By Philippa Allen, Managing Director, Regulatory Compliance, Asia
On 15 July 2025, the Hong Kong Securities and Futures Commission (SFC) issued circular 25C/41, introducing an enhanced facilitative measure for itinerant professionals (ITPs). ITPs are licensed individuals from overseas group companies of licensed corporations or virtual asset (VA) service providers who conduct regulated activities or provide VA services in Hong Kong on a short-term basis.
The circular extends the permitted duration of activity from 30 to 45 calendar days per year and outlines key regulatory requirements to maintain oversight and compliance.
This update forms part of the SFC’s broader efforts to support cross-border business within regulated financial groups, providing licensed firms with greater flexibility to temporarily engage qualified professionals from overseas affiliates without compromising regulatory standards.
What are the key requirements?
To help firms remain aligned with the revised regime, the SFC has detailed the following conditions:
1. Eligibility
ITPs must be from an overseas group company of:
- A licensed corporation under the Securities and Futures Ordinance (SFO)
- A licensed VA service provider under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO)
2. Permitted activities
ITPs may conduct regulated activities under the SFO, or provide VA services under the AMLO, on behalf of the licensed corporation in Hong Kong.
3. Licence requirement
ITPs must hold a representative licence from the SFC. The licence will include a condition limiting the number of days the ITP may operate in Hong Kong.
4. Extended duration
The permitted period has been extended from 30 to 45 calendar days per year. This applies to both new and currently licensed ITPs, whose licence conditions will be updated accordingly.
5. Chaperoning requirement
ITPs must be always chaperoned by a licensed person unless they are exclusively serving professional investors (as defined under the SFO, excluding certain prescribed classes).
6. No change to application process
There are no structural changes in the application process. The intended 45-day period offers operational flexibility, but the same licensing conditions will continue to apply. Related conditions will be updated accordingly.
Strategic considerations for licensed firms
The 15-day extension offers more than just operational breathing room. It invites firms to rethink how they deploy global expertise in Hong Kong. To fully capitalise on this flexibility while staying compliant, licensed entities should:
- Reassess ITP usage: Identify frequent travellers and evaluate whether the extended timeframe enhances business continuity or client service
- Strengthen chaperoning protocols: Ensure clear documentation and consistent application, especially when engaging non-professional investors
- Update internal tracking: Monitor ITP presence in Hong Kong to avoid breaching licence conditions
- Educate key teams: Train compliance and client-facing staff on the revised regime to prevent inadvertent breaches
- Consult official guidance: Refer to the SFC Licensing Handbook or the Licensing Handbook for VA Trading Platform Operators for detailed requirements
How we can help
With over two decades of regulatory experience and a team of 100+ specialists across Asia, we’re here to help you navigate the evolving ITP regime with confidence.
Whether you’re reviewing your ITP framework, updating chaperoning procedures, preparing licence applications, or conducting compliance health checks, we offer tailored, practical solutions aligned with the latest SFC regulations. We also support clients with mock inspections, internal control documentation and real-time tracking tools to ensure ongoing compliance.
If you’d like to learn more or speak with our team of experts, reach out to us now.
