SFC Continuous Professional Training (CPT) Requirements: Hour Calculation and Record Maintenance

The SFC’s 2024-2026 strategic review of intermediary conduct has placed licensed representatives’ ongoing competency under a sharper spotlight. A key driver is the SFC’s increased focus on “fit and proper” standards, which now explicitly link a representative’s failure to meet Continuous Professional Training (CPT) obligations to potential disciplinary action. In 2025, the SFC issued a record number of deficiency letters to licensed corporations regarding their CPT record-keeping, signalling a shift from passive compliance to active enforcement. For any licensed individual or corporation, understanding the precise calculation of CPT hours and the mandatory record maintenance regime is no longer a back-office formality—it is a regulatory requirement with direct consequences for licence renewal and enforcement outcomes. This article sets out the SFC’s rules under the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission (the Code of Conduct), specifically paragraph 12, and the relevant guidelines.

The Core CPT Obligation: Hours and the Licensing Cycle

The SFC’s requirement is not a suggestion. It is a mandatory condition attached to every individual licence. The legislation provides that a licensed representative must complete a minimum of 5 CPT hours per calendar year, with a carry-forward provision of up to 5 hours from the preceding year. This rule is found in paragraph 12.1 of the Code of Conduct. The calculation is straightforward: a representative must accrue 5 hours in the current year, or if they carried forward 5 hours from the previous year, they must accrue at least 0 hours in the current year to meet the 5-hour threshold. The carry-forward provision is a one-year window only. Hours from 2023 cannot be used to satisfy the 2025 requirement if they were not used in 2024.

Step 1: Identify the Relevant Licensing Year

The SFC operates on a calendar-year basis for CPT purposes. The relevant period runs from 1 January to 31 December of each year. A representative licensed on 1 July 2024 is still required to complete 5 CPT hours for the 2024 calendar year. The SFC does not pro-rate the requirement for mid-year licence approvals. The only exception is for representatives whose licence is approved after 1 October in any given year. In that case, the requirement for that calendar year is reduced to 2.5 hours. The SFC’s 2024 Guideline on CPT (the Guideline) confirms this pro-ration rule.

Step 2: Calculate the Carry-Forward

The carry-forward provision allows a representative to use up to 5 hours of CPT completed in the previous year to meet the current year’s requirement. The calculation is as follows: if a representative completed 8 hours in 2024, they may carry forward 3 hours to 2025. They then need to complete only 2 hours of new CPT in 2025 to meet the 5-hour minimum. The SFC’s Guideline states that the carry-forward is calculated net of the previous year’s requirement. Hours carried forward cannot be carried forward again. If a representative uses 2 of the 3 carried-forward hours in 2025, the remaining 1 hour is lost and cannot be used in 2026.

Step 3: Identify Qualifying Activities

Not all training qualifies as CPT. The SFC’s Guideline specifies that CPT must be “relevant to the regulated activities for which the person is licensed.” Qualifying activities include:

• Attending seminars, workshops, or conferences organised by the SFC, the Hong Kong Institute of Bankers, or other SFC-recognised professional bodies.
• Completing online courses offered by the Hong Kong Securities and Investment Institute (HKSI) or the SFC’s own e-learning platform.
• Attending in-house training programmes that are structured, have a defined curriculum, and are delivered by a qualified trainer.

The SFC does not accept self-study, reading of regulatory circulars, or general business training as CPT. The 2024 SFC Enforcement Report noted that the most common deficiency in CPT compliance was the inclusion of non-qualifying activities. The SFC’s position is clear: the activity must be structured, assessed (either by a test or a certificate of completion), and directly relevant to the representative’s licensed functions.

Record Maintenance: The Documentary Burden

The SFC does not accept a verbal confirmation of CPT completion. The legislation provides that the licensed corporation must maintain a central register of all CPT records for each of its licensed representatives. This requirement is set out in paragraph 12.2 of the Code of Conduct. The record must be kept for a minimum of 7 years from the end of the calendar year to which the CPT relates. The SFC expects the register to be available for inspection upon request.

What a Proper Record Must Contain

The SFC’s Guideline specifies the minimum information that must be recorded for each CPT activity:

• The date and duration of the activity (in hours and minutes).
• The title and a brief description of the activity.
• The name of the organiser or provider.
• A certificate of completion or a signed attendance record.
• A note on the relevance of the activity to the representative’s regulated activities.

A common error is recording “1 hour” for a seminar that ran for 45 minutes. The SFC expects precise time recording. If a seminar runs for 1 hour and 15 minutes, the record should state 1.25 hours. The SFC does not accept rounding up to the nearest hour.

The Licensed Corporation’s Responsibility

The licensed corporation is the primary record-keeper. The SFC’s 2024 Circular on CPT Compliance (the Circular) states that the licensed corporation must “take reasonable steps to ensure that its licensed representatives comply with the CPT requirement.” This includes:

• Maintaining the central register.
• Verifying the authenticity of CPT certificates.
• Following up with representatives who are behind on their CPT hours.
• Reporting any CPT deficiencies to the SFC.

The SFC has the power to impose a financial penalty on the licensed corporation for failing to maintain proper records. In 2024, the SFC fined one licensed corporation HK$500,000 for failing to keep a central register for 18 months. The SFC’s Enforcement Division treats record-keeping failures as a breach of the Code of Conduct, which can lead to a reprimand, a fine, or a suspension of the corporation’s licence.

Enforcement and Consequences of Non-Compliance

The SFC’s enforcement approach has shifted. Non-compliance with CPT requirements is now treated as a standalone breach, not merely a deficiency to be remedied. The SFC’s 2025 Enforcement Annual Report (published in March 2025) recorded 12 enforcement actions against individual representatives for CPT-related breaches. The sanctions ranged from a public reprimand to a suspension of the individual’s licence for up to 6 months.

Individual Representative Consequences

For an individual licensed representative, failing to meet the CPT requirement can lead to:

• A conditional licence renewal, requiring the representative to complete the missing hours within a set period (typically 3 months).
• A suspension of the licence if the hours are not completed within the conditional period.
• A public reprimand on the SFC’s public register, which can damage the representative’s professional reputation and employability.

The SFC’s Guideline states that “persistent failure to comply with the CPT requirement may call into question the fitness and propriety of the licensed person.” This is a serious finding. A representative found to be not fit and proper may have their licence revoked.

Licensed Corporation Consequences

For the licensed corporation, the consequences are broader. The SFC can:

• Impose a financial penalty of up to HK$10 million for systemic record-keeping failures.
• Issue a public censure.
• Impose additional CPT requirements on all representatives of the corporation.
• Refer the matter to the Market Misconduct Tribunal if the failure is linked to broader compliance failures.

The SFC’s 2024 Circular emphasised that “a licensed corporation’s failure to supervise its representatives’ CPT compliance is a breach of the management obligation under the Code of Conduct.” This means the responsible officers and the board can also be held personally liable.

Practical Steps for Compliance

The SFC expects a proactive approach. The following steps are based on the SFC’s Guideline and the 2024 Circular.

Step 1: Set Up a Central Register

The licensed corporation must establish a central register. The register can be maintained electronically or in hard copy. The SFC does not prescribe a specific format, but the register must be searchable by representative name, date, and activity type. The register should include a column for “Status” (e.g., “Completed,” “Pending Verification,” “Deficient”). The SFC recommends updating the register within 30 days of the CPT activity.

Step 2: Schedule CPT Activities Early

The SFC’s Guideline recommends that representatives complete their CPT hours by 30 September of each year. This allows the licensed corporation time to verify the records and address any deficiencies before the year-end. The SFC’s 2025 Enforcement Report noted that representatives who completed their CPT by 30 September had a 99% compliance rate, compared to 82% for those who completed it in the last quarter.

Step 3: Conduct a Mid-Year Review

The licensed corporation should conduct a mid-year review of each representative’s CPT status. The review should identify representatives who have completed fewer than 2.5 hours by 30 June. The licensed corporation should then issue a written reminder and offer to sponsor relevant training. The SFC’s Circular states that “a documented review process demonstrates a commitment to compliance and may mitigate the severity of any enforcement action.”

Step 4: Retain All Supporting Documents

The licensed corporation must retain all certificates of completion, attendance records, and course materials for 7 years. The SFC’s Guideline states that “the burden of proof lies with the licensed corporation to demonstrate that the CPT activity was completed and was relevant.” If a certificate is lost, the SFC will not accept a representative’s own statement as proof.

Key Takeaways

• The SFC requires 5 CPT hours per calendar year, with a carry-forward of up to 5 hours from the previous year, and no pro-ration except for licences approved after 1 October.
• The licensed corporation must maintain a central register of all CPT records for a minimum of 7 years, with precise recording of activity date, duration, and relevance.
• Non-compliance by an individual representative can lead to a conditional licence renewal, suspension, or a finding of not being fit and proper.
• The SFC’s 2024-2025 enforcement trend shows a clear shift toward treating CPT failures as standalone breaches, with financial penalties for corporations reaching HK$500,000.
• A proactive compliance approach—early scheduling, mid-year reviews, and robust record-keeping—is the only reliable defence against SFC enforcement action.

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