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Circular to intermediaries SFC and HKMA joint product survey 2025

Dec 6, 2025
Latest News SFC Circular to intermediaries SFC and HKMA joint product survey 2025

On December 5, 2025, the SFC and HKMA announced the 2025 joint survey on the sale of non-exchange-traded investment products in Hong Kong. This annual survey focuses on Reporting Intermediaries, aiming to gain insights into the industry landscape and market trends. The survey, covering collective investment schemes, debt securities, structured products, swaps, swaptions, and repos sold to non-institutional investors, includes three parts: general information, selling activities, and supplementary information for high-volume intermediaries. Submissions are due by various dates in early 2026, with queries directed to Ms Denise Chan at the SFC.

This article was generated using SAMS, an AI technology by Timothy Loh LLP.

On December 5, 2025, the Securities and Futures Commission ("SFC") and the Hong Kong Monetary Authority ("HKMA") launched the 2025 joint survey focused on the sale of non-exchange-traded investment products. This annual initiative aims to gather data on the selling activities of licensed corporations and registered institutions in Hong Kong.

The survey is designed to provide a better understanding of the industry landscape and market trends, to supervise intermediaries' selling practices, and to address common industry concerns.

The information collected through this survey will be pivotal for the SFC and HKMA to implement effective regulatory measures and enhance oversight of the financial markets in Hong Kong.

The survey covers the sale of non-exchange-traded investment products, such as collective investment schemes, debt securities, structured products, swaps, swaptions, and repos, to non-institutional and certain corporate investors between January 1 and December 31, 2025.

Institutional and certain corporate investors who are exempt from the suitability obligation are excluded from the survey.

The comprehensive survey questionnaire, designed for Reporting Intermediaries, includes three distinct parts.

Part A focuses on general information and requires all Reporting Intermediaries to provide contact information and indicate if they sold any reportable non-exchange-traded investment products to in-scope clients during the reporting period.

Part B is designated for detailed information on the sale of non-exchange-traded investment products to in-scope clients, including transaction amounts by product type, top issuers, and client types.

Part C is mandatory for Reporting Intermediaries with significant transaction amounts (HK$1 billion or above for LCs, HK$30 billion or above for RIs) and collects detailed information on transaction amounts and top investment products sold.

The SFC published a circular detailing the reporting timeline for intermediaries who completed the 2024 joint product survey.

The report outlines submission dates: January 16, 2026, for Part A only; February 27, 2026, for Parts A and B; and March 6, 2026, for all three parts.

The questionnaire, available in Excel format, along with guidance notes and completion instructions, is accessible on WINGS. Collected information will remain confidential, anonymized, and aggregated before release.

For queries, intermediaries can contact Ms. Denise Chan at the Intermediaries Division of the SFC, or seek technical assistance via the hotline or email This email address is being protected from spambots. You need JavaScript enabled to view it..

The report is valid for professional investors as defined in paragraphs (a) to (i) of the Code of Conduct and for trust corporations, corporations, or partnerships exempted from the suitability obligation under paragraph 15.4.

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