cannot treat ordinary Type 6 status as sponsor-ready.
  • - Weak deal-file samples, conflicts controls, expert-review process, or principal involvement evidence can create harder follow-up than the form itself.
  • - Capital raising or placing features may trigger Type 1 analysis if the firm introduces investors, arranges subscriptions, or receives transaction-linked compensation.

Questions to ask advisers

  • - Is this ordinary Type 6 advice, sponsor work, compliance adviser work, takeovers work, Type 1 placing/dealing, or a combination?
  • - Which principals and responsible officers can evidence sponsor eligibility and actual transaction supervision?
  • - Do Paper 15, Paper 16, Paper 17, local regulatory framework, and deal-experience records match each person's role?
  • - How will the firm prove due diligence planning, issue escalation, conflict control, verification, committee review, and record retention in a real deal file?

Common mistakes

  • - Assuming Type 6 approval automatically makes the firm sponsor-ready despite conditions, sponsor principal requirements, or Sponsor Guidelines gaps.
  • - Treating sponsor principal evidence as a CV instead of proving completed IPO role, supervisory authority, transaction-team oversight, and issue escalation.
  • - Ignoring Paper 15, Paper 16, or Paper 17 when sponsor or takeovers work is planned.
  • - Describing capital raising as corporate finance advice while documents show placing, distribution, or transaction-compensation activity that may need Type 1 analysis.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.