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Keep your books · Course 3 · Lesson 7 of 7

Who can use HKFRS for Private Entities in Hong Kong?

  • 1 min read
  • Checked 29 October 2026
In this course · 7 of 7
Otty, the OCTIS octopus

The short answer

Any Hong Kong entity without public accountability (one whose debt or equity is not publicly traded and which does not hold assets for outsiders as a primary business) that publishes general purpose financial statements can use HKFRS for Private Entities. There is no size test. Banks, insurers and securities brokers are excluded; a subsidiary with no public accountability of its own can use it.

HKICPA's FAQ sets out the key points:

  • Core test: the entity must not be publicly accountable. Public accountability arises if its debt or equity is traded in a public market, or if it holds assets for a broad group of outsiders as a primary business.
  • Excluded: publicly traded entities of any size, and financial institutions: banks, insurers, securities brokers or dealers, pension funds, mutual funds and investment banks.
  • Not automatically excluded: companies limited by guarantee, unlimited companies, and not-for-profit organisations. Each depends on its facts. Company status under the Ordinance is not the only test.
  • Holding client money incidentally to the main business does not by itself create public accountability. The FAQ gives solicitor firms and charities as examples.
  • Subsidiaries: a subsidiary of a group reporting under HKFRS or IFRS may use the standard if it has no public accountability itself.
  • No shareholder approval is needed to adopt it, according to the FAQ.

Unlike the SME-FRF, there is no size or company-type threshold. HKICPA revises the standard from time to time, so use the edition in force for your financial year.

Legal basis and sources

The law

  • Companies Ordinance (Cap. 622), s.380 (accounting standards)
  • HKICPA: HKFRS for Private Entities

General information for business owners, not legal, tax or professional advice. Rules change, so check the sources or ask a licensed professional before you act.

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    Who can use HKFRS for Private Entities in Hong Kong? | OCTIS