Does the audit cover the Significant Controllers Register?
Not as a stated part of the audit report. The Significant Controllers Register is a separate Companies Ordinance duty of the company. Auditors may still ask who owns and controls the company when assessing related parties and client acceptance.
What the register is Hong Kong companies must keep a register of people with significant control over the company. It is a company duty, kept at the registered office or another place in Hong Kong (notified to the Registrar if it is not the registered office), and not an audit document. A person holding more than 25% of the issued shares, directly or indirectly, is a significant controller.
How it can come up in an audit
- Ownership and related parties: the auditor needs to know who controls the company to identify related-party transactions and disclosures.
- Client acceptance: auditors collect ownership details as part of their own anti-money laundering checks (see the AML answer).
- Representations: management is asked to confirm that related parties have been identified.
Legal basis The register comes from Part 12 of the Ordinance and Schedule 5A, added by the Companies (Amendment) Ordinance 2018 (in force from 1 March 2018). The company enters each significant controller's particulars, or states that there is none, and appoints a designated representative to assist law enforcement officers. The auditor's report duties in ss.405-407 cover the financial statements, the directors' report and the accounting records, not the register. The Companies Registry's FAQ and guideline set out the detailed duties.
Practical tip Keep the register up to date and consistent with the members' register and the annual return. Giving the auditor a consistent picture of ownership avoids queries.
An audit does not replace compliance with the register rules.
Legal basis
- Companies Ordinance (Cap. 622), Part 12 and Schedule 5A
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
- Do I need consolidated accounts if my Hong Kong company has subsidiaries?A holding company must normally prepare consolidated statements and have them audited. There are exceptions for wholly owned subsidiaries and, with notice, partly owned ones, and for reporting-exempt groups, which may exclude some subsidiaries.
- Why does my auditor ask for ID and source-of-funds information?Audit firms are regulated for anti-money laundering and counter-terrorist financing, and AFRC inspects firms' compliance. Firms therefore verify who owns and controls a client before accepting it, which is separate from the audit tests.
- Does every Hong Kong limited company need an audit?Yes. Every Hong Kong company must have an auditor for each financial year and its financial statements audited, whatever its size or whether it trades. The only company that escapes is a qualifying private company that has validly become dormant under s.5 and s.447 of the Companies Ordinance.
- Why does Hong Kong require even a small private company to be audited?Hong Kong's Companies Ordinance makes audit a universal requirement for companies, because an independent report on the accounts protects members, creditors, lenders and the tax authority. Small companies get simpler reporting rules, not an audit exemption.
- Do I still need an audit if my company had no revenue or no business activity?Yes, unless the company has formally become dormant. Having no sales does not make a company dormant in law. If it had any expenses, bank charges or other recorded transactions, the audit duty continues for that year.