Family-owned legal association
As of December 2025
SFC Approval Period
Performance Pledge
Minimum quick capital (small 9)
Extremely low capital threshold
Type 9 licenses (Asset Management) are regulated activity licenses issued by the Hong Kong Securities and Futures Commission (SFC) under the Securities and Futures Ordinance (SFO). Licensed institutions are authorized to manage portfolios of securities or futures contracts for clients on a discretionary basis.
December 2025: The SFC and FSTB published the consultation conclusion on the AMLO revisions, confirming the establishment of a new VA management license under the AMLO. Existing VA license holders with Type 9 licenses may need to transition to the new system in the future.
Licensees have the right to make investment decisions on behalf of their clients and to manage their portfolios of securities or futures contracts on a discretionary basis.
Type 9 licence distinguishes between large and small licenses through the "License Issuance Conditions" attached by the SFC, with different types corresponding to different capital requirements and business scopes.
Licensed institutions can apply for a Type 9 Uplift (VA) to be authorized to manage virtual asset funds, which is currently a necessary license for managing VA funds.
Type 9 licence is often applied for in combination with Type 4 licence (for providing securities advice), forming a "4+9" configuration that covers investment advice and discretionary management.
First, see which scenario is relevant to you → See the "Typical Customer Scenarios" section below.
Choose the business scenario that best suits you to quickly understand the recommended licensing path and capital requirements.
Small 9 card (or 4+9 small cards)
Quick funds starting from HK$10
It does not require holding client assets and has a low capital threshold, making it suitable for providing personalized discretionary asset management services to high-net-worth clients.
We provide discretionary asset management for high-net-worth clients, allocating securities investment portfolios based on their risk preferences.
Small No. 9
Quick funds starting from HK$10
Private equity funds typically do not involve CIS public offerings and do not need to hold client assets; a small No. Type 9 licence is sufficient to meet their business needs.
We manage PE/VC funds and hedge funds, providing discretionary fund management services to professional investors.
Big Type 9 licence
Paid-up share capital of HK$500 million+ and quick funds of HK$3 million
It is required to manage collective investment schemes (CIS) and issue and manage public fund products for retail investors.
Issuing and managing retail fund products, and providing collective investment plan management services to public investors.
Type 9 + VA Upgrade
Same basic license + VA additional requirements
When the VA (virtual assets) accounts for ≥10% of the GAV (gross asset value), an upgrade application is required, and additional requirements such as VA project risk control, management, and valuation must be met.
Manage cryptocurrency funds and tokenized funds to provide investors with virtual asset investment management services.
⚠ Pay attention to the progress of the AMLO revision; in the future, it may be necessary to transition to an independent VA management license.
Unsure which path is best for you?
For a more in-depth understanding of the specific differences and business scope of Big and Small Cards, please refer to the "Big and Small Card Structure" section below.
Type 9 licence distinguishes between large and small licenses through the "license conditions" attached by the SFC, with different types corresponding to different capital requirements and business scopes.
Key takeaway: Type 9 licence differentiates between small and large licenses through the "License Conditions" attached by the SFC. Smaller licenses are subject to restrictions such as "not holding customer assets" and "not managing CIS," while larger licenses do not have these restrictions. The different conditions also affect capital requirements and business scope.
Not subject to specified licensing conditions
✓ Client assets can be held
✓ Manageable Group Investment Scheme (CIS)
✓ Available to retail investors
✓ Can issue/manage public funds
Paid-up share capital
HK$5,000,000
Quick funds
HK$3,000,000
Applicable scenarios: Public fund managers and institutions that need to hold client assets.
Subject to specified licensing conditions rules
X No holding customer assets
X They are prohibited from managing collective investment schemes (CIS).
X Typically limited to professional investors
X Limited to private equity funds/discretionary management
Paid-up share capital
No requirement
Quick funds
HK$100,000
Applicable scenarios: EAM, family office, private fund manager
When issuing a license, the SFC may attach specific conditions to the license. These conditions restrict the scope of business that the licensee can conduct. Common additional conditions include:
Licensed institutions must apply to the SFC to remove additional conditions, and must meet higher capital requirements (HK$5,000,000 paid-up share capital + HK$3,000,000 in quick funds) and stricter compliance standards, including arrangements for the custody of client assets and a more robust risk management framework.
Yes, the additional conditions will be clearly stated in the licensing documents issued by the SFC and can be found in the SFC's public register. Anyone can view the specific licensing conditions of a licensed corporation through the SFC's public registration records.
Misconception X : "Type Type 9 licence can only be used for private equity funds"
✓ Fact: A Big 9 license allows you to manage mutual funds (CIS), which issue and manage fund products for retail investors.
Misconception X : "Type 9 licence cannot be used for asset management"
✓ Fact: Type 9 licence can be used for discretionary asset management, but cannot hold client assets or manage CIS.
Misconception X : "Type 9 and Type 4 have the same function"
✓ Fact: Type 9 licence represents discretionary management (making investment decisions on behalf of clients), while Type 4 licence represents providing securities advice (advice but not decisions).
For information on VA upgrade paths and common license combinations, please refer to the "Licensing Paths" section below.
Choose the most suitable license combination based on business needs to understand the triggering conditions and additional requirements for VA upgrades.
Institutions that only need to entrust full asset management and do not need to provide investment advice services.
Quick capital of HK$100,000 (small 9), no paid-up capital requirement.
Paid-up capital HK$5,000,000 + quick capital HK$3,000,000 (Big 9)
✓ The application process is relatively simple
✓ Only 2 ROs are needed
✓ Only Paper 1 + Paper 6 are required for the exam.
X cannot provide investment advice services .
X has a narrow business scope
Asset managers typically need to provide both investment advice and discretionary management services, and the 4+9 combination is the most common in the market.
Quick capital of HK$100,000 (small license), no paid-up capital requirement
Paid-up capital HK$5,000,000 + quick capital HK$3,000,000 (for major projects)
✓ Coverage of investment advice + full discretionary management
✓Most common configuration in the market
✓ More comprehensive customer service
X RO requires at least 4 people (at least 1 person for each type of RA).
The X exam requires passing an additional test paper 7.
Institutions that need to execute securities transactions and manage assets themselves, such as proprietary trading + asset management.
Paid-up share capital HK$5,000,000 + quick funds HK$3,000,000
Same as above (Type 1 licence itself has higher capital requirements)
✓ Can execute transactions independently
✓ Reduce reliance on external brokerage firms
X Capital has high requirements.
X compliance requirements are more complex.
The X exam requires passing an additional test paper 8.
Institutions that provide comprehensive financial services, covering securities trading, investment consulting, and asset management.
Paid-up share capital HK$5,000,000 + quick funds HK$3,000,000
Ibid.
✓Strongest comprehensive service capabilities
✓One -stop financial services
✓ Strong market competitiveness
X Capital has the highest requirements.
X's compliance system is the most complex.
X RO and staffing requirements are high.
Type 9 license is currently the necessary license for managing virtual asset funds (through the VA Uplift mechanism). When a fund's VA ratio is ≥10% of GAV or VA investment is a clear objective of the fund, an application for VA upgrade must be submitted to the SFC.
⚠ Future Regulatory Changes: In December 2025, the SFC confirmed that a new VA management license will be established under the AMLO. Existing Type 9 VA license holders may need to transition to the new system. It is recommended to closely monitor policy developments.
| path | Paid-up share capital | Quick funds | RO requirements | examination | Applicable scenarios |
|---|---|---|---|---|---|
| Small 9 (independent) | No requirement | HK$100,000 | ≥2 people | P1 + P6 | EAM / Home Office / Private Equity |
| Big 9 (Independent) | HK$3,000,000 | HK$3,000,000 | ≥2 people | P1 + P6 | Public Fund Management |
| 4 + 9 (small) | No requirement | HK$100,000 | ≥4 people | P1 + P6 + P7 | Consulting + Management |
| 4 + 9 (large) | HK$3,000,000 | HK$3,000,000 | ≥4 people | P1 + P6 + P7 | Comprehensive asset management services |
| 1 + 9 | HK$3,000,000 | HK$3,000,000 | ≥4 people | P1 + P6 + P8 | Trading + Management |
| VA upgrade | Same as above + Additional requirements | Ibid. | +VA experience | +VA Training | Virtual asset funds |
For detailed application requirements for each pathway, please refer to the "Application Requirements" section below.
A comprehensive analysis of the capital requirements, staffing, compliance structure, and examination requirements for a Type 9 license.
| Item | Small No. 9 | Big Type 9 licence |
|---|---|---|
| Paid-up share capital | No requirement | HK$5,000,000 |
| Quick funds | HK$100,000 | HK$3,000,000 |
| Legal source | SFC Financial Resources Rules, cap571N | SFC Financial Resources Rules, cap571N |
Note: Quick funds must be maintained continuously, and are not a one-time requirement at the time of application.
| examination | content | Applicable licenses |
|---|---|---|
| Paper 1 | Basic Securities and Futures Regulations | All licenses require an exam |
| Paper 6 | Asset Management Regulations | Type 9 is a must-test |
| Paper 7 | Financial market | Type 4 licence is a must-test (required for combinations of 4 and 9). |
| Paper 8 | Securities Regulations | Type 1 licence is a must-test (required for combinations of 1 and 9). |
The exam is administered by HKSI (Hong Kong Securities and Investment Institute), and exemptions may be applied for (subject to relevant qualifications or experience).
Understand the application requirements? Next, let's compare the two licensing methods: "New Application vs. Acquisition".
Both methods of obtaining a license have their advantages and disadvantages, and the choice depends on your time, budget, and risk tolerance.
| Contrast Dimensions | New application | Acquisition of existing licensed companies |
|---|---|---|
| time period | 5–7 months | 3–6 months |
| Cost structure | Application fee + consultant fee + personnel costs | Acquisition price + advisory fees + due diligence costs |
| SFC Approval | New approval process (approximately 15 weeks) | Equity Change Approval |
| Compliance System | Build from scratch | Inherit the existing system (subject to evaluation) |
| Historical risks | No historical baggage | Due diligence on historical compliance records is required. |
| Staffing | You need to recruit your own RO/LR. | Possibly inheriting the existing team |
| flexibility | Fully Custom Architecture | Limited by the existing architecture |
| Certainty | There is a risk of rejection. | Already licensed, high certainty |
✓ No historical compliance risks
✓ Fully customizable company structure
✓Building a brand and culture from scratch
The approval process for X is relatively long (5-7 months).
X needs to build a compliance system from scratch.
X carries a risk of rejection.
✓ Faster turnaround time (3-6 months)
✓ Already has a license, high certainty
✓ Can inherit existing teams and systems
X needs to bear historical compliance risks .
The acquisition price for X may be high.
X is limited by the existing architecture.
| Licence type | reference price | Explain |
|---|---|---|
| Pure No. 9 (small plate) | HK$1.5 million – HK$200 million | Clean compliance record |
| Cards 4+9 (small cards) | HK$200 million – HK$230 million | Clean compliance record |
| Type 4+9 licences (including NAV) | HK$210 million – HK$250 million | Including customer net assets |
⚠ The prices above are for market reference only. Actual prices depend on factors such as licensing requirements, compliance records, and customer resources. We recommend obtaining the latest market quotes through AIYING.
Sign a service agreement
Target screening
Letter of Intent
due diligence
Equity Transfer Agreement
SFC approval (3-6 months)
Delivery
If you have ample time (6 months or more), wish to completely customize the company structure, or have concerns about the historical compliance status of the target company.
If you need to obtain a license quickly (3-6 months), have a clear business start-up timeline, and are capable of conducting comprehensive due diligence.
It is recommended to hire a professional consultant to assist in ensuring that the process is compliant, the materials are complete, and the risks are controllable.
Key Points of Acquisition Due Diligence
For a detailed overview of the application process and timeline, please refer to the "Application Process" section below.
Understand the detailed process, timeline, and cost breakdown for both new applications and acquisitions.
Estimated total time: Approximately 5-7 months (SFC corporation license application processing time is approximately 15 weeks, source: SFC Performance Pledge)
Estimated total time: Approximately 3-6 months (depending on the complexity of due diligence and the progress of SFC approval).
| Expense items | Amount of money | Remark |
|---|---|---|
| Corporate license application fee | HK$4,740 per RA category | One time |
| RO application fee | HK$2,950 per person | One time |
| LR application fee | HK$1,790 per person | One time |
| Corporate Annual License Fee | HK$5,340 per RA category | Resuming annually (starting in April 2025) |
| RO Annual Fee | HK$4,740 per RA category | Per year |
| LR annual fee | HK$1,790 per RA category | Per year |
Source: SFC official fee schedule. The above fees do not include consulting fees, legal fees, or other third-party service fees.
⚠ Important Notice: Starting in April 2025, the SFC will resume collecting annual license fees (previously waived for several years due to COVID-19). Licensed entities must pay by the designated date each year; late payment may affect the license status.
For ongoing compliance obligations after obtaining a license, please refer to the "Ongoing Compliance Obligations" section below.
Obtaining a license is just the beginning; continuous compliance is key to long-term operation. Understand daily compliance requirements and reporting obligations.
Continuously monitor customer transactions, identify suspicious activities, and regularly update CDD information.
Regularly assess whether clients' investment portfolios align with their risk tolerance and investment objectives.
Continuously identify and manage potential conflicts of interest to ensure that customer interests are prioritized.
All transaction records, customer documents, and compliance documents must be kept for at least 7 years.
Provide regular compliance training for employees to ensure they understand the latest regulatory requirements.
The requirement for quick capital must be maintained and must not fall below the minimum threshold.
| Report Types | frequency | Explain |
|---|---|---|
| financial statements | Per year | Audited annual financial statements must be submitted within four months of the end of the fiscal year. |
| Application for fiscal resources | per month | Monthly FRR filings demonstrate continued compliance with quick funds requirements. |
| Large position report | As needed | You must promptly report when your holdings reach the specified threshold. |
| Important Event Notice | Immediately | In the event of a major incident (such as compliance violations, personnel changes, etc.), the SFC must be notified within the specified time. |
| AML/CFT Report | As needed | Suspicious Transaction Reports (STRs) must be submitted to JFIU. |
| Annual compliance review | Per year | Internal compliance review report, assessing the effectiveness of the compliance system. |
Serious violations may constitute criminal offenses, including:
⚠ OTC Derivatives Compliance: From September 2025, Type 9 corporations involved in OTC derivatives must comply with the ISO 20022 transaction notification system. In October 2025, the SFC further expanded the Type 9 OTC derivatives regulatory framework. Relevant entities must ensure their reporting systems are compliant.
⚠ AIYING recommends: Establish a comprehensive compliance calendar and automated reminder system to ensure all reports and declarations are completed on time. Conduct regular internal compliance reviews to promptly identify and correct potential issues.
Still have questions? Check out the "Frequently Asked Questions" section below.
This compilation addresses frequently asked questions about Hong Kong's Type 9 license, based on official SFC documents and practical experience.
The Type 9 license is differentiated into small and large licenses through the "license conditions" added by the SFC. The conditions for a small Type 9 license include restrictions such as "not being allowed to hold customer assets" and "not being allowed to manage collective investment schemes (CIS)," with a very low capital threshold (only HK$10 in quick capital, no paid-up capital requirement). A large Type 9 license has no such restrictions; it allows holding customer assets and managing mutual funds, but requires HK$500 million in paid-up capital and HK$3 million in quick capital.
The Small 9 license allows for discretionary asset management services, including providing discretionary investment management for high-net-worth clients and family offices, and managing private equity funds (PE/VC funds, hedge funds), etc. However, it does not allow holding client assets or managing collective investment schemes (CIS), and is generally limited to providing services to professional investors. The Small 9 license represents the lowest-cost path to entering the asset management industry.
Type 9 licenses grant full discretionary management rights (making investment decisions on behalf of clients), while Type 4 licenses provide securities advice (offering suggestions but not making decisions). Type 9 license holders have the right to make and execute investment decisions on behalf of clients, while Type 4 license holders can only provide investment advice to clients; the final decision-making power rests with the client.
In practice, asset managers typically need to provide both investment advice and discretionary management services. A Type 4 license (securities advisory) allows you to recommend investment strategies to clients, while a Type 9 license (asset management) allows you to execute investment decisions on behalf of clients. This combination covers the entire asset management business chain and is the most common license configuration in the market.
Restricted Type 9: no paid-up share capital requirement; liquid capital must be at least HK$100,000. Full Type 9: paid-up share capital of at least HK$5,000,000 and liquid capital of at least HK$3,000,000. Source: SFC Financial Resources Rules (Cap. 571N).
A new application usually takes about 5 to 7 months. This includes 4 to 8 weeks for preparation, 2 to 4 weeks for documents, and around 15 weeks for SFC review under its performance pledge. Acquiring an existing licensed corporation may take about 3 to 6 months. The actual timeline depends on document completeness, SFC review progress, and response speed for follow-up information.
A Type 9 RO must pass HKSI LE Paper 1 and Paper 6 (Asset Management) or Paper 12. The RO should also generally have at least three years of asset management experience in the past six years and at least two years of management experience. Source: SFC Guidelines on Competence.
Licensed institutions must apply to the SFC to remove additional conditions, which require meeting higher capital requirements (HK$5,000,000 paid-up share capital + HK$3,000,000 in liquid funds) and stricter compliance standards, including arrangements for the custody of client assets and a more robust risk management framework. The upgrade process requires SFC approval.
When a fund's virtual assets (VA) comprise ≥10% of its GAV (Total Asset Value), or when VA investment is a clearly defined investment objective of the fund, it must apply to the SFC for a Type 9 VA license upgrade. After the upgrade, it must comply with the VA Fund Manager Terms and Conditions. In December 2025, the SFC confirmed that it will establish a new VA management license under AMLO, and existing VA upgrade license holders may need to transition to the new system in the future.
Acquisitions require thorough due diligence, with a focus on: historical compliance records (any SFC disciplinary actions or warnings), the retention intentions and qualifications of existing ROs/LRs, customer contracts and AUM, outstanding legal disputes or regulatory investigations, and the status of IT systems and compliance infrastructure. The SFC rigorously reviews license transfers, and new shareholders must submit a business plan. It is recommended to retain the original RO for at least 6 months to 1 year for the transition period.
From 1 April 2025, the SFC resumed charging annual licence fees after several COVID-19-related waiver years. Annual fees are HK$5,340 per RA for corporations, HK$4,740 per RA for ROs, and HK$1,790 per RA for licensed representatives.
On December 24, 2025, the SFC and FSTB published the consultation summary of the AMLO revisions, confirming the establishment of three new VA project licenses under the AMLO (VA Trading, VA Advice, and VA Management). Existing Type 9 VA upgrade holders may need to transition to an independent VA management license regime in the future. Specific transition arrangements and timelines are still pending further announcements from the SFC; it is recommended to closely monitor policy developments and prepare for the transition in advance.
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.
Based on SFC official guidelines and Aiying's practical experience, we provide the most authoritative application guidance.
Detailed self-checklist and document preparation guide to ensure the completeness and accuracy of application materials
100+ successful case experience summary, avoid common pitfalls and improve success rate
Integrate international best practices to ensure the forward-looking and adaptable compliance system
To maximize your success rate, Aiying conducts an internal mock review of your application materials before formal submission. Our expert team acts as a regulator, scrutinizing each document from the most rigorous perspective to identify logical loopholes, data inconsistencies, and compliance gaps in advance.
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%.