Does the Business Registration Ordinance require me to keep accounting records?
Not directly. The Business Registration Ordinance deals with registering the business and notifying changes, such as a new business address or name, within one month. The duty to keep accounting records comes from the Companies Ordinance (for companies) and section 51C of the Inland Revenue Ordinance (for all businesses).
A common mix-up: owners hear "business registration" and assume it covers books and records. It does not.
What the Business Registration Ordinance does cover, according to the IRD:
- holding a valid business registration certificate;
- notifying the Business Registration Office in writing within one month of changes to business particulars (for example business name, nature of business or address);
- for partnerships, notifying admission or retirement of partners within one month. The IRD states that failure to notify is an offence with a maximum fine of HK$5,000 and imprisonment of one year.
Where the bookkeeping duty actually sits:
- Companies: Companies Ordinance (Cap. 622), s.373 for keeping records and s.377 for the seven-year retention.
- All businesses: Inland Revenue Ordinance (Cap. 112), s.51C.
If your business is registered but has no transactions yet, you should still set up a simple record system from day one so the first transaction is captured properly.
Legal basis
- Business Registration Ordinance (Cap. 310)
- Inland Revenue Ordinance (Cap. 112), s.51C
- Companies Ordinance (Cap. 622), s.373
Sources
Applies to 2026 · Last reviewed 29 October 2026
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.
Related questions
- How do I choose the financial year end for a new Hong Kong company?Directors can specify the first (primary) accounting reference date, as long as it falls within 18 months after incorporation. If no date is specified, the default is the last day of the month in which the first anniversary of incorporation falls. Choose a date that suits your business cycle and workload.
- What is a chart of accounts and how should a small Hong Kong business set one up?A chart of accounts is the numbered list of categories your ledger uses: assets, liabilities, equity, income and expenses. Keep it short, consistent and aligned to the statements you must produce. Separate accounts for director loans, MPF, tax and foreign-currency balances make year-end work easier.
- What accounting should I set up when I start a new Hong Kong company?Open a company bank account, choose your financial year end within 18 months of incorporation, set up a ledger or software with a clear chart of accounts, and start filing documents from day one. Appoint someone to keep the books, and arrange an auditor and an accountant early.
- What is the difference between bookkeeping and accounting in Hong Kong?Bookkeeping is the day-to-day recording of transactions: sales, purchases, payments and receipts. Accounting uses those records to prepare financial statements, interpret results and support tax and audit work. In Hong Kong the law cares about both: the company must keep adequate records, and its directors must prepare financial statements from them.
- Is a Hong Kong company legally required to keep accounting records?Yes. Section 373 of the Companies Ordinance (Cap. 622) requires every company to keep accounting records that explain its transactions and show its financial position and performance at any time. Directors who fail to take all reasonable steps risk a fine of HK$300,000, and up to 12 months' jail if the failure is wilful.