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Can someone who was a director of a company whose pharmaceutical licence was revoked serve as a director of a new applicant company?

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

Q146 · Category C: Eligibility and Personnel Requirements (Q101-Q150)
This situation will be subject to very stringent scrutiny, and the chances of success are slim, but it is not absolutely impossible. If a person has served as a director of a company whose licence was revoked, the PPB will conduct an extremely thorough investigation when assessing their eligibility to serve as a director of a new company. The PPB will focus on the following points: 1) What were the specific reasons for the company’s licence being revoked? Did they involve serious dishonesty or a significant threat to public health? 2) What role did the director play in the events leading to the revocation? Did they actively participate, knowingly fail to report the matter, or genuinely have no knowledge of it while fulfilling their duties as a director? 3) Has the director shown any reflection or improvement since the events? They must be able to provide highly persuasive evidence that they have learned significant lessons and that the new applicant company has established robust checks and oversight mechanisms to prevent a recurrence.

📘 Regulatory basis

This is a typical case in a “fit and proper person” assessment. Past regulatory breaches are an important basis for assessing the risk of future conduct. The PPB’s primary duty is to protect the public, so it takes an extremely cautious approach to applicants in such cases.

📗 Drew Tang's recommendations

If this happens, your only hope lies in complete candour and compelling evidence. The applicant must prepare an extremely detailed statement explaining the events and their own responsibility. The new company's business plan and compliance framework must also be beyond reproach. Even so, you should be prepared for the application to be rejected. In many cases, replacing the director is the wiser choice.

📕 Risk notice

If the reason for licence revocation involves serious issues such as fraud or deliberately endangering the public, it is almost impossible for the relevant directors to pass the PPB's “fit and proper person” test again. Attempting to excuse such a history may be viewed as a lack of remorse and make the situation worse.

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