Hong Kong (HK)

Jurisdiction Overview

IDQuestionAnswer
471 *BO Record: Does the registration of domestic companies comprise beneficial owner's identity information? No. Companies available without recorded beneficial ownership information.
 Data Date: 2019

Notes

 
While under the Companies Ordinance (Cap. 662, last updated 2019), all companies except those that are listed on the Hong Kong stock exchange must keep a register of beneficial owners (significant controllers), such registers are held by individual companies and the data is not centralised or filed with a public authority. Indeed, the law "requires every company incorporated in Hong Kong, except for listed companies which are subject to separate disclosure requirements under the SFO [Securities and Futures Ordinance], to obtain and maintain up-to-date beneficial ownership information by keeping a SCR [Singificant Controllers Registry]. The information is not further compiled in a central register but remains with each company" (GF 2019: 39 [TJN-note]). Otherwise, the significant controller registers require companies to identify beneficial owners over the threshold of 25% and those persons that have significant control through other means (GF 2019: 40). Thus, although beneficial ownership information may be recorded at company level, such records may be held in paper format (see Guideline on the Keeping of Significant Controllers Registers by Companies 1.3.1), and are not directly accessible/searchable by public authorities.

Sources

GF 2019: 39-42; Companies Ordinance (Cap. 622, as amended August 2019): 653A-653ZK; Guideline on the Keeping of Significant Controllers Registers by Companies (1 March 2018): 1.3.1
 
https://www.cr.gov.hk/en/publications/docs/Guidelines_scr_e.pdf
 
https://www.elegislation.gov.hk/hk/cap622!en