Where Must a Hong Kong Company Keep Its Accounting Records?

Section 374 of the Companies Ordinance covers location:

• Records must be kept at the registered office or any other place the directors think fit, and be open to inspection by the directors at all times without charge.
• If records are kept outside Hong Kong, the accounts and returns about the business dealt with in them must be sent to, and kept at, a place in Hong Kong, again open to the directors' inspection.
• Those accounts and returns must disclose the financial position with reasonable accuracy at intervals of not more than 6 months, and must be enough to let directors ensure the financial statements comply with the Ordinance.

Directors who fail to take all reasonable steps commit an offence carrying a fine of HK$300,000, and a fine plus 12 months' imprisonment if wilful.

This matters for overseas owners and groups that run bookkeeping from another country or cloud service. The records can be kept abroad, but a Hong Kong set of accounts and returns at least every six months is still required. Electronic records stored on a cloud service should still be reproducible in readable form in Hong Kong.