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If a company holding a pharmaceutical licence undergoes a major shareholding change, such as being acquired by another company, must it reapply for the licence?

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

Q143 · Category C: Eligibility and Personnel Requirements (Q101-Q150)
This depends on the circumstances, but a completely new application is generally not required; instead, strict notification and approval procedures must be followed. When a licensed company undergoes a major shareholding change or transfer of control, the legally licensed entity (that is, the company as a legal person) remains unchanged, so the licence itself remains valid. However, the company must immediately notify the Drug Office, Department of Health, in writing of this major change. The new major shareholders, directors and ultimate beneficial owners must submit their personal particulars to the Pharmacy and Poisons Board (PPB) and undergo a “fit and proper person” assessment. The PPB must be satisfied that, under the new control, the company can and will continue to comply with all licence conditions. In some cases, if the PPB has concerns about the new shareholders’ background or intentions, it may impose additional licence conditions or conduct inspections more frequently.

📘 Regulatory basis

Licence conditions generally require notification to the regulator of any significant change that may affect the company’s control. This is to ensure that the PPB can continue to discharge its statutory duty to supervise the ‘fitness’ of licence holders.

📗 Drew Tang's recommendations

Before any merger and acquisition or major share transaction, we strongly recommend that both buyer and seller make regulatory approval one of the key conditions precedent to completion. We will help the new shareholders prepare the full set of notification documents and proactively communicate with the Drug Office to explain the commercial rationale for the transaction and the future operating plan, with a view to securing a smooth approval process.

📕 Risk notice

“Act first and notify later”—that is, notifying the regulator only after completing a share transaction—is an extremely wrong and dangerous approach. It may be seen as disregard for regulatory requirements and could seriously call into question the integrity of the new management. In the worst-case scenario, if a new shareholder is found not to be a “Fit and Proper Person”, the PPB has the power to initiate licence revocation proceedings.

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