Hong Kong SFC Continuous Professional Training Requirements

Hong Kong’s continuous professional training regime is built from layers rather than a single number. The headline figure is 10 hours a year, but a responsible officer advising on takeovers while licensed for two regulated activities is working to four separate minimums at once — and the Guidelines do not spell out how far they overlap.

The rules sit in the SFC’s Guidelines on Continuous Professional Training, dated January 2022 and published under section 399 of the Securities and Futures Ordinance.

The hours, layer by layer

The base requirement (paragraph 5.2). Licensed representatives and registered individuals must complete a minimum of 10 CPT hours per calendar year, and this does not scale with the number or types of regulated activities held. Responsible officers and executive officers need two additional hours, so at least 12, with those two covering regulatory compliance topics.

Activity-relevant hours (paragraph 5.3). At least five hours a year should address topics directly relevant to the regulated activities the individual is licensed for, allocated in proportion to time spent in each practice area. Worth noting that paragraph 5.2 uses “must” while 5.3 uses “should” — a distinction a compliance officer should take at face value rather than treat as loose drafting.

Specialist hours. Sponsor work attracts at least 2.5 hours a year on sponsor-related topics, and work under the Codes on Takeovers attracts at least 2.5 hours on takeovers topics. Both can count toward the five activity-relevant hours.

Ethics and compliance (paragraph 5.4). After the first year, at least two hours a year on ethics or compliance — meaning the legal and regulatory framework, regulators’ codes and industry guidelines, and corporate or professional-body policies.

New joiners. Within 12 months of first becoming a licensed or registered individual, two hours on ethics as a one-off. These can count toward the annual ethics requirement but not toward a responsible officer’s two additional compliance hours (paragraph 5.5).

One honest caveat: the Guidelines list these components without stating how they interact. Whether the ethics hours also count toward the five activity-relevant hours is not addressed, so the prudent reading is to treat them as distinct unless the SFC says otherwise.

Topics are illustrative, not mandated

Paragraph 7.1 lists relevant topics including fintech, environmental, social and governance matters, cybersecurity and information technology. Responsible officers have an additional list at 7.2 covering business management, risk management and control strategies, general management and supervisory skills, macro and micro economic analysis, and financial reporting and quantitative analysis.

Two points for anyone building a curriculum. No minimum hours attach to any individual topic — fintech and ESG appear as examples, not quotas. And anti-money laundering is not named at all in the CPT Guidelines, which surprises firms that assume it is mandated. The list is expressly non-exhaustive.

What counts, and what does not

Paragraph 6.1 sets a three-part test: the activity must be relevant to the individual’s functions, have significant intellectual and practical content, and involve interaction with other persons.

That last element is the one that disqualifies most convenient options. Paragraph 6.3 states that normal working activities, and general reading of the financial press or of technical, professional, financial or business literature, will generally not count — nor will activities without interaction with others.

Acceptable activities under 6.2 include courses, workshops, lectures and seminars; distance learning requiring assignments; self-study and online courses, where there are independent assessments and sufficient records; industry research; publishing papers; speeches; lecturing or teaching; commenting on industry consultation papers; and service on SFC regulatory committees or formal working groups. Face-to-face and virtual delivery are both acceptable. Luncheon talks of one to two hours count as half an hour.

Two further limits: repeating the same activity with the same content does not satisfy the requirement (7.6), and language courses generally do not count, although management training does where it assists the regulated activities (7.4).

Part-year, changing employer, and no carry-forward

An individual first licensed during the year may apply the hours pro rata to the licensed period — the Guidelines’ example is a licensed representative licensed on 1 July, who needs five hours. The one-off two ethics hours for new joiners are excluded from pro-rating.

Excess hours do not carry forward to the next year (5.8(f)), so over-delivering in one year buys nothing in the next. Pre-licence training taken in the same calendar year does count (5.8(b)).

On a change of employer, hours carry forward from the previous employer and the new employer may rely on the individual’s declaration and supporting documents. The new employer is not accountable for a shortfall accrued elsewhere, but must ensure the annual requirement is met from that point — which makes a declaration at onboarding a practical necessity rather than a nicety.

Records: three years, held by both sides

Individuals must retain appropriate records of their CPT activities, with evidence such as attendance certificates and examination results kept for a minimum of three years (5.6). Corporations must keep training details, attendance records and materials for the same minimum period (4.6 to 4.7). The SFC may request records from licensed representatives and responsible officers; the HKMA may request them from registered individuals and executive officers.

Where responsibility sits

This is the structural feature that distinguishes Hong Kong. Under paragraph 4.1 corporations are held primarily responsible for planning and implementing a continuous education programme, and must review it at least annually. Who pays is left to the firm and the individual to settle.

But the individual obligation is personal: they must remain fit and proper at all times, complete the hours and keep the records. At the annual return, licensed corporations, responsible officers and licensed representatives confirm compliance or explain non-compliance for the previous calendar year (3.4). Failure casts doubt on fitness and properness and may lead to disciplinary action, though the regulators state they will take a pragmatic approach (3.5).

One further requirement sits in the separate Guidelines on Competence rather than the CPT Guidelines: an “Extra CPT” obligation of five hours for each regulated activity applied for, as a one-off, to be completed within the six months preceding the application.

How it compares across the region

Hong Kong sits at the lighter end of regional requirements. Singapore’s Notice FAA-N26 runs to 30 hours a year for an investment product adviser — six core plus twenty-four supplementary — as set out in our guide to MAS competency requirements. The structural difference is that Hong Kong places primary responsibility for the education programme on the corporation while keeping the hours personal to the individual.

On the funding side, Hong Kong operates its own subsidy for individual learning, covered in our guide to the Continuing Education Fund — though its contact-hour and assessment conditions exclude most self-paced e-learning. Our CPD course library covers the ethics and regulatory material the annual requirement draws on.

Frequently asked questions

How many CPT hours does the SFC require?

Ten per calendar year for licensed representatives and registered individuals, regardless of how many regulated activities they hold, and at least twelve for responsible officers and executive officers, whose two additional hours must cover regulatory compliance.

Is anti-money laundering training mandatory under the CPT Guidelines?

It is not named in them, and no minimum hours are set for it. The topic lists include fintech, ESG, cybersecurity and information technology as examples, and are expressly non-exhaustive.

Does reading industry publications count?

Generally not. Paragraph 6.3 excludes normal working activities and general reading of the financial press or professional literature, and requires activities to involve interaction with other persons.

Can unused hours be carried into next year?

No. Excess hours do not carry forward. Pre-licence training within the same calendar year does count, and hours earned with a previous employer carry forward within the year.

How long must CPT records be kept?

A minimum of three years, by both the individual and the corporation, and they must be available to the SFC or the HKMA on request depending on the licence type.