[Nov 2023 Update] Adopting The BRN As The New Unique Business Identifier For Hong Kong Entities

On 27 October 2023, the Company Registry officially announced the initiation of the Unique Business Identifier (UBI) across various entities under the administration of the Registrar of Companies.

This marks the initiation of the second phase of UBI implementation, set to commence on 27 December 2023. From this point onward, the Business Registration Number shall be completely adopted as the Unique Business Identifier for entity identification purposes.

What is the Unique Business Identifier?

The Unique Business Identifier (UBI) is a distinct number used to identify legal entities. This system has been adopted in many other economies (e.g., Singapore, New Zealand, Canada, Philippines, etc.) to reduce miscommunication caused by using different identifiers across international jurisdictions.

By implementing the Business Registration Number (BRN) as the UBI for Hong Kong entities under the Registrar of Companies, the government aims to facilitate better communication and data exchange between government departments and businesses.

As part of its commitment to maintaining Hong Kong’s status as a leading global financial center, the Companies Registry divided the UBI into two phases. Notably, the first phase has already been in effect from 1 November 2021, concerning Limited Partnership Funds.

Which entities are subject to this adoption?

Following the Companies Registry’s announcement, the second phase of UBI will cover limited companies and entities as follows:

• Companies incorporated or registered under the Companies Ordinance
• Open-ended fund companies incorporated or registered under the Securities and Futures Ordinance
• Limited partnerships registered under the Limited Partnerships Ordinance
• Registered trustees corporations incorporated under the Registered Trustees Incorporation Ordinance; and
• Other entities formed or registered under Ordinances administered by the Registrar of Companies.

What key roles will the BRN hold as the new UBI?

Following the implementation of the second phase, the Business Registration Number shall be:

• Displayed as the “No.” on essential documents, such as the Certificate of Incorporation; Certificate of Registration; or Certificate of Change of Name;
• Mentioned on specified forms and documents delivered to the Registry in place of the existing Company Registration (CR) Number; and
• The main identification for business entities under different services of the Registry.

In brief, the BRN will function as the unique identifier for communication with the government and external entities.

How does this update affect existing businesses?

Companies incorporated or registered before 27 December 2023 under the aforementioned ordinances, including the Companies Ordinance, do not need to take any actions to comply with this change. Instead, the Registry will send a letter to the entity’s reported address, confirming the replacement of the current CR number with the BRN.

Please note that currently-in-use certificates will not be reissued by the Registry.

In addition, for existing companies without a BRN (e.g., those exempted from registration under the Business Registration Ordinance), a dummy number converted from the former CR number will become the new UBI.

How to search for the corresponding BRN of a company

Starting the implementation date of the second phase on 27 December 2023, the Companies Registry’s Electronic Search Services will include a new function designed for this purpose.

This feature shall allow users to search for the relevant entity’s BRN, or UBI, through the former Company Registration Number and vice versa.

Explore BBCIncorp’s site for additional updates and details on the adjustment, or reach out to us at service@bbcincorp.com if you have any further inquiries about doing business in Hong Kong. Our support team is ready to offer the help you need.