LicenseCompare

Securities and Futures Commission

Hong Kong custody/client assets licensing requirements

Safekeeping, client money, custody control, qualified custodian, safeguarding, asset segregation, and client asset operational models. This page maps the issue to Hong Kong application evidence, individual roles, corporate controls, public registers, and official sources.

Who this page is for

  • - Custodians
  • - Managers with custody risk
  • - Platforms handling client money
  • - Brokers and fund operators
  • - Asset managers serving professional investors
  • - Securities brokers and introducing brokers

Likely route questions

  • - SFC client asset, custody, Type 1, and financial resources analysis

Activity trigger map

  • - Can the firm move, instruct, deduct from, or otherwise control client assets?
  • - Are client assets held directly, by a custodian, by a fund vehicle, or through a platform?
  • - What audit, segregation, disclosure, capital, and reporting controls are needed?
  • - Which entity will hold, safeguard, control, or arrange custody of client assets?
  • - How will professional, accredited, institutional, or wholesale client status be evidenced and monitored?
  • - Which domestic permissions, representative approvals, and ongoing obligations apply before launch?

Individual requirements

  • - Licensed representatives for regulated functions
  • - At least two responsible officers for each regulated activity
  • - At least one responsible officer available at all times for each regulated activity
  • - Executive directors who supervise regulated activity generally need responsible officer approval

Corporate requirements

  • - Hong Kong corporation or registered non-Hong Kong company with a real operating model
  • - Fit and proper controllers, directors, substantial shareholders, responsible officers, and managers
  • - Paid-up share capital and liquid capital aligned to the regulated activities and financial resources rules
  • - Compliance, AML/CFT, conflicts, complaints, dealing, custody, outsourcing, and technology controls

People and key-person expectations

  • - Licensed representatives for regulated functions
  • - At least two responsible officers for each regulated activity
  • - At least one responsible officer available at all times for each regulated activity
  • - Named owners should be able to explain the activity workflow, client type, controls, and evidence pack.

Documents and evidence checklist

  • - Custody and client assets
  • - Capital and financial resources
  • - Compliance framework
  • - Outsourcing and vendors
  • - Regulatory reporting
  • - Official-source route memo
  • - Public register verification plan
  • - Questions log for qualified advisers

Capital, timeline and bottlenecks

Capital and liquid capital expectations depend on regulated activity, whether client assets are held, and other SFC financial resources requirements.

Timeline estimate: Typically 4 to 8+ months after a serious application pack is ready.

  • - Responsible officers without enough authority, availability, local experience, or activity-specific competence
  • - Business plans that do not match the regulated activities requested
  • - Weak financial resources calculations or unclear custody/client asset model
  • - Outsourcing, trading, conflicts, and AML controls drafted generically rather than around the proposed business

Common mistakes

  • - Saying the firm does not hold assets while retaining practical control over movements.
  • - Not documenting qualified custodian, CASS, client money, or safeguarding assumptions.
  • - Do not treat Type 9 as a substitute for all dealing or advisory activity without checking the actual workflow.
  • - Actively marketing into Hong Kong can matter even where services are provided from outside Hong Kong.

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.