Can my company secretary do my accounts in Hong Kong
Yes, your company secretary can do your accounts, but they cannot then act as your statutory auditor due to independence rules.
Can My Company Secretary Do My Accounts in Hong Kong
Yes. A company secretary can provide accounting and bookkeeping services for the same Hong Kong company. The secretary cannot act as the statutory auditor. The Companies Ordinance (Cap. 622) does not prohibit a company secretary from preparing accounting records or financial statements. If the secretary also holds a TCSP licence under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), additional compliance obligations apply. The critical restriction is independence. The person who prepares the accounts cannot sign the audit report.
Company Secretary Accounting Services Hong Kong
A company secretary may lawfully offer company secretary accounting services Hong Kong businesses need for day-to-day record keeping and financial statement preparation. The secretary's statutory duties under Cap. 622 include maintaining the company's registers and filing returns, but nothing prevents the secretary from also handling bookkeeping, preparing management accounts, or drafting the financial statements that will be audited. Many Hong Kong companies appoint a corporate service provider that acts as both secretary and accountant, provided the audit function is separated.
TCSP Licence Accounting Services HK
A company secretary who provides TCSP licence accounting services HK must comply with the customer due diligence and record-keeping requirements under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). If the secretary is a licensed trust or company service provider, the accounting work falls within the scope of the licence. The secretary must identify and verify the beneficial owners of the company, maintain records of transactions, and report suspicious activity to the Joint Financial Intelligence Unit. Failure to comply is an offence carrying a fine of up to HK$100,000 and imprisonment for up to six months.
Company Secretary Bookkeeping HK
A company secretary performing company secretary bookkeeping HK must ensure the accounting records are sufficient to show and explain the company's transactions and to disclose its financial position with reasonable accuracy. The Companies Ordinance requires these records to be kept for seven years. The secretary may record the daily financial transactions, maintain ledgers, and prepare trial balances. However, the secretary cannot also be the practising certified public accountant who signs the statutory audit report, because the auditor must be independent of the company's management and officers. The HKICPA's ethical standards prohibit a person from auditing financial statements they have prepared.
The Audit Independence Rule
The statutory audit must be carried out by a practising certified public accountant registered with the HKICPA, and only a registered practice unit may sign a Hong Kong statutory audit report. If the company secretary has prepared the accounting records or financial statements, that secretary is not independent and cannot act as the auditor. The company must appoint a separate auditor, typically a different firm or a different practice unit within the same firm, to perform the audit. This separation applies regardless of whether the secretary holds a TCSP licence.
What to Do Next
If your company secretary will handle the bookkeeping and prepare the financial statements, confirm that a separate HKICPA-registered auditor will be appointed for the statutory audit. File Form ND2A with the Companies Registry to notify any change of company secretary. Ensure the secretary's TCSP licence is current if the secretary provides trust or company services to multiple clients. Keep the accounting records for seven years after the transactions.
Sources
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