1. Type 4 License (Advising on Securities) Statutory Business Functions
Provide securities investment advice
Provide purchase of securities falling within the statutory definition within the scope and conditions of the license、sell、hold or other opinions。stock、bond、ETF、Whether a fund or tokenized product is a security，And whether the suggestion triggers other activities，Must be judged according to product and service process。
Write and distribute research reports
Produce and publish securities-related analysis reports (such as stock research、bond ratings or market analysis)，for customers、Public or institutional references to support investment decisions (such as issuing a "buy" or "sell" rating)。
Portfolio and Strategy Consulting
Securities investment portfolios can be constructed、Provide advice on allocation or risk management；If the institution has full investment decision-making power or directly manages the investment portfolio，must continue to evaluate Category 9 asset management activities。
virtual assets (VA) Consulting function
If virtual assets or tokenized products are “securities”，Providing advice may involve Category 4 and SFC virtual asset related requirements。Opinions on non-securities virtual assets not being automatically approved for Type 4 license，It cannot be uniformly summarized as being regulated only by a certain VASP framework.，Separate analysis is required based on services and current systems.。
2. Core statutory qualification requirements for applying for Type 4 license
fit and proper person (Fit and Proper)：In good faith, the China Securities Regulatory Commission、Competence、Financial soundness and past regulatory or criminal matters review of the applicant corporation、Responsible person、Licensed representatives and other relevant persons，and review the equity arrangements of directors and major shareholders。Relevant matters must be disclosed truthfully，Comprehensive evaluation by the China Securities Regulatory Commission。
Corporate and operational arrangements：The applicant must usually be a company established in Hong Kong，Or a non-Hong Kong company registered under the Companies Ordinance，and maintain with personnel、Record、System and business fit、Management and premises arrangements for effective supervision by the SFC。The SFC does not uniformly stipulate a fixed number of local employees for all Category 4 applications。
Responsible person (RO)：Category 4 activities usually require at least two approved responsible persons，At least one of them shall be an executive director，And there must be at least one responsible person available to supervise the business at all times。Relevant experience、Management experience、local regulatory knowledge、Exam papers and exemptions are assessed based on individual background and intended supervised activities，It should not be rewritten as a unified condition for permanent residence in Hong Kong。
Compliance and Internal Control：Establish an AML/CFT that is commensurate with the business、Customer due diligence、Suitability、conflict of interest、Research approval、employee transactions、Data protection、Complaints and Record Keeping Controls。Licensed corporations are required to arrange audits in accordance with applicable rules，However, the specific work and application stage requirements of independent auditors must be confirmed on a case-by-case basis.。
business plan：Explanation activities、product、client、TOLL、promotion、opinion generation、Research approval、Transaction execution boundaries and internal controls。When virtual assets or algorithms are involved，Product classification should be stated、data、Model、Personnel review and customer protection；The SFC does not have a unified statutory threshold for “analytical tools” as described on this page.。
3. Securities and Futures (Financial Resources) Rules Capital Requirements and Official Fees
| Institutional business conditions restrictions | Minimum paid-up share capital (Paid-up Capital) | Minimum working capital (Liquid Capital) |
|---|---|---|
| Subject to the condition "not to hold client assets" | not applicable (No hard requirements) | $100,000 Hong Kong dollar |
| Other situations (customer assets can be held) | $5,000,000 Hong Kong dollar | $3,000,000 Hong Kong dollar |
| SFC application fee and annual license fee | Corporate and individual application fees、The annual license fee and any current exemption must be confirmed according to the SFC WINGS and current fees page when submitting or billing；Old amounts that have not been reviewed by the current fee schedule will not be used on this page.。 | |
Note on legal restrictions：4Number plates are only allowed to provide opinions，Excludes executionSecurities trading under the Securities and Futures Ordinance(needHong Kong SFC License No. 1）、Corporate financing advice (requires No. 6 license) or direct management of client funds/investment portfolios (requires No. 9 license)。
4. Licensing exemptions under the Securities and Futures Ordinance
incidental exemption：Securities advice provided by a Type 1 or Type 9 licensed corporation，If it is entirely incidental to securities trading or collective investment scheme portfolio management and meets all statutory conditions，There may be no need to obtain Category 4 separately。Whether it is "completely incidental" must be charged、Judgment of authority and actual process。
Group member companies exempt：Securities advice is provided only to group members who meet the definition of a wholly owned relationship for their own use，May be exempted if all statutory conditions are met；Not applicable to customers outside the group or entities that do not qualify for the relationship。
Professional exemption：lawyer、Securities advice provided by a barrister or professional accountant is entirely incidental to the scope of their professional practice，Can be exempted from licensing。
Publication or broadcast exemption：By complying with regulations definition、Publications or broadcasts generally available to the public providing opinions，Satisfy the content、May be exempted under media and business conditions。website、social media、Subscriptions to communities or personalized recommendations cannot be automatically applied。
trust company exemption：as a registered trust company，If the investment advice provided is entirely incidental to the performance of the duties of a registered trust company，Can be exempted from licensing。
5. Type 4 license applications and transactions in control of licensed corporations
[Path A] Apply directly to the China Securities Regulatory Commission (The total cycle is approx. 6-12 months)
1. preparation：Confirm business、main body、control architecture、Responsible person、financial resources、Premises and internal controls。
2. submit：Submit applicable forms and supporting documents through WINGS and pay the current fee。
3. review：CSRC conducts completeness and substantive review，And can ask for replacement parts、Background information or management notes。
4. Decide：The SFC independently decides whether to issue a license and whether to impose conditions；Fulfill continuing responsibilities after obtaining the license。
【Path B】Acquisition of a licensed corporation or its controlling entity
1. Due diligence：Check license conditions、client、Historical business、supervision、finance、tax、People and system risks，There is no guarantee in advance that the subject will be "clean"。
2. transaction documents：The price is determined by the buyer, seller and independent professional consultants、Prerequisites and risk allocation。
3. control approval：Persons who intend to become or increase their interests as substantial shareholders are usually required to obtain prior approval from the Securities and Futures Commission。
4. Delivery and Operation：Responsible personnel must still be maintained after closing、Financial resources and internal controls，Business integration shall not exceed license conditions。
6. Core risks and challenges in No. 4 license application and acquisition
Responsible Personnel Risk：Candidate’s experience、Examination or actual performance arrangements do not meet the requirements，or personnel leaving after the transaction，May affect application and continued operations。Re-appointment subject to SFC approval，The time required is determined on a case-by-case basis。
Virtual asset classification risks：Category 4 only deals with opinion activities constituting securities and the conditions for their application。Product classification and other regulatory systems should be checked before starting business；Whether legal advice is required depends on complexity，Not all projects are mandatory。
acquisition risk：The target company may have undisclosed liabilities、Customer Responsibilities、Regulatory matters or system gaps。Buyers should arrange independent legal arrangements commensurate with the size of the transaction、finance、Tax and regulatory due diligence，and allocate risk in transaction documents。
Review and management notes：The SFC may require responsible officers or management to explain operations and internal controls，Regulatory inspections can also be conducted after licensing。Whether to interview、Inspection or supplementary documents are determined on a case-by-case basis，Cannot preset "burst checks" or fixed results。
7. Category 4 application and transaction support provided by Hong Kong Huitong
Comprehensive application agency
Can assist in managing the structure according to the agreed scope、business plan、Internal monitoring documents such as operations and AML/CFT，and organize responses to regulatory inquiries。Applicants and management must confirm the materials and perform their duties in person，The consultant cannot answer all questions for you。
Target screening and due diligence(DD)
Can assist in organizing subject information according to the contract，and coordinate with independent counsel、Accountant or tax advisor to conduct due diligence。No resource network can guarantee that the underlying object does not have history、client、supervision、debt or systemic risk。
M&A closing and transfer
Can assist with transaction coordination，and arrange for independent professionals to process the letter of intent、sale and purchase agreement、Tax and corporate matters。CSRC control approval is not a simple filing，Bank account and delivery results are not guaranteed。
8. Hong Kong No. 4 Financial License Core Legal Questions and Answers (FAQ)
Type 4 Regulation “Advising on Securities”。License may cover securities advice and research，However, actual authority is subject to license conditions、client、Limitations on how products and opinions are provided；If you execute transactions or have full investment decision-making power，Also required to assess Category 1 or Category 9。
If the advice provided by a Type 1 or Type 9 licensed corporation is wholly incidental to its dealings in securities or management of its collective investment scheme portfolio，and meet all statutory conditions，There may be no need to obtain Category 4 separately。Whether to charge independently is only one of the factors in judging，Depends on the actual process and permissions。
Protected by the "Group Company Exemption"，If a corporation pays purely to its wholly-owned subsidiary、A parent company or other wholly-owned subsidiary that holds all issued shares provides investment advice for its own use，Can be exempted from licensing。This does not apply to providing advice to clients external to the Group。
Category 4 activities usually require at least two responsible persons，At least one of them shall be an executive director，And there must be at least one responsible person available to supervise the business at all times。Relevant experience、Management experience、local regulatory knowledge、Exam papers and exemptions are assessed based on individual background and intended supervised activities。
If the institution is subject to the licensing condition of “not holding client assets”，The minimum working capital requirement is HKD 100,000 (no minimum paid-up capital requirement)。If there is no such restriction (customer assets can be held)，It requires a paid-up share capital of HK$5 million and working capital of HK$3 million.。
The Securities and Futures Commission will, based on financial soundness、Competence、Relevant persons with comprehensive assessment of character, integrity and past supervision or criminal matters。Bankruptcy、Criminal or regulatory matters must be truthfully disclosed，However, whether it affects qualifications shall be determined by the China Securities Regulatory Commission based on the facts.。
If virtual assets or tokenized products are securities，Advising on it may involve Category 4 and additional conditions。Opinions on non-securities virtual assets not being automatically approved for Type 4 license，The applicable system must be based on the product、Services and current laws will be determined separately.。
Customer restrictions on virtual asset-related products、knowledge assessment、Suitability and sales guarantee depend on the complexity of the product、Is it recognized?、Customer Categories and Current SFC Joint Circulars。All advice cannot be limited to professional investors，There is no unified mandatory form of “digital tools”。
Licensees should conduct suitability assessments by product and customer、Risk disclosure、Communication records and ongoing control。Do you need a dynamic system?、Update frequency and subsequent evaluation depends on service model，Cannot be written as a unified technical requirement for all Category 4 virtual asset opinions。
Buyers should check the target company’s product classification、License conditions、client、Opinion record、system、Outsourcing and past regulatory matters。Whether transaction monitoring and system integration time are required depends on the actual business of the target company，Cannot preset a fixed number of months。
Key risks include undisclosed liabilities、Customer Responsibilities、regulatory matters、Responsible personnel leave office、The license conditions do not match the buyer’s business。New responsible officers must be approved by the Securities and Futures Commission，Timing depends on candidate and review。
Common issues include mismatch in experience or exams of responsible personnel、Business plans and internal controls are inconsistent with actual processes、Insufficient financial resources or equity information。Replacement and review times depend on the individual case，Cannot preset 1 to 3 months or 2 to 4 weeks。
The SFC may require the responsible officer or management to explain their experience on a case-by-case basis、Business and Internal Control，Written questions may also be asked。Interviews are not a fixed step for all applications，Consultant mock preparation does not guarantee review speed or results。
A-S-P-I-Re is the virtual asset regulatory roadmap announced by the China Securities Regulatory Commission in 2025。It does not by itself automatically change the license conditions of each Type 4 licensed corporation.；When providing advice on virtual assets, the laws in effect must still be used、Circular、The Code and case conditions shall prevail。
Licensed corporations are required to pay applicable annual fees in accordance with current rules、Submission of annual returns and audited accounts，and fulfill financial resources、AML/CFT、Responsibilities such as records and notification of major changes。The CPT hours and topics for licensed individuals are based on their roles and the SFC’s current continuing training guidelines.，It is not appropriate to generalize to the range of 5 to 10 hours。
9. Hong Kong Securities and Futures Commission SFC No. 4 License-Application Case
10. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
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| Legislation and regulatory guidance | |
| Licensing and regulatory authorities | |
| Fact-checking sources for this page |
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