Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
Hong Kong pharmaceutical compliance · applications / acquisitions / ongoing maintenance Independent Third-Party Service Provider
HONG KONG DRUG LICENSING

During the licence application process, if there is a change of director or shareholder in my company, do I need to notify the Department of Health?

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

Q220 · Category E: Application Process and Approval Procedures (Q201-Q250)
Yes, this is absolutely required. Throughout the licence application process, you have an ongoing responsibility to ensure that all information submitted to the Department of Health is up to date and accurate. The company's director and shareholder structure is an important factor in the regulatory authority's assessment of whether the applicant is “fit and proper”. Therefore, as soon as there is any appointment or resignation of a director, or a significant change in the shareholding structure (for example, a change of controlling shareholder), you must proactively notify the Drug Office, Department of Health, in writing. You will need to submit the relevant company resolutions, the latest forms filed with the Companies Registry (such as ND2A and NSC1), and identity documents and CVs of newly appointed directors. The regulatory authority needs to carry out the same background checks on new directors or shareholders.

📘 Regulatory basis

Although no law expressly prescribes change notifications “during the application period”, this follows naturally from the fundamental legal obligation to provide true, accurate and complete information. After a licence is issued, the Wholesaler’s Code of Practice expressly requires the licence holder to notify the Department of Health of changes to key personnel and company structure.

📗 Drew Tang's recommendations

We recommend that clients keep their company structure as stable as possible during the application period. If a change is necessary, please notify us immediately. We will guide you in preparing the notification documents and communicate with the Department of Health as professionally as possible, explaining the background and reasons for the change to minimise any potential disruption to the application timetable. We will ensure that the entire process is transparent and compliant.

📕 Risk notice

Failure to disclose is the greatest risk. If the Department of Health discovers through other channels, such as public information from the Companies Registry, that your company structure has changed and you have not notified it, this will be regarded as a serious lack of integrity. The regulator may question your reliability, leading at best to stringent scrutiny and significant delays, and at worst to your application being refused outright. Do not take any chances.

Back to Category E: Application Process and Approval Procedures (Q201-Q250) Search more questions

YOUR NEXT STEP

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

Book a Project Assessment ↗