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Must any member of the board of directors of a company applying for a pharmaceutical licence have a medical or pharmaceutical background?

A complete explanation of the regulatory basis, Drew Tang’s recommendations and risk alerts. The original material dates from 2025; read it alongside the latest official requirements.

Original guide, 2025 edition: These FAQs are provided for topic-based reference and have not all been individually checked against current rules. Please confirm fees, personnel, renewal, changes and product requirements against the professional in-depth guide for the relevant licence type and the official requirements in force at the time.

Drug Office, Department of Health Chinese Medicines Board

Q120 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
There is no explicit legal requirement for a company’s board of directors to include members with medical or pharmaceutical backgrounds. The applicant is the corporate entity, and the regulator’s core requirement is that the company engages qualified key technical personnel, such as a Responsible Person (RP), registered pharmacist and Authorised Person (AP), who are responsible for and supervise licensed activities. However, from the perspective of corporate governance and risk management, having a board member with a relevant professional background is undoubtedly an advantage. It signals to the regulator that the company’s senior decision-makers can understand and assess the risks specific to the pharmaceutical industry and are better placed to support and oversee the company’s compliant operations.

📘 Regulatory basis

The Pharmacy and Poisons Ordinance focuses on the qualifications of professionals involved in operations, rather than the composition of the board of directors. However, when assessing a company’s overall “suitability”, the PPB may consider its governance structure; the board’s professional competence is one qualitative indicator.

📗 Drew Tang's recommendations

If most members of your board lack a pharmaceutical background, we recommend considering the establishment of a “scientific or compliance advisory committee” comprising external experts, such as experienced pharmacists, doctors or industry consultants. This can provide the board with professional decision-making support and demonstrate to the regulatory authority, when applying for a licence, the company's commitment to professional standards.

📕 Risk notice

A board made up entirely of people with commercial or financial backgrounds may prompt the regulator to question its ability to manage the risks of a pharmaceutical business, if the application materials and business plan do not clearly explain how the board will manage and oversee the specialist technical team. This will not directly result in a refusal letter, but may lead to further and more in-depth enquiries.

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