In this course · 5 of 6
Course 4
Choose your auditor
6 lessons · 6 min
- 1Who is allowed to audit a Hong Kong company?
- 2What is the difference between AFRC and HKICPA for auditors?
- 3How do I check that my auditor is properly registered in Hong Kong?
- 4Can an overseas auditor audit my Hong Kong company?
- 5Who is disqualified from being the auditor of my company?
- 6Can the same firm do my bookkeeping, tax and the audit?

The short answer
A Hong Kong company cannot appoint as auditor any officer or employee of the company, or a partner or employee of such an officer or employee. The same applies to people disqualified for a parent or subsidiary. Professional ethics rules add further independence limits.
Statutory disqualifications (s.393(2)) A person cannot be appointed auditor if they are:
- An officer or employee of the company.
- A partner or employee of an officer or employee of the company.
- Someone who is disqualified in that way for a parent or a subsidiary undertaking of the company, or for a subsidiary of that parent.
An auditor is not counted as an "officer or employee" just because they are auditor.
If it happens after appointment The auditor immediately ceases to hold office and must notify the company in writing within 14 days (s.418). Failing to do so is an offence, with a defence for someone who neither knew nor had reason to believe they had become disqualified.
Ethics rules (HKICPA Code of Ethics) The Code, which AFRC oversees, adds independence rules beyond the statute. For audits of public interest entities (listed and similar companies), a person who has been engagement partner for seven cumulative years must then stay off the audit for five consecutive years (three for the engagement quality reviewer, two for other key audit partners; Section 540). For other companies the firm must judge long-association threats and consider safeguards such as rotating staff off the team. The Code also covers self-review threats and inducements.
For owners Do not appoint a relative who is also an officer or employee, and do not let the audit firm's staff take a role in the company.
Legal basis and sources
The law
- Companies Ordinance (Cap. 622), s.393
- Companies Ordinance (Cap. 622), s.418
- HKICPA Code of Ethics for Professional Accountants
Official sources
- Companies Ordinance (Cap. 622), s.393 – e-Legislation
- Companies Ordinance (Cap. 622), s.418 – e-Legislation
- Companies Ordinance (Cap. 622) – full text, Companies Registry
- HKICPA Code of Ethics for Professional Accountants (revised to December 2023), Section 540
- HKICPA A Plus – Revised Code of Ethics: key areas of focus for auditors
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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