Country-specific guidance Current
Requesting beneficial ownership information from a corporate client
What to ask for, since the register itself isn't public.
A Hong Kong company's significant controllers register isn't open for public inspection, so you generally can't just look this information up. This guide sets out what to ask a corporate client for directly. It is general information, not legal or compliance advice.
Action plan
1 Ask who holds significant control, using the statutory thresholds "Beneficial owner" isn't a vague concept here; Hong Kong law sets specific tests for it.
Under the Companies Ordinance, a person or entity has significant control over a Hong Kong-incorporated company (other than a listed company) if they hold, directly or indirectly, more than 25% of the issued shares or voting rights, hold the right to appoint or remove a majority of the board, or otherwise have the right to exercise, or actually exercise, significant influence or control. Ask the corporate client to identify every person or entity meeting one of these tests, not just the largest shareholder.
- Ask for anyone holding more than 25% of shares or voting rights, directly or indirectly
- Ask about board-appointment rights and any significant-influence arrangement, not just shareholding
- Don't assume the largest named shareholder is the only significant controller
Done when: Every person or entity meeting a significant-control test has been identified from the client, not assumed
Companies Registry: Significant Controllers Register FAQ2 Request the company's designated representative details The designated representative is the client's own nominated contact point for the register.
A Hong Kong company keeping a significant controllers register must appoint a designated representative to act as the contact point for authorities regarding that register. Asking a corporate client for this person's name and contact details, alongside the significant controller information itself, is a useful cross-check that the client's own register is actually being maintained.
- Ask the client to name their designated representative for the significant controllers register
- Treat this as a signal the client's own register is being kept, not a formality
- Follow up if the client can't identify a designated representative
Done when: The corporate client has provided its designated representative's name and contact details
3 Don't assume you can look this up instead of asking The significant controllers register is not open for public inspection.
Unlike some other company records, a Hong Kong company's significant controllers register is not open for public inspection. That means your firm generally can't substitute a registry search for asking the client directly. Build the direct request into onboarding rather than assuming a search will surface it.
- Treat a direct client request as the primary route to significant controller information
- Don't rely on a public company search to surface significant controller details
- Escalate internally if a corporate client is reluctant to provide this information
Done when: The firm requested significant controller information directly from the client rather than relying on a public search
See the Significant Controllers Register requirements overview