SFC Resumes Collection of Annual Licensing Fees
This update ends a multi-year waiver period introduced to provide financial relief for licensed corporations and regulated professionals during challenging economic times, including the COVID-19 pandemic and prior financial downturns. For licensed corporations and individuals engaged in various regulated activities (RAs), understanding these updated compliance and regulatory requirements is crucial to avoid potential surcharges, suspensions, or revocations that could impact ongoing operations.
SFC Implements Licensing Fees to Strengthen Regulation
The SFC is resuming annual licensing fee collection to address a projected budget deficit, with an HK$256 million in annual revenue expected. The waiver, in place intermittently since 2009 (and extended through March 2025), was designed to support the financial services industry during periods of economic strain.
With Hong Kong financial markets showing signs of stabilization, the reinstated fees will help fund the SFC’s core supervisory activities including inspections and enforcement.
Failure to comply poses serious consequences under Securities and Futures Ordinance Sections 138(3) and 195(4)(a) and (6), including surcharges, license suspension, or revocation—particularly for entities with more complex operations.
Making timely payments not only mitigates these risks but also demonstrate sound governance, which may be favourably viewed during regulatory SFC inspections and routine regulatory reviews.
Annual Licensing Fee Payment Deadline
Under Section 138(2) of the SFO, annual licensing fees must be paid within one month of the license or registration anniversary date. Fees vary by intermediary type and are charged per RA.
Importantly, fees are still due on the anniversary date, even if RAs cease later. Firms are therefore encouraged to review their licensing structure in advance to ensure they are only paying for activities that remain necessary.
Annual Licensing Fee Details and Payment Options
Fee details are in Item 18, Schedule 3 of the Securities and Futures (Fees) Rules:
| Types of Intermediary / Licensed Individual | Types of RA | Annual Licensing Fee (HKD) |
|---|---|---|
| Licensed Corporation | RAs other than RA 3 | $4,740 per RA |
| RA 3 | $129,730 | |
| Responsible Officer | RAs other than RA 3 | $4,740 per RA |
| RA 3 | $5,370 | |
| Licensed Representative | RAs other than RA 3 | $1,790 per RA |
| RA 3 | $2,420 | |
| Registered Institution | RAs other than RAs 3 and RA 8 | $35,000 per RA |
Note:
– Annual fee for RA 7 (automated trading services) is waived if incidental to RA 1 (dealing in securities) or RA 2 (dealing in futures contracts).
– Registered institutions don’t need to register for RA 3 (leveraged foreign exchange trading) or RA 8 (securities margin financing) under Section 119 of the SFO.
The SFC recommends paying fees efficiently through the WINGS platform using WINGS Pay, FPS, PPS, or credit cards. E-Notifications are sent via WINGS Mails on each license anniversary dates, requiring intermediaries to ensure proper access and delegation settings are in place within their Corporate WINGS accounts.
A Quick Guide and FAQs are available to assist with managing the fee payment process efficiently.
How to Manage Annual Licensing Fee Requirements
To manage this regulatory transition effectively and minimize compliance risks:
- Review anniversary dates: Assess all licenses and registrations to anticipate upcoming due dates and associated fees.
- Ensure WINGS access is up to date: Confirm that delegated personnel can receive and respond on e-Notifications promptly via WINGS platform.
- Conduct internal reviews: Evaluate whether all current RAs remain necessary to avoid incurring avoidable costs.
- Seek expert guidance: If you require support navigating these updated annual licensing fee requirements, consider reaching out to a qualified compliance advisor, such as Waystone’s APAC Compliance Solutions team.
Staying ahead of these changes ensures regulatory continuity, cost-efficiency, and reinforces sound governance—so your business can stay focused on growth.
How Waystone Can Help
Waystone provides a comprehensive suite of Corporate Compliance Solutions tailored to support businesses expanding into or operating within Hong Kong. Our team of regulatory compliance professionals is committed to strengthening compliance framework, so you can concentrate on growing your business with confidence.
To learn more about our corporate compliance solutions, please reach out to your usual Waystone representative or our APAC Compliance Solutions via below.