“Take Papers 1, 7 and 8 for securities” is shorthand for a common route, not a formula for every applicant. The SFC competence framework also considers the regulated activity, representative or Responsible Officer role, academic and industry background, and any applicable exemption.
Locate yourself with three layers
- Activity: which regulated activity the firm and individual will actually conduct.
- Role: licensed representative or Responsible Officer supervising the business.
- Competence: local regulatory framework, industry qualification, management experience and ongoing training.
How to read a common representative route
Paper 1 commonly addresses the local regulatory framework. Paper 7 supplies financial-markets knowledge and is paired, by business area, with Paper 8 (Securities), 9 (Derivatives), 10 (Credit Rating Services), 11 (Corporate Finance) or 12 (Asset Management). Responsible Officers usually need an additional regulatory paper for the activity.
This is a way to read the map, not personal licensing advice. Applicants for the same RA may face different requirements because of recognised qualifications, experience or exemptions. Check the current SFC Guidelines on Competence and your firm’s compliance advice.
Why “twelve types” is now incomplete
Schedule 5 to the SFO lists Types 1 to 13. Type 13—providing depositary services for a relevant collective investment scheme—took effect on 2 October 2024. Types 11 and 12 remain subject to commencement of their corresponding new regimes. “Listed in the Schedule” and “currently commenced” are therefore different questions.
Virtual assets require two classifications
First ask whether the token is a security or futures contract under the SFO. Then ask whether a centralised virtual-asset trading platform falls under the AMLO VASP licensing regime. A non-security token does not, by itself, mean that the platform is outside SFC regulation.
Pre-enrolment checklist
- Confirm the RA and application role, not just the job title.
- Check the current examination map and exemptions.
- Confirm the HKSI Study Guide version and effective date.
- Treat passing an exam, submitting an application and receiving a licence as three separate states.
Official sources used
Use these primary sources to confirm any change after the article date.
