CFA® Program and FRM® Exam in Hong Kong: SFC licensing

Passing the CFA® Program exams or the FRM® Exam is not a licence in Hong Kong: the SFC licenses people for regulated activities through the firm that employs them. Under its competence rules of October 2024, a finance-related degree or a qualification such as the CFA® designation covers the academic part; you still pass a regulatory paper on Hong Kong law. The FRM certification is not on the SFC’s lists. (SFC, Guidelines on Competence)

If you work in Hong Kong’s securities industry, or want to, the licence question comes before any other. This page explains what the Securities and Futures Commission (SFC) asks of individuals, where the CFA Program and the FRM Exam fit into it, and what the exams cost in Hong Kong dollars. The rules quoted are the SFC’s Guidelines on Competence of October 2024.

How does SFC licensing work?

The SFC licenses individuals to carry on regulated activities – for example Type 1 (dealing in securities), Type 4 (advising on securities), Type 6 (advising on corporate finance) and Type 9 (asset management). Individuals hold a licence as representatives; responsible officers supervise the activity, and a firm needs at least two of them for each activity it carries on. (SFC, types of intermediary and licensed individual) You apply together with the firm that will employ you, which the SFC calls the sponsoring corporation, and any exemption you are granted belongs to that role at that firm. (SFC, Guidelines on Competence)

The SFC wants you to show the right qualifications, knowledge of your products and of Hong Kong’s rules, enough experience and the ethical standards of the industry. In practice each route combines up to four things: an academic or professional qualification, an industry qualification for the products you deal in or advise on, a local regulatory framework paper on Hong Kong law – both usually papers of the Licensing Examination administered by the Hong Kong Securities and Investment Institute (HKSI) – and experience. Which of them you need depends on your background. (SFC, Guidelines on Competence)

What do you need as a representative?

• The regulatory paper: Paper 1 of the HKSI Licensing Examination for Securities and Futures Intermediaries, for every regulated activity except Types 3 and 7 (check the official website).
• Industry qualifications in Hong Kong: Papers 7 and 8 of the HKSI Licensing Examination for Types 1, 4 and 8; Papers 7 and 12 for Type 9 (asset management) (check the official website).
• Extra training hours, where a route allows them instead of an industry qualification: five CPT hours for each regulated activity applied for, a one-off requirement taken within six months before the application (check the official website).
• How recent: the industry qualification and the regulatory paper should be obtained no more than three years before the application, unless you have stayed in the industry or held a licence recently (check the official website).

This table simplifies the SFC’s own; a law firm’s summary written when these routes started in 2022 sets them out the same way. (Charltons, SFC competency standards from 2022 (secondary source)) Check the guidelines before you rely on a route.

Where does the CFA® Program fit?

The CFA® designation is one of the three examples the SFC gives of a professional qualification in finance, so it puts you on the main route even without a finance-related degree. If you already have such a degree, the charter adds nothing to the licence route; it is career development. (SFC, Guidelines on Competence)

A pass in Level I appears in an older list that still counts. Appendix C of the 2011 guidelines has this entry: “Chartered Financial Analyst Exam Level 1 Passed”, listed under the United States for representatives in Types 1, 2, 4, 5, 6, 8 and 9 (check the official website). The current guidelines say the SFC accepts the industry qualifications in that appendix. (SFC, Appendix C to the Guidelines on Competence (2011)) (SFC, Guidelines on Competence) For someone with a degree outside the finance-related fields, a recent Level I pass may therefore do the job of HKSI Papers 7 and 8 – but the appendix is old, its text does not show which entries also apply to responsible officers, and the three-year rule applies. Ask your firm’s licensing team to confirm before you skip a paper.

And the FRM® certification?

Neither the 2024 guidelines nor the 2011 appendix names it. The SFC may accept a qualification from elsewhere if the awarding body’s documents show it is equivalent to the HKSI paper concerned, so it is not ruled out – it is simply not listed. Risk experience can count in its own right: for credit rating services the SFC names credit risk management at financial institutions as relevant experience, while risk management of funds counts only as indirect experience for asset management, usually with a condition on the licence. (SFC, Guidelines on Competence)

Not every risk job is a regulated activity. If yours is not, SFC licensing may not apply to you; ask your employer.

What does a responsible officer need?

On the main route: at least three years of relevant industry experience in the past six years, two years of management experience and a pass in the local regulatory framework papers – Papers 1 and 2 for Types 1, 4 and 8 (check the official website). The same degrees and professional qualifications as for representatives count, the CFA designation among them. (SFC, Guidelines on Competence) If you aim to supervise a team one day, the years of experience take longest, so start counting them now.

What happens once you hold a licence?

You keep training: at least 10 hours for representatives and 12 for responsible officers, at least five of them on topics directly relevant to their regulated activities (check the official website). Courses, workshops and self-study with an independent assessment can count; normal work and general reading do not. (SFC, Guidelines on Continuous Professional Training) The guidelines do not name the CFA Program or the FRM Exam, so ask your firm whether and how your study counts, and keep your own records: the guidelines expect you to keep evidence such as exam results for at least three years.

What do the exams cost in Hong Kong dollars?

CFA Institute and GARP charge in US dollars. At the ECB reference rates of 29 October 2026 a US dollar was worth HKD 7.8464. (ECB, euro reference rates of 29 October 2026)

HKSI charges its own fee for each licensing paper. For later levels, retakes and prep, use the Level I cost calculator or the FRM® Exam cost calculator, which both offer the Hong Kong dollar.

What does this mean for you?

• Graduate with a finance, economics, accounting, business or law degree joining a broker or asset manager. Plan for the regulatory paper (HKSI Paper 1). Level I can be a next step for your career, not a condition of the licence.
• Career changer with another degree. You need an industry qualification, two years’ experience or extra training hours as well as Paper 1. A Level I pass from the last three years may count as the industry qualification – confirm it with the firm first; otherwise plan for HKSI Papers 7 and 8 (Types 1 and 4) or 7 and 12 (Type 9).
• Risk professional working towards the FRM certification. Check whether your role is a regulated activity at all. If it is, the FRM Exam does not replace an HKSI paper unless the SFC accepts documents showing equivalence.
• Aiming to become a responsible officer. Count your years of relevant and management experience now, and keep evidence of them; plan the regulatory papers (1 and 2 for Types 1, 4 and 8; 1 and 6 for Type 9) close to the application.

For the long view of the charter route, see the path from Level I to the charter; for the risk side, the FRM certification path.

What are the common mistakes?

• Treating a CFA Program pass as a licence. The SFC licenses a person for an activity at a firm, not an exam result.
• Sitting HKSI papers too early: they should normally be no more than three years old when you apply.
• Assuming the FRM certification counts as an industry qualification. It is not on the SFC’s lists.
• Relying on the 2011 appendix without asking the firm’s licensing team how the SFC applies it today.
• Forgetting the yearly training hours once you hold a licence.

What does this page cover?

Last updated

30 October 2026

Based on

• The SFC’s Guidelines on Competence (October 2024), Appendix C of the June 2011 guidelines and the Guidelines on Continuous Professional Training (January 2022)
• A law firm’s summary of the competence routes from 2022 (secondary source)
• CFA Institute and GARP fees from our fact register; ECB reference rates

Includes

• SFC licensing for representatives and responsible officers, and where the CFA Program and the FRM Exam fit
• 2027 exam fees in US dollars and Hong Kong dollars

Not included

• Rules for bank staff registered through the HKMA, insurance and leveraged foreign exchange licences
• Hong Kong salaries and how many candidates pass
• This is not legal, financial or careers advice

CIIA and CFP are trade marks of their respective owners and are named only because the SFC names them; their owners are not connected with this page.

High Performer Certs is an independent study platform. It is not affiliated with, endorsed by, or sponsored by CFA Institute or the Global Association of Risk Professionals (GARP). We are not a CFA Institute Prep Provider and not a GARP Exam Preparation Provider. CFA Institute does not endorse, promote, review or warrant the accuracy or quality of our products and services. GARP does not endorse, promote, review or warrant the accuracy of our products or services. All questions and explanations are our own original material and contain no CFA Institute or GARP exam, curriculum or practice questions. CFA®, Chartered Financial Analyst®, CIPM® and GIPS® are registered trademarks owned by CFA Institute. FRM® and GARP® are trademarks owned by the Global Association of Risk Professionals.