This comprehensive analysis of credit rating agencies' (CRA) licensing requirements, license structure (both large and small), CRA Code compliance framework, and application strategies will help you efficiently obtain a Type 10 license. (SFC Type 10 license)
All licensed CRAs in Hong Kong
Minimum quick capital
SFC Approval Period
Under the Securities and Futures Ordinance (SFO), Type 10 regulated activities cover credit rating services offered to the public.
Schedule 5, Category 10 of the Securities and Futures Ordinance
To prepare a credit rating for the following purposes: (a) to publish it to the public, whether in Hong Kong or elsewhere, or as reasonably expected; or (b) to distribute it by subscription, whether in Hong Kong or elsewhere, or as reasonably expected.
In short: If your organization's credit ratings are published to the public or distributed via subscription, you will need to apply for a Type 10 license.
View SFC's official card dealing instructions
Regulated activity number
RA10 (Class 10)
Legal basis
Schedule 5 of the Securities and Futures Ordinance
Suitable
Credit rating agencies (CRA)
regulatory agency
Hong Kong Securities and Futures Commission (SFC)
俗稱
Rating Card / Number 10
Common combinations
Usually licensed independently
Exclusive Code of Conduct
CRA Code
Determine if your business needs to apply for a No. 10 license plate.
Compile and publish credit ratings for bonds/debt instruments to the public.
Compile and distribute credit rating reports via subscription
Provide publicly available credit ratings to issuers and charge fees.
Operating a credit rating website/platform in Hong Kong for the public to check rating results.
Prepare public ratings for structured finance products (such as CDOs and CMBS).
A credit rating prepared at the request of an individual, provided exclusively to the commissioning party, and not intended for public dissemination (private rating).
Collecting, organizing, disseminating, or distributing information about a business's debt or credit history (credit reporting services).
Internal credit rating activities, such as internal bank assessments of counterparty risk (internal risk control).
Sharing or analyzing consumer or business credit data, such as through consumer or business credit reporting agencies (credit data analytics).
Key features that distinguish it from other SFC license types
There are only about 7 licensed CRAs in Hong Kong, making it the type of license with the fewest licenses among all SFC licenses. The market is highly concentrated in the three major international rating agencies.
Unlike other licenses, the core obstacle of license number 10 is not the capital threshold, but the scientific nature of the rating methodology and the accumulation of market reputation.
Type 10 license holders must comply with the specific Code of Conduct for Credit Rating Agencies (CRA Code), which has been in effect since June 2011.
Pay attention to the latest regulatory developments related to Type 1 licence0.
ARC Ratings (Asia Pacific) Limited has been granted a Type 10 license by the SFC, becoming the first cross-border rating agency to be licensed outside of the transition period.
SFC announced that it will resume collecting annual license fees starting in April 2025, after a temporary exemption due to the pandemic.
SFC is focusing on the boundary between ESG ratings and traditional credit ratings, and may introduce specific regulatory guidelines for ESG ratings in the future.
What types of organizations are suitable for Type 1 licence0?
Depending on their business model and market positioning, different types of institutions have different application paths and capital requirements.
The three major CRAs operate in the Asia-Pacific region.
International credit rating agencies such as Moody's, S&P, and Fitch have established subsidiaries or branches in Hong Kong to provide credit rating services to bond issuers in the Asia-Pacific region.
Large Type 10 (Full Function)Capital requirements
Paid-up share capital of HK$500 million+ and quick funds of HK$3 million
Core Competitiveness
Global rating methodology, brand reputation, and cross-border rating capabilities
Greater China Market Focus
Small and medium-sized rating agencies that focus on the Greater China or Asia-Pacific markets provide credit ratings for local corporate bonds, municipal bonds, or SMEs.
Type 1 licence0 (does not hold client assets)Capital requirements
Quick funds HK$10
Core Competitiveness
Local market insights, SME rating expertise, flexible pricing
A New Track for Sustainable Finance
An emerging agency focused on environmental, social, and governance (ESG) ratings, providing investors with ESG risk assessments and sustainability ratings.
Depending on the scope of businessCapital requirements
Depending on whether or not client assets are held
Core Competitiveness
ESG methodology, sustainable finance expertise, and compliance foresight
⚠ Pure ESG ratings, which do not involve credit risk assessment, may not fall under Category 10 regulated activities. It is recommended to consult AIYING for confirmation.
AI-driven rating innovation
We leverage big data and AI/ML technologies to provide automated credit rating services and publish algorithm-driven rating results to institutional investors or the public.
It depends on the business model.Capital requirements
Depending on the specific business scope
Core Competitiveness
Technological innovation, data analysis capabilities, and efficiency of automated rating
⚠ If the rating results are released to the public or distributed via subscription, a No. 10 license is required.
As of March 2026, there were seven institutions in Hong Kong holding SFC Type 10 licenses, covering the three major international rating agencies, Chinese-funded rating agencies, and emerging multinational rating agencies.
Licensed corporations
Country/region of origin
The first year of license issuance
The three major international rating agencies
Moody's Investors Service Hong Kong Limited
One of the world's three largest credit rating agencies, Moody's was founded in 1909 and has offices in more than 40 countries. Moody's provides credit rating, research, and risk analysis services to global capital markets.
Global coverage of 130+ countries Rating more than 11,000 companies A century of rating historyparent company
Moody's Corporation (NYSE: MCO)
Headquarters
美國紐約
S&P Global Ratings Hong Kong Limited
S&P Global Ratings is a leading global credit rating and financial data analytics firm. Its credit risk measurement system is one of the most widely used standards in global capital markets.
The world's largest rating agency Covering 128 sovereign ratings More than 100 million credit ratingsparent company
S&P Global Inc. (NYSE: SPGI)
Headquarters
美國紐約
Fitch (Hong Kong) Limited
One of the world's three largest credit rating agencies, Fitch was founded in 1914 by John Knowles Fitch. Fitch is known for its independent, forward-looking credit perspective and global reach.
Dual Headquarters Operation Model 30+ global offices Structured finance ratings leadparent company
Fitch Group (Hearst Corporation)
Headquarters
New York, USA / London, UK
China Chengxin (Asia Pacific) Credit Ratings Company Limited
China Chengxin Group's international rating platform obtained SFC License No. 10 in 2012, becoming the first Chinese-funded rating agency to obtain a credit rating license in Hong Kong, focusing on credit rating in the Greater China region.
The first Chinese-funded CRA to obtain a license Greater China Professional Rating Cross-border rating capabilitiesparent company
China Chengxin Group
Headquarters
Beijing, China / Hong Kong
Dagong Global Credit Rating (Hong Kong) Co., Limited
Dagong Global Credit Rating Group's Hong Kong subsidiary obtained one of the first batch of licenses (Type 10) in 2011. Dagong is committed to building a new international rating system to provide independent credit risk assessments for global investors.
The first batch of licensed institutions New rating system Belt and Road Rating Expertiseparent company
Dagong Global Credit Rating Group
Headquarters
Beijing, China / Hong Kong
Lianhe Ratings Global Limited
United Credit Ratings Group's international business platform obtained one of the first batch of licenses (Type 10) in 2011. It focuses on providing credit rating services for Chinese companies seeking overseas financing and for international investors.
The first batch of licensed institutions Overseas rating of Chinese enterprises Cross-border financing servicesparent company
United Credit Rating Group
Headquarters
Beijing, China / Hong Kong
ARC Ratings (Asia Pacific) Limited
The Asia-Pacific subsidiary of ARC Ratings, an independent European rating agency, obtained SFC License No. 10 in March 2026. It is the first multinational rating agency to obtain a license outside of the transition period, marking a further internationalization of the Hong Kong rating market.
The first non-transitional license obtained ESMA Registered Rating Agency Eurasia Cross-border Ratingparent company
ARC Ratings SA (Portugal)
Headquarters
Lisbon, Portugal / Hong Kong
Moody's Investors Service Hong Kong Limited
One of the world's three largest credit rating agencies, Moody's was founded in 1909 and has offices in more than 40 countries. Moody's provides credit rating, research, and risk analysis services to global capital markets.
Global coverage of 130+ countries Rating more than 11,000 companies A century of rating historyparent company
Moody's Corporation (NYSE: MCO)
Headquarters
美國紐約
S&P Global Ratings Hong Kong Limited
S&P Global Ratings is a leading global credit rating and financial data analytics firm. Its credit risk measurement system is one of the most widely used standards in global capital markets.
The world's largest rating agency Covering 128 sovereign ratings More than 100 million credit ratingsparent company
S&P Global Inc. (NYSE: SPGI)
Headquarters
美國紐約
Fitch (Hong Kong) Limited
One of the world's three largest credit rating agencies, Fitch was founded in 1914 by John Knowles Fitch. Fitch is known for its independent, forward-looking credit perspective and global reach.
Dual Headquarters Operation Model 30+ global offices Structured finance ratings leadparent company
Fitch Group (Hearst Corporation)
Headquarters
New York, USA / London, UK
China Chengxin (Asia Pacific) Credit Ratings Company Limited
China Chengxin Group's international rating platform obtained SFC License No. 10 in 2012, becoming the first Chinese-funded rating agency to obtain a credit rating license in Hong Kong, focusing on credit rating in the Greater China region.
The first Chinese-funded CRA to obtain a license Greater China Professional Rating Cross-border rating capabilitiesparent company
China Chengxin Group
Headquarters
Beijing, China / Hong Kong
Dagong Global Credit Rating (Hong Kong) Co., Limited
Dagong Global Credit Rating Group's Hong Kong subsidiary obtained one of the first batch of licenses (Type 10) in 2011. Dagong is committed to building a new international rating system to provide independent credit risk assessments for global investors.
The first batch of licensed institutions New rating system Belt and Road Rating Expertiseparent company
Dagong Global Credit Rating Group
Headquarters
Beijing, China / Hong Kong
Lianhe Ratings Global Limited
United Credit Ratings Group's international business platform obtained one of the first batch of licenses (Type 10) in 2011. It focuses on providing credit rating services for Chinese companies seeking overseas financing and for international investors.
The first batch of licensed institutions Overseas rating of Chinese enterprises Cross-border financing servicesparent company
United Credit Rating Group
Headquarters
Beijing, China / Hong Kong
ARC Ratings (Asia Pacific) Limited
The Asia-Pacific subsidiary of ARC Ratings, an independent European rating agency, obtained SFC License No. 10 in March 2026. It is the first multinational rating agency to obtain a license outside of the transition period, marking a further internationalization of the Hong Kong rating market.
The first non-transitional license obtained ESMA Registered Rating Agency Eurasia Cross-border Ratingparent company
ARC Ratings SA (Portugal)
Headquarters
Lisbon, Portugal / Hong Kong
Source: Public Register of Licensees and Registered Institutions of the Securities and Futures Commission (SFC) of Hong Kong, as of March 2026
Card number 10 has a distinction between "high" and "low" cards. Similar to card number 9, SFC differentiates them by adding "specifying the conditions for dealing the card":
Since credit rating agencies typically do not need to hold client assets, most CRAs actually hold a "small 10 license".
Subject to specified licensing conditions rules
Suitable for most CRAs Do not hold client assetsPaid-up share capital
Not applicable (N/A)
Quick funds
HK$100,000
✓ Only rating reports and rating comments are provided.
✓ It does not involve fund custody or asset management.
✓ The vast majority of credit rating agencies fall into this category.
Not subject to specified licensing conditions
Full-featured Client assets can be heldPaid-up share capital
HK$5,000,000
Quick funds
HK$3,000,000
✓ Client assets can be held
✓ No additional restrictions on business scope
Clarification: This is the requirement for the "Big 10 License". Most CRAs apply for the "Small 10 License", which only requires HK$100,000 in quick capital and has no paid-up capital requirement. The capital threshold difference is 50 times.
Clarification: License No. 10 has its unique features. The SFC will specifically examine the scientific validity and independence of the rating methodology, a requirement not found in other license applications. Furthermore, License No. 10 holders must comply with a specific CRA Code, rather than the general Code of Conduct.
Clarification: Not necessarily. License No. 10 only applies to credit ratings that are "published to the public or distributed via subscription." Internal credit assessments, privately commissioned ratings, and credit reporting services are not regulated under Category 10 and do not require a License No. 10.
Understand the detailed process, timeline, and cost breakdown for both new applications and acquisitions.
| Licence type | Paid-up share capital | Quick funds |
|---|---|---|
| Type 1 licence0 (subject to credit rating requirements) | not applicable | HK$100,000 |
| Large 10 license plate (unrestricted) | HK$5,000,000 | HK$3,000,000 |
⚠ Most CRAs apply for a Small 10 license. If you are unsure which type to apply for, please consult AIYING.
Source: Appendix 1 of the Securities and Futures (Financial Resources) Rules
✓ At least two Responsible Persons (ROs) directly supervise the operation of Type 10.
✓ At least one RO must be in Hong Kong at all times to oversee operations (it is recommended that both ROs be in Hong Kong).
✓ At least one RO must be an executive director as defined by SFO.
✓ The same person may serve as the RO for multiple regulated activities (provided there is no conflict of interest).
✓ Overseas ROs need to submit a work visa application to the Immigration Department first.
✓ A comprehensive compliance monitoring system must be established .
✓ A conflict of interest management policy must be developed (a core requirement of the CRA Code).
✓ An internal review and verification mechanism for the rating methodology must be established .
✓ An independent compliance department or compliance officer must be established .
✓ A Chinese wall policy must be established.
✓ An appeal handling mechanism must be established .
✓ A detailed rating methodology document must be submitted .
✓ The methodology must be scientific, systematic, and consistent.
✓ The key assumptions and limitations of the rating model must be explained .
✓ A mechanism for regular review and updating of the methodology must be established.
✓ SFC will give special consideration to the independence and objectivity of its methodology.
⚠ This is the most crucial review stage in the application for Type 1 licence0. It is recommended to prepare sufficient methodological documents in advance.
✓ Must hold a law, accounting, or finance-related degree or professional qualification
✓ Or possess equivalent qualifications recognized by SFC
✓ At least 3 years of relevant industry experience in the past 6 years
✓ At least 2 years of management experience
✓ Related industries include: credit rating, credit analysis, fixed income research, risk management, etc.
✓ Another RO can pass the exam within 6 months of obtaining the license.
✓Exam Exemption: Holders of equivalent overseas qualifications recognized by SFC may apply for an exemption.
✓ At least one RO must pass: HKSI LE Paper 1 (Basic Securities and Futures Regulations) + HKSI LE Paper 4 before submitting the application.
⚠ Important Reminder: The exam requirements for Plate 10 (RO) are Paper 1 + Paper 4, which are different from Plate 1 (Paper 1 + Paper 7) and Plate 9 (Paper 1 + Paper 7).
New application cycle
SFC Approval Commitment Time
Preparation stage
✓ Determine the scope of business and license type (large/small No. 10 license plate)
✓ Prepare rating methodology documents (the most crucial preparatory work)
✓ Form a compliance team (at least 2 ROs)
✓ RO through HKSI LE Paper 1 + Paper 4
✓ Establish a compliance monitoring system and built-in architecture
✓ Develop conflict of interest management policies
✓ Prepare company registration documents (if not already registered at the port).
✓ Prepare proof of financial resources
✓ Submit online application through SFC WINGS system
✓ Pay the application fee (HK$57,740 for corporation + HK$3,770 per RO)
✓ SFC conducts initial review (confirmation of receipt within approximately 2 weeks)
✓ The SFC may request supplementary information (especially related to rating methodology).
✓ The scientific nature and independence of the SFC review and rating methodology
✓ SFC assesses RO's competence and experience
✓ SFC reviews compliance systems and internal control architecture
✓ Awaiting final approval from the SFC (promised timeframe approximately 15 weeks)
⚠ The SFC's review of Type 10 license applications focuses on the rating methodology. Insufficient methodology documentation may significantly extend the processing time.
✓ Received official approval notification from SFC
✓ Pay the annual license fee (HK$5,340/year for corporations + HK$4,740/year for each RO)
✓ Register in the SFC Public Record Book
✓ Officially commence credit rating business
✓ Establish a CRA Code compliance reporting mechanism
✓ Submit your first annual compliance report to the SFC
For example, while developing the rating methodology, company registration, RO exam preparation, and compliance system setup can be carried out in parallel. The AIYING team will assist you in developing the optimal parallel progress plan to minimize the overall timeline.
Approximately 21-27 weeks (5-7 months)
Group price HK$57,740 + RO per person HK$3,770
Corporation HK$5,340/year + HK$4,740/year per RO
Approximately 15 weeks (corporation license application)
Source: SFC Performance Pledges | Annual license fee to resume from April 2025
Transparently presenting all official fees, capital requirements, and ongoing operating costs helps you with your financial planning.
| Expense items | Amount (HK$) | Explain |
|---|---|---|
| Corporate license application fee | HK$57,740 | One-time, each type of regulated activity |
| RO (Responsible Person) Approval Fee | HK$3,770 | Every RO, every type of regulated activity |
| Licensed Representative (LR) Approval Fee | HK$1,790 | Each LR, each type of regulated activity |
License application fee
HK$57,740 x 1 = HK$57,740
RO Approval Fee
HK$3,770 x 2 = HK$7,540
First year license fee (corporation)
HK$5,340 x 1 = HK$5,340
First year license fee (RO)
HK$4,740 x 2 = HK$9,480
Total official SFC fees in the first year
HK$80,100
* The above fees are only those charged by SFC and do not include consulting fees, office rent, IT system and other operating costs.
| Contrast Dimensions | Small No. 10 | Big 10 license plate |
|---|---|---|
| Paid-up share capital | No requirement | ≥ HK$5,000,000 |
| Quick funds | ≥ HK$100,000 | ≥ HK$3,000,000 |
| Holding client assets | Improper | can |
| Applicable scenarios | Most CRAs | Very few require holding client assets. |
| Market commonality | common | rare |
The vast majority of CRAs hold Small 10 licenses. Only HK$10 in liquid funds are required, with no paid-up capital requirement. The SFC restricts its ability to hold client assets through additional "specified licensing conditions."
A minimum paid-up share capital of HK$500 million plus HK$3 million in liquid funds is required. This applies to very rare situations where holding client assets is necessary, and is extremely uncommon in practice.
| Expense items | Amount of money | Explain |
|---|---|---|
| Annual license fee (corporation) | HK$5,340 / year | Each type of regulated activity |
| Annual License Fee (RO) | HK$4,740 / year | Every RO, every type of regulated activity |
| Annual License Fee (LR) | HK$1,790 / year | Each LR, each type of regulated activity |
| Compliance monitoring costs | Depending on the scale | Compliance system maintenance, auditing, training, etc. |
| Annual audit fee | Depending on the scale | Audited annual financial statements |
Under section 138(2) of the Securities and Futures Ordinance, all intermediaries and licensees are required to pay an annual license fee within one month of the expiry date of their license or certificate of incorporation each year. Failure to pay on time will result in the following consequences:
| Overdue time | as a result of |
|---|---|
| More than 1 months but less than 2 months | A 30% surcharge will be levied. |
| More than 2 months but less than 3 months | A 50% surcharge will be levied. |
| More than 3 months but less than 4 months | Temporary suspension of license/registration |
| More than 4 months | Cancellation of license/registration |
Source: SFC Official FAQ (Updated March 14, 2025)
The CRA Code (Code of Conduct for Credit Rating Agencies) is a code of conduct developed by the SFC specifically for licensed agencies holding a Type 10 license. It has been in effect since June 2011 and has not been revised to date.
The rating methodology must be reviewed and updated regularly, and any changes to the methodology must be promptly communicated to the SFC and the market.
An annual compliance report must be submitted to the SFC, detailing compliance with the CRA Code.
Must continuously meet the minimum quick capital requirements (HK$100,000 for Small 10 license plates / HK$3,000,000 for Large 10 license plates), and must submit a financial resources declaration form to the SFC monthly/quarterly.
The effectiveness of the conflict of interest management policy must be reviewed annually, and all identified conflicts of interest must be recorded and reported.
ROs and analysts must receive ongoing professional training and ensure that their teams understand the latest regulatory requirements.
Business changes, RO changes, compliance violations, etc., must be notified to the SFC within the specified time.
To date, the SFC has taken relatively few enforcement actions against the CRA, but with the development of the ESG rating and credit rating markets, regulatory efforts are expected to gradually increase.
Unlike licenses number 1 and 9, the market for acquiring licenses number 10 is extremely scarce. There are only about 7-8 licensed CRAs in Hong Kong, and most of them are Hong Kong subsidiaries of international rating agencies, so they almost never sell their licenses. For the vast majority of applicants, applying for a new license is the only realistic way to obtain one.
There are only about 7-8 licensed CRAs in Hong Kong, making it the type with the fewest licenses among all SFC licenses. Therefore, the number of targets available for acquisition is extremely limited.
International CRAs such as Moody's, S&P, and Fitch dominate the market, and these agencies will not sell their Hong Kong licenses.
The core value of Type 1 licence0 lies in its rating methodology and market reputation. Simply acquiring a shell company with a license plate has limited significance because the methodology and the team are inseparable.
Even if a target for acquisition is found, the SFC will still conduct a comprehensive review of the new shareholders and management. The review standards are basically the same as for new applications and cannot significantly shorten the time to obtain a license.
✓ Review and optimization suggestions for rating methodology
✓ SFC application material preparation and submission
✓ RO Candidate Qualification Assessment and Recommendation
✓ SFC communication and coordination during the approval process
✓ Compliance system design and construction
✓ Professional consultant service throughout the process
The following are the most frequently asked questions about Hong Kong Type 10 license plates. For any further inquiries, please contact AIYING for professional answers.
是的。 SFC以附加指明發牌條件來區分：小10號牌（不持有客戶資產）僅需速動資金HK$10萬；大10號牌需繳足股本HK$500萬+速動資金HK$300萬。大多數CRA持有的是小10號牌。
小10號牌僅需速動資金HK$100,000，無繳足股本要求。大10號牌需繳足股本HK$5,000,000+速動資金HK$3,000,000。
10號牌RO須通過HKSI LE試卷1和試卷4。注意：這與1號牌和9號牌的考試要求（試卷1+試卷7）不同。
Not necessarily. If the ESG rating only assesses a company's environmental, social, and governance performance and does not involve credit risk assessment, it may not fall under Category 10 regulated activities. However, if the ESG rating is combined with a credit rating, a Category 10 license may be required. It is recommended to consult AIYING for confirmation.
Theoretically possible, but practically impossible. There are only about 7-8 licensed CRAs in Hong Kong, most of which are Hong Kong subsidiaries of international rating agencies and do not sell licenses. Applying for a brand new license is the only realistic option.
Yes, a company can hold multiple licenses simultaneously. For example, a financial group can hold both a Type 1 license (securities trading) and a Type 10 license (credit rating), but it needs to establish effective information firewalls.
The CRA Code (Code of Conduct for Credit Rating Agencies) is a code of conduct specifically developed by the SFC for Type 10 license holders and has been in effect since June 2011. Unlike the general Code of Conduct applicable to other licenses, it specifically addresses the unique risks and requirements of the credit rating business.
The entire process, from preparation to license issuance, takes approximately 5-7 months. The preparation phase lasts about 4-8 weeks, SFC approval about 15 weeks, and the license issuance process takes about 2-4 weeks. The review time may be extended if the rating methodology is not adequately prepared.
Annual license fee: HK$5,340 per corporation/year + HK$4,740 per RO/year. Additional ongoing operating costs, such as compliance system maintenance, auditing, and training, must also be considered.
No. If the rating results are to be published to the Hong Kong public or distributed via subscription, the overseas CRA must establish a subsidiary or branch in Hong Kong and apply for a Type 10 license. Ratings published solely overseas are not subject to the SFC's jurisdiction.
Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring 24/7 professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.
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This mechanism allows us to ensure that the materials submitted to regulators are highly professional, complete, and impeccable, thereby minimizing regulatory inquiry rounds, significantly shortening approval times, and reducing the license rejection rate by 67%.