No. Regulatory background checks are targeted and focus mainly on people with key responsibilities for the company’s operations and compliance. You do not need to submit details of every employee. Those generally required to provide detailed personal information and undergo a “fit and proper person” assessment include: 1) all company directors; 2) the company’s ultimate beneficial owner (UBO); 3) nominated key personnel, such as the RP for a wholesaler or manufacturer, an Authorised Person (AP) and the person in charge of quality control; and 4) the pharmacist-in-charge of a pharmacy. Personal details of non-key staff, such as warehouse operators, sales representatives and general clerical staff, do not need to be submitted to the regulatory authority at the licence application stage.
HONG KONG DRUG LICENSING
When applying for a pharmaceutical licence, must I submit the personal details of all employees for background checks?
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.
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