Can I be exempted from HKSI Paper 1? Exemptions and how they work

Yes, but only in specific cases, and most newcomers do not qualify. A full Paper 1 exemption mainly covers people licensed for the same type of activity in the past three years, temporary licence applicants, and people who have worked full time in regulation or compliance in Hong Kong. You do not apply to HKSI. The SFC decides, case by case, as part of the licence application made with your sponsoring firm.

Who grants exemptions

Paragraph 4.4 of the SFC's Guidelines on Competence says exemptions are discretionary, specific to the facts and to the sponsoring firm, and not transferable. A licence application is made jointly by you and the licensed corporation employing you, through the SFC's WINGS-LIC system, and the SFC considers any exemption as part of it. In practice, you need an employer before an exemption is even possible.

Bank staff are "relevant individuals". The bank must make sure you meet the competence requirements before it submits your name to the HKMA, and keep records for HKMA inspection. Ask your bank's compliance team first.

Full exemption from Paper 1

Under paragraph 4.4.3.1, a full exemption from the regulatory paper can apply if you:

• are, or within the past three years were, licensed, and are applying for a regulated activity with the same regulatory paper in the same role;
• are applying for a temporary licence; or
• have worked full time in regulatory or compliance work in Hong Kong for at least 3 of the past 6 years, in the same regulated activity.

Paragraphs 4.4.3.2 to 4.4.3.7 set out several conditional exemptions, covering responsible officers, itinerant professionals and representatives adding a regulated activity. The condition is often 5 extra hours of continuous professional training. Whether one fits you depends on your facts; read the Guidelines on Competence itself.

Exemptions from Papers 7 and 8

• Full exemption: you are, or within the past three years were, licensed and are applying for an activity needing the same industry qualification in the same role (for example a Type 1 representative adding Type 4); or you are applying for a temporary licence.
• Conditional exemption: you are currently licensed, have 5 years' related local experience in the past 8 years, and are applying for an activity needing a different industry qualification in the same role. The conditions include 5 extra CPT hours.

Do not confuse an exemption with not needing a paper. Under the SFC's Option A, holders of a degree in accounting, business administration, economics, finance or law, or of a qualification such as CFA, CIIA or CFP, need no industry qualification paper as a representative. That is not a Paper 1 exemption: you still sit Paper 1. See which HKSI papers do I need.

Summary: who can be exempted

Situation	Paper 1	Papers 7 and 8
Licensed in the past three years, adding an activity in the same role that uses the same paper	Full exemption	Full exemption
Applying for a temporary licence	Full exemption	Full exemption
3 of the past 6 years in full-time regulatory or compliance work in Hong Kong, same activity	Full exemption	Not covered by this route
Currently licensed, 5 years' local experience in the past 8, adding an activity needing a different industry qualification	Depends on the case	Conditional exemption (plus 5 extra CPT hours)
Newcomer with a designated degree or a qualification such as CFA (Option A)	Must sit	Not needed
Newcomer with none of the above	Must sit (or be granted the six-month grace period)	Depends on your education and experience route

This is an overview only. The SFC's decision on your case is what counts.

The six-month grace period

The SFC may approve your licence on condition that you pass the regulatory paper within six months of approval. If you do not pass in time, the approval may become invalid and the licence lapse. This is usually granted only once per regulatory paper (paragraphs 4.4.1.2(b) and 4.4.1.6).

Key point: the grace period postpones Paper 1; it does not waive it. Fail to pass within six months and the licence can lapse.

Re-entrants and older passes

Paragraph 4.4.4 of the guidelines provides an exemption from both the industry qualification and the regulatory paper for people returning to the industry. Check the details in the latest SFC guidelines and raise it through your sponsoring firm.

Separately, the SFC expects passes to be no more than three years old when you apply, but an older Paper 1 pass can still count if you are, or in the past three years were, licensed for an activity where that paper applies. The SFC's example: someone who passed Papers 1 and 7 and was licensed for Type 1 in the past three years need not retake them to add Type 2.

HKSI certificates are separate

SFC exemptions affect licensing only. To earn an HKSI certificate, you must complete a set combination of papers within three years of the first paper you pass, and HKSI allows no exemptions for certificate purposes.

If you do not qualify

Paper 1 has 60 questions in 90 minutes, with a 70% pass mark (42 correct). It costs HK$1,800 at the Hong Kong centre (checked November 2026). HKSI's published pass rate for Paper 1 averaged 49.98% over October 2025 to September 2026, the lowest of the three papers. See registration and fees and the Paper 1 guide, and practise Paper 1 questions in English and Chinese on ExamDuck.