Hong Kong has long been famous for its business-friendly environment and simplified company setup process. However, compliance with the local legislation is just as crucial as the registration of your company. One of the key requirements is the upkeep of a Significant Controllers Register (SCR)—a tool aimed at improving corporate transparency.
The Register of Significant Controllers is part of the compliance landscape that helps to prevent money laundering and enhance transparency in business dealings.
In this blog, we will show you how to register an SCR in Hong Kong. We will cover what information you need to supply, who is a material controller, and why this is important to your company.
What is a Significant Controller Register?
The Significant Controllers Register (SCR) is a statutory record that captures the individuals or entities who have significant control over a Hong Kong company.
Legal Reasons
The obligation to keep an SCR started on 1 March 2018 beneath the Companies Ordinance (Cap. 622).
Why It Was Created
The SCR was established to bring Hong Kong in line with international regulations on transparency and to enhance its anti-money laundering (AML) efforts.
Who Needs to Keep an SCR?
All Hong Kong companies, both private and guarantee companies, are obliged to keep an SCR—except for companies listed on the Hong Kong Stock Exchange.
Who is a Significant Controller?
An important controller can be either:
- A natural person (individual), or
- A legal person (e.g., another company)
…who is:
- More than 25% of shares (directly or indirectly)
- Over 25% of the right to vote
- The power to appoint or dismiss most of the board of directors
- Significant influence or control over the company’s decisions
What information needs to be recorded in the SCR?
Your SCR should contain:
- Full name, ID card/passport number (for individuals)
- Company name, registration number, and registered office (for companies)
- Type of control (e.g., ownership, voting rights, board influence)
- Date the person/entity became a significant controller
- Details of the chosen representative (who deals with law enforcement inquiries)
Five Simple Steps to Prepare the Significant Controllers Register
Here is a quick guide to assist you in planning your SCR:
1: Determine Your Significant Controllers
Verify your company structure to see who meets the requirements.
2: Serve Notices to Potential Controllers
Tell every person or organization you think is a major controller. They have responsibility to reply with the right information.
3: Gather and Confirm Information
Collect the necessary company or personal details and see the kind of control you possess and since when you have been a controller.
4: Choose a Representative
This person (or licensed practitioner) will be the key contact for law enforcement. He or she should be:
- A director, employee, or member of a company; OR
- A registered legal/accounting practitioner or TCSP licensee
5: Keep the SCR at the Registered Office.
Keep a hard copy of the SCR at your registered office or a place stated in Hong Kong.
6: Present the SCR for Inspection
The SCR must be easily accessible to police officers whenever it is necessary, but not to the public.
Final Reflections
Maintaining a Significant Controllers Register is not just a process—a requirement under the law of Hong Kong. Failure to comply can result in fines up to HK$25,000 and penalties for each day of non-compliance.
By following the process described in this guide, you can keep your company in line with the rules and avoid problems.
If in doubt, you can hire a TCSP licensee or company secretary to help you with your compliance needs.
You may discuss with FastLane HR for assistance in searching and recruiting individuals for key positions such as company secretary. This can go a long way in helping your business develop.