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HONG KONG DRUG LICENSING

Is there a minimum registered capital requirement when applying for a 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

Q218 · Category E: Application Process and Approval Procedures (Q201-Q250)
Neither Hong Kong company law nor pharmaceutical regulations set a specific minimum share capital for a company applying for a drug licence. The Hong Kong Companies Registry permits a company to be incorporated with very low share capital (for example, HKD 1). From a legal perspective, the amount of the company’s share capital will not directly determine whether the PPB Committee approves or refuses the application. However, in commercial practice and from the perspective of regulatory scrutiny, a company with a reasonable and robust capital structure is more likely to demonstrate its commitment to long-term operations and ability to withstand risks. Very low share capital may raise some concerns for reviewing officers when they assess whether the company is a fit and proper licence holder. Therefore, although there is no statutory minimum, it is prudent to set share capital at a reasonable level commensurate with the scale of your business.

📘 Regulatory basis

Neither the Companies Ordinance (Cap. 622) nor the Pharmacy and Poisons Ordinance (Cap. 138) prescribes minimum registered capital for a company applying for a drug licence. The PPB focuses on whether the applicant is “fit and proper”, which is assessed on a range of factors.

📗 Drew Tang's recommendations

We recommend that clients set a reasonable registered capital amount, such as HK$100,000 to HK$1,000,000, based on the initial investment and early operating funding requirements in their business plan. This not only signals capability to regulators, but also reflects your serious commitment to the business. We will present the company’s financial soundness as a strength in your application materials.

📕 Risk notice

Although low registered capital will not directly result in refusal, extremely low registered capital for your company, such as just 1 HKD, combined with a lack of other evidence of financial soundness, such as a bank reference or a financial support undertaking from shareholders, may count against you. In an application that is already borderline in other respects, this “last straw” may sometimes influence the Board’s final decision.

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