SFC CPT Requirements: How Many Hours You Need Before 31 December
Under the SFC’s Guidelines on Continuous Professional Training, every licensed representative must complete at least 10 CPT hours each calendar year, and every Responsible Officer at least 12. At least five hours must relate directly to your regulated activities and at least two to ethics or compliance. The CPT year closes on 31 December.
This guide sets out who the requirements apply to, how the hours break down, what happens at the deadline and which records to keep.
Who the CPT requirements apply to
The requirements apply to every individual licensed by the Securities and Futures Commission (SFC): licensed representatives, Responsible Officers (ROs) and relevant individuals of registered institutions. Executive officers of registered institutions follow the same standard as ROs.
Licensed corporations carry their own duty. The firm must provide or arrange suitable training and make sure its licensed staff meet the requirements, so a shortfall by one representative also reflects on the firm.
How many hours, and on what
| Requirement | Licensed representative | Responsible Officer |
|---|---|---|
| Minimum CPT hours per calendar year | 10 | 12 |
| Hours directly relevant to your regulated activities | At least 5 | At least 5 |
| Hours on ethics or compliance | At least 2 | At least 2 |
| Additional hours on regulatory compliance | Not required | 2 (included in the 12) |
| New joiners: one-off ethics training | 2 hours within the first 12 months | 2 hours within the first 12 months |
The two extra hours for ROs must cover topics relating to regulatory compliance, which reflects their responsibility for supervising the firm’s business. The one-off ethics hours for new joiners are separate: they cannot be used to meet the two additional hours an RO needs.
Relevance matters as much as the total. A representative licensed for asset management (Type 9) who spends all 10 hours on unrelated topics has not met the five-hour rule, even though the total looks right.
Joining or moving mid-year
If you are first licensed part way through the year, your hours can be applied pro rata to the period you were licensed. Someone licensed on 1 July, for example, would generally need about half the annual requirement for that year. New joiners must still complete the two hours on ethics within their first 12 months.
If you change employer, CPT hours completed at your previous firm carry across with you for the same calendar year. Keep your certificates, because your new employer becomes responsible for checking that you meet the requirement from the date you join.
Why 31 December matters
CPT runs on the calendar year, not the financial year or your licence anniversary. Three points follow from that:
- Hours must be completed by 31 December. Hours done in January count towards the new year, not the one just ended.
- Excess hours cannot be carried forward. Completing 20 hours this year does not reduce next year’s requirement.
- Compliance is confirmed to the SFC. Licensed corporations, ROs and representatives confirm compliance, or explain any non-compliance, in the annual return.
With the deadline in view, the practical step now is to count what each person has completed this year and book the remaining hours before the December holidays.
What happens if you fall short
The SFC states that failing to meet the applicable CPT requirements will cast doubt on an individual’s fitness and properness to remain licensed, and may lead to disciplinary action. A shortfall can also raise questions about the firm’s internal controls during an inspection.
If a shortfall cannot be avoided, explain it in the annual return and make up the hours as soon as possible. How quickly the gap is closed will affect how the SFC views it.
Records you need to keep
Both the individual and the firm should keep sufficient records of CPT activities for at least three years. In practice that means:
- Certificates or attendance records showing the course title, date and duration.
- Evidence of assessment for online or self-study courses.
- A note of which hours count towards the regulated activities, ethics and compliance categories.
Firms should hold a central record for each licensed person so that compliance can be confirmed quickly at the year end and records produced if the SFC asks.
Completing your hours online with Heinbro
Our Online Training platform lets licensed representatives and ROs complete outstanding hours on demand, on any device, with no software to install. Each course carries one CPT hour and ends with an automatically marked assessment. Learners receive a certificate and signed attendance record as soon as they finish, and firms can follow each employee’s CPT record through a digital portal.
For firms preparing for an SFC inspection, we also run mock audits. Our guide to SFC mock audits explains why it pays to run one before the regulator does.
Frequently asked questions
How many CPT hours does a Responsible Officer need each year?
A Responsible Officer needs at least 12 CPT hours each calendar year. This includes two additional hours on regulatory compliance, at least five hours directly relevant to the regulated activities and at least two hours on ethics or compliance. The one-off ethics hours for new joiners do not count towards the two additional hours.
What is the CPT deadline?
CPT runs on the calendar year, so the deadline is 31 December. Hours completed in January count towards the new year. Licensed corporations, Responsible Officers and licensed representatives then confirm compliance, or explain any shortfall, to the SFC in their annual return.
Can extra CPT hours be carried forward to next year?
No. The SFC guidelines state that excess CPT hours accumulated in one calendar year cannot be carried forward to the following year. Each year’s requirement has to be met with hours completed in that year, so it is better to spread training across the year than to front-load it.
Do I need full CPT hours if I was licensed part way through the year?
Not necessarily. For someone first licensed during the year, the SFC allows the annual requirement to be applied pro rata to the period licensed. New joiners must still complete two hours on ethics within their first 12 months, so check both requirements.
What records do I need to keep?
Keep certificates or attendance records showing each activity’s title, date and duration, plus evidence of assessment for online courses. Both the individual and the licensed corporation should keep sufficient CPT records for at least three years, and be able to produce them if the SFC asks.
