Who is allowed to audit a Hong Kong company?
Only a practice unit can be appointed as auditor of a Hong Kong company: in practice a certified public accountant (practising) or a CPA firm or corporate practice registered with the Accounting and Financial Reporting Council. An employee or officer of the company cannot be its auditor.
Eligibility (s.393) Only a practice unit is eligible to be appointed as the auditor of a company. The Companies Ordinance's s.393 sets disqualifications too (see the independence answer).
What this means in practice
- The auditor signs the report as a certified public accountant (practising), meaning a CPA who holds a practising certificate.
- Since 1 October 2022 the AFRC issues and renews practising certificates and registers practice units (CPA firms and corporate practices). HKICPA still registers CPAs and sets standards.
- The IRD's profits tax return asks whether a Hong Kong practice unit audited the accounts, and for the practising certificate number of the signing accountant, normally printed on the audit report.
What does not qualify
- A bookkeeper, tax agent or accounting service business that is not a registered practice unit.
- A CPA who does not hold a practising certificate.
- The company's own directors, officers or staff.
Check before you engage Search AFRC's public registers of practising CPAs and practice units, and ask for the firm's practising certificate number. If the name is not on the register, the audit would not satisfy the Ordinance.
Legal basis
- Companies Ordinance (Cap. 622), s.393
- Professional Accountants Ordinance (Cap. 50)
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 check that my auditor is properly registered in Hong Kong?Search the public registers kept by the AFRC for practising CPAs and for registered practice units, and ask the firm for the signing accountant's practising certificate number. The number is normally printed on the audit report.
- 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.
- My company is loss-making. Do I still need to audit it?Yes. Profit or loss has no bearing on the audit requirement. A loss-making company is audited every year, and the auditor will also look closely at going concern.