Implementation of New Unique Business Identifier (UBI) for Hong Kong Companies

Last Updated on 4 January 2025

The Hong Kong Companies Registry has recently implemented a new system called the Unique Business Identifier (UBI) for all entities under the administration of Hong Kong’s Registrar of Companies.

This system aims to enhance the identification of legal entities involved in various transactions and regulatory interactions.

By adopting the Business Registration Number (BRN) of the company or entity, the UBI system reduces errors caused by different identifiers and facilitates communication and data exchange across government departments and businesses.

Affected Companies and Entities

The implementation of the UBI system is being rolled out in two phases. The first phase, which started on November 1, 2021, covered limited partnership funds. The second phase, effective December 27, 2023, includes the following companies and entities:

• Companies incorporated or registered under the Companies Ordinance (Cap. 622)
• Open-ended fund companies incorporated or registered under Part IVA of the Securities and Futures Ordinance (Cap. 571)
• Limited Partnerships registered under the Limited Partnerships Ordinance (Cap. 37)
• Registered Trustees incorporated under the Registered Trustees Incorporation Ordinance (Cap. 306)
• Other entities formed or registered under various Ordinances administered by the Registrar

The UBI of a Company or Entity

For existing companies or entities that were incorporated or registered before December 27, 2023, their UBI will be their existing tax identification number (BRN).

This refers to the first eight digits of the Business Registration Certificate number assigned by the Business Registration Office of the Inland Revenue Department (IRD).

For new companies incorporated or registered on or after December 27, 2023, their UBI number will also be their BRN, which will be stated on the Certificate of Incorporation or the Certificate of Registration of a Non-Hong Kong Company issued by the Companies Registry.

In cases where companies or entities incorporated or registered before December 27, 2023, do not have a BRN (such as companies exempted from registration under the Business Registration Ordinance), the Registry has assigned a ‘dummy’ BRN with an alphabetic prefix.

It’s important to note that these companies or entities do not have business records in the Business Register maintained by the IRD and should not use the dummy BRN for business registration documents or duplicates of a valid business or branch registration certificate.

Usage of the UBI

The BRN will continue to serve as the tax identification number for Hong Kong companies and will also be used in the following ways:

• Printed on certificates of incorporation, registration, and change of name issued by the Companies Registry
• Quoted on specified forms and documents submitted to the Companies Registry, replacing the existing Company Registration Number (CRN)
• Used for searching and identifying a company or entity across different services provided by the Companies Registry

Evidence of the Change in Identification Number

The Companies Registry has issued a letter to each company prior to the implementation of Phase 2 of the UBI system, informing them of the change and their BRN. Sovereign has forwarded these letters to clients upon receipt.

Shortly after December 27, 2023, the Companies Registry will create an information sheet that provides evidence of the change to use the BRN as the identification number for every company or entity. This information sheet will be available for public inspection.

Companies can also apply for a Letter of Confirmation, which serves as additional evidence, after the launch of the Revamped Integrated Companies Registry Information System (ICRIS). Sovereign can assist clients in applying for a Letter of Confirmation at an additional cost.

The Revamped Integrated Companies Registry Information System (ICRIS)

As of December 27, 2023, the Companies Registry has revamped the ICRIS and introduced a new e-Services Portal. This portal allows users to access all electronic services provided by the Registry, including document submission and search services, at any time and from anywhere.

The UBI has replaced the previous Company Registration Number (CRN) as the identification number for all companies and entities under the administration of the Registrar of Companies.

The electronic submission services previously available through the e-Registry and GovHK have been replaced by the electronic submission services provided through the e-Filing Services on the new e-Services Portal.

To facilitate the launch of the revised ICRIS, the Registrar of Companies has specified the requirements for delivering documents in electronic form or other forms for registration under various ordinances.

Conclusion

The implementation of the Unique Business Identifier (UBI) system in Hong Kong aims to enhance the identification of legal entities and improve communication and data exchange across government departments and businesses.

The UBI, based on the Business Registration Number (BRN), will serve as the tax identification number for companies and entities, replacing the previous Company Registration Number (CRN).

Companies and entities should familiarize themselves with the new system and ensure compliance with the requirements set by the Companies Registry.