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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.

Section 373 sets the duty. The records must be good enough to:

  • show and explain the company's transactions;
  • disclose, with reasonable accuracy and at any time, its financial position and financial performance; and
  • let the directors check that the financial statements comply with the Ordinance.

The duty applies to every company, including one with no trading, one that is exempt from audit, or one that is dormant. It sits with the directors, not with an outside bookkeeper or the company secretary, although directors can delegate the work.

Separately, anyone carrying on a business in Hong Kong, including sole proprietors and partnerships, must keep records of income and expenditure under section 51C of the Inland Revenue Ordinance so that assessable profits can be worked out.

A company's duty is not met by keeping bank statements in a drawer. The records should be organised so that a director, auditor or the IRD can follow any entry back to its source document.

  • Companies Ordinance (Cap. 622), s.373
  • Inland Revenue Ordinance (Cap. 112), s.51C

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.

    Is a Hong Kong company legally required to keep accounting records? | OCTIS