This depends on the circumstances. When assessing a licence application or renewal, the regulator will assess whether all the company’s directors are “fit and proper persons”. If a director’s criminal record involves dishonesty, fraud, or offences related to medicines or public safety, the regulator is highly likely to consider that director not to be a “fit and proper person”. This may directly result in a new licence application being refused or cause problems with renewal of an existing licence. The impact may be smaller if the record relates to a minor offence unrelated to the company’s business or integrity, such as a minor traffic offence.
HONG KONG DRUG LICENSING
Can a person with a criminal record be a director of a company that holds a pharmaceutical 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.
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