I. Do Family Offices Need to Apply for a Hong Kong SFC License?

1. Core Principle: Activity-Based Determination

Hong Kong does not have a dedicated licensing regime specifically for “family offices.” Instead, licensing requirements are generally evaluated under the Securities and Futures Ordinance (SFO) based on “regulated activities.”

• If a family office engages in regulated activities defined in the SFO (such as “asset management” or “securities dealing”) on a commercial basis in Hong Kong, it would typically need to apply to the Securities and Futures Commission (SFC) for the relevant license.
• Conversely, if it only manages its own assets without offering paid services to external clients or providing third-party investment management, it is generally exempt from SFO licensing requirements.

2. Single-Family Office (SFO)

• Exclusively managing its own family assets, with no external fees or outside capital:
  Such arrangements are usually deemed internal (100% family-controlled) asset management and are not considered an external “business.”
  • According to the SFO’s “intra-group exemption” and various SFC guidelines regarding family offices, as long as the office only serves the same family/ownership structure and does not conduct activities requiring a license, no SFC license is needed.
• Common Structures:
  1. A trustee or a company holding family assets → wholly owns/controls → single-family office (internal unit) → manages only the trust’s or family-owned assets;
  2. All contributors and beneficiaries belong to the same family (including trusts, spouses, and in-laws) and do not offer services to external parties for profit.

Conclusion: If it is a single-family scenario and only manages its own family’s assets, it generally does not need to apply for SFC licenses such as Type 1, Type 4, or Type 9.

3. Multi-Family Office (MFO)

• Manages assets for multiple families or external clients, providing portfolio management, investment advice, securities dealing, etc. This is considered external, commercial activity:
  • May require a Type 9 license (asset management), Type 1 license (dealing in securities), Type 4 license (advising on securities), etc., depending on the actual services.
• If it involves futures/options, it may also need a Type 2 or Type 5 license; if it deals with virtual assets, it must meet additional SFC requirements for such activities.

Conclusion: As soon as the scope extends beyond a single family to multiple families or external clients for “investment management,” “investment advice,” or “dealing,” the office must apply for the corresponding SFC license(s) under the SFO classification.

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II. If the Family Has Insurance Needs, Is an “Insurance Broker License” Required?

1. Basic Concept of the Insurance Broker License

• Hong Kong’s insurance industry is regulated by the Insurance Authority (IA).
• If a company or individual arranges insurance contracts, provides insurance advice, or intermediates on behalf of clients (including non-family members), they generally must apply to the IA for an Insurance Broker License or an insurance agency license.
• Simply buying insurance for oneself (or one’s own company) without brokering or selling to third parties typically does not require an insurance broker license.

2. Common Insurance Situations for a Family Office

1. Only handles insurance for its own family members, not offering commercial brokerage to external clients:
   • If the family office is purely managing internal family coverage or coordinating with insurers for its own family policies but does not engage in third-party “insurance broking,” generally no insurance broker license is required.
2. Provides “insurance arrangement” or “insurance consulting” services to multiple families or external clients and charges intermediary fees:
   • This constitutes an external insurance intermediary business, requiring an insurance broker license and meeting IA’s requirements on capitalization, qualified personnel, and compliance.

Conclusion: Merely arranging or purchasing insurance for one’s own family does not require an insurance broker license; but if providing paid insurance intermediary services for other families or clients, one must apply for the relevant license from the Insurance Authority.

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III. Common License Combinations in Different Scenarios

Here are a few simplified examples:

1. Single-Family Office (SFO)
   • ActivitiesActivitiesActivities Only manages its own family’s assets + handles family insurance internally + no external charging
   • SFCLicense?SFC License?SFCLicense? Usually not required (qualifies for the intra-group/family-only exemption)
   • InsuranceBrokerLicense?Insurance Broker License?InsuranceBrokerLicense? Not required (merely dealing with in-house insurance)
2. Multi-Family Office (MFO)
   • ActivitiesActivitiesActivities Manages assets for multiple families + offers investment/advisory/trading services
   • SFCLicense?SFC License?SFCLicense? Required (e.g. Type 9, depending on the scope)
   • InsuranceBrokerLicense?Insurance Broker License?InsuranceBrokerLicense? If also arranging insurance policies for those families and collecting fees, yes.
3. Family Investment Company + External Insurance Services
   • ActivitiesActivitiesActivities Primarily invests family assets but also engages in insurance agency/brokerage for external parties
   • SFCLicense?SFC License?SFCLicense? Not required if it only manages its own assets; required (e.g. Type 9) if it manages others’ investments.
   • InsuranceBrokerLicense?Insurance Broker License?InsuranceBrokerLicense? Yes, because it conducts external insurance intermediary business.

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IV. Summary and Recommendations

1. Single-Family Office
   • Mainly serves internal family needs, usually does not need an SFC license; nor does it need an insurance broker license (unless it provides insurance intermediary services to external parties).
2. Multi-Family Office / External Services
   • Check whether it offers “asset management,” “securities dealing,” “investment advice” or other regulated activities, then apply for the appropriate SFC licenses (commonly Type 9, Type 1, Type 4, etc.).
   • If it also conducts insurance broking/agency for multiple families or other clients, it will need to apply for an Insurance Broker License from the IA.
3. Insurance-Related
   • Purchasing or arranging insurance solely for the family does not require a broker license.
   • Providing insurance intermediary services with fees charged to others does require a broker license.

Key Reminder

• If the family office deals with virtual assets, futures, or cross-border investments, it should also ensure compliance with SFC regulations and other relevant jurisdictions;
• It is strongly recommended to consult professional legal advisors, licensed consultants, or accountants prior to setting up a family office to ensure full compliance and secure all necessary licenses.

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References

• Hong Kong Securities and Futures Commission: Securities and Futures Ordinance (Cap. 571) and Licensing Handbook
• SFC Circular on the Licensing Obligations of Family Offices
• Insurance Authority (IA) rules on insurance brokers/agents
• Actual operational cases of family offices (single-family vs. multi-family distinction)

The above content is provided as a general reference and does not constitute formal legal advice. For precise compliance and licensing evaluations, please directly consult professional advisory teams.