LicenseCompare

Securities and Futures Commission

Hong Kong family office licensing requirements

Single-family, multi-family, investment office, trust, adviser, and externally marketed family office arrangements. This page maps the issue to Hong Kong application evidence, individual roles, corporate controls, public registers, and official sources.

Who this page is for

  • - Family offices
  • - Family investment companies
  • - Trust and corporate service groups
  • - Private wealth teams
  • - Asset managers serving professional investors
  • - Securities brokers and introducing brokers

Likely route questions

  • - SFC Type 9 or exemption analysis depending on family office facts

Activity trigger map

  • - Whose assets are managed and who controls the office?
  • - Are services provided only to family entities or to external clients?
  • - Does the office market funds, give advice, charge fees, or accept outside capital?
  • - Which entity will manage family office 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

  • - Ownership and controllers
  • - People and competence
  • - Governance and accountability
  • - Compliance framework
  • - AML/CFT and financial crime
  • - 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

  • - Assuming the phrase family office removes all licence questions.
  • - Ignoring outside capital, marketing, compensation, and advisory activity.
  • - 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.