Yes, the regulatory authority conducts a comprehensive and in-depth background review of applicant companies, going beyond the level of immediate shareholders. This is particularly relevant where the corporate structure is complex (for example, where several offshore companies hold shares through multiple tiers). The Drug Office, Department of Health, and the Pharmacy and Poisons Board (PPB) may require the applicant to disclose its full shareholding structure and identify the Ultimate Beneficial Owner (UBO). The regulatory authority will then carry out the same “fit and proper person” assessment of those UBOs, including reviewing their identity, financial position, business reputation and any criminal record. This is intended to prevent people from using complex corporate structures to conceal disqualifying status and circumvent regulation.
HONG KONG DRUG LICENSING
When applying for a pharmaceutical licence, does the background check on company shareholders extend to the ultimate beneficial owner (UBO)?
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.
Back to Category C: Applicant Eligibility and Personnel Requirements (Q101-Q150) Search more questions