New Obligation for Hong Kong Companies

From March 1, 2018, each Hong Kong company has to maintain a newly-created “Significant Controllers Register” (SCR).
The purpose is to enhance the transparency of corporate ownership and control as per the HK Companies (Amendment) Ordinance 2018.


If you have a HK company, you will need to take these actions by March 30, 2018:


1. Identifying the Significant Controller(s)

This can be:

  • a natural person
  • a legal entity (corporate shareholder of the Hong Kong company)

that has any of the below:

  • more than 25% of company’s issued shares OR voting rights
  • the right to appoint or remove company’s directors
  • the right to exercise significant influence over the company OR over the activities of a trust


2. Appointing a Designated Representative

Each company has to appoint one person as its representative to provide assistance relating to the SCR. Designated representative must be one of the following:

  • shareholder, director or employee of the company who is a natural person resident in Hong Kong; OR
  • licensed company service provider, Hong Kong registered solicitor or accountant


3. Creating the SCR:

This record contains the significant controller’s particulars, and must be maintained accurately.

Please note the consequences for non-compliance of the above are:

  • the company and every responsible person are liable to a fine of HKD25,000
  • in case of continuing offence, a daily fine of HKD700.

Fiducia’s Hong Kong Corporate Services Team can assist you with handling these changes. Please contact us so that we may share further details.