How Hong Kong's UBI Simplifies Business for Foreign and Local Owners

Hong Kong has replaced its dual-identifier system with the Unique Business Identifier (UBI), making the 8-digit Business Registration Number (BRN) the single, primary ID for all companies for both tax (IRD) and corporate (CR) matters. The old 7-digit Company Registration Number (CRN) is now a legacy number, so businesses must update their records and use the BRN for all official filings and operations to ensure compliance.

BRN vs. CRN: The Ultimate Guide to Hong Kong’s New Unique Business Identifier (UBI)

Navigating Hong Kong’s dynamic regulatory landscape is a crucial step for any entrepreneur. A core part of this is understanding the key numbers that define your business’s legal and fiscal identity. For decades, this framework operated on a dual-system, with businesses juggling two important codes: the Business Registration Number (BRN) and the Company Registration Number (CRN).

However, a major transformation has streamlined this entire system. As of

December 27, 2023, the Hong Kong government officially launched the Unique Business Identifier (UBI) system, fundamentally changing how companies are identified. This reform officially adopted the familiar 8-digit BRN as the single, universal identifier for all companies and entities.

This means the CRN, once the primary legal identifier for incorporated companies, has been relegated to a legacy status. While the legal concepts of "business registration" and "company incorporation" remain distinct, the number you use to track and manage your company is now one and the same: the BRN.

This guide provides an exhaustive breakdown of this new framework. We’ll deconstruct the purpose of the BRN and the historical CRN, detail the mechanics of the UBI transformation, and offer a practical compliance guide for your business.

The Business Registration Number (BRN): Hong Kong’s Universal Business ID

The Business Registration Number (BRN) is the foundational identifier for every commercial activity in Hong Kong. Its importance goes far beyond tax, making it essential for the daily operations of every business, from a solo freelancer to a multinational corporation.

Who Issues the BRN and Why?

The BRN is issued by the Business Registration Office, a division of Hong Kong’s Inland Revenue Department (IRD). This is a critical point because it establishes the BRN’s primary purpose: identifying entities for tax compliance. The IRD's role is to track all profit-seeking activities in the region, a much broader scope than just incorporated companies. This universal reach is precisely why the BRN was chosen to become the UBI.

The legal requirement is set out in the Business Registration Ordinance (BRO), which defines a "business" as any activity carried on for the purpose of gain. This includes:

• Trades and commerce

• Craftsmanship and professions

• Individual freelancers and consultants

• Partnerships and corporations

• Clubs that provide facilities for a fee

  
  

Under the BRO, any person or entity must register their business with the IRD within one month of commencement. Failure to do so is a serious offense that can result in fines and even imprisonment.

A key rule under the ordinance is that every company incorporated in Hong Kong must obtain a BRN, "regardless of whether it is actually carrying on any business in Hong Kong". Unlike a sole proprietorship, which registers when it starts doing business, a limited company must register simply because it exists. This legal nuance treats a corporate vehicle as an instrument for business that must be on the IRD's radar from day one.

The Function and Format of the BRN

The BRN is a unique8-digit number (e.g., 12345678) with no letters or special characters. It serves several critical functions:

• Tax Identification Number (TIN): At its core, the BRN is your business’s tax ID. It’s the primary number used for filing annual Profits Tax Returns and all other correspondence with the IRD.

  
  

• Operational Necessity: You cannot run a business in Hong Kong without a BRN. It is essential for opening a corporate bank account, signing an office lease, applying for specific licenses, and entering into legal contracts.

  
  
  
  

• The New UBI: As of late 2023, the BRN is now also the UBI for all incorporated companies, used for all filings with the Companies Registry.

  
  

Upon registration, the IRD issues a Business Registration Certificate (BRC). This certificate displays your business name, address, nature of business, and the BRN. The BRN is the first eight digits of the "Certificate No." (e.g., 22222222-XXX-XX-XX-X) . A valid BRC must be displayed prominently at your principal place of business. The certificate must be renewed every one or three years by paying the required fee and levy.

The Company Registration Number (CRN): A Legacy Identifier

Before the UBI reform, the Company Registration Number (CRN) was the definitive identifier for incorporated companies. It was directly tied to the concept of a company having its own legal personality, separate from its owners.

Historical Role and Purpose

The CRN was issued by the Companies Registry (CR) under the authority of the Companies Ordinance. The CR’s job is to manage the incorporation, statutory filings, and dissolution of companies, focusing on corporate law and governance.

When a company was incorporated, it was granted a separate legal personality, meaning it could own property, enter contracts, and sue or be sued in its own name. The CRN was the unique identifier assigned by the CR to signify and track this distinct legal status.

Historically, the CRN was a 7-digit number that appeared prominently on the Certificate of Incorporation (CI)—the company's official "birth certificate". It was the primary reference number for all corporate filings, such as submitting Annual Returns or notifying the CR of changes to directors.

The historical separation of the CRN (for legal form) and the BRN (for economic purpose) was logical but created administrative inefficiencies. This division ultimately led to the UBI reform, a move toward integrated, modern regulation.

The Big Change: Understanding the Unique Business Identifier (UBI) System

The UBI system is the most significant change to Hong Kong’s corporate identification framework in decades. It has streamlined the old dual-system into a single, unified approach.

Why the Change?

The primary reason for the reform was to enhance efficiency and streamline interactions between businesses and government departments. Using a single identifier reduces errors, simplifies data sharing, and aligns Hong Kong with international best practices where single business identifiers are common.

How It Works: The BRN Becomes the UBI

The UBI system officially adopts the 8-digit Business Registration Number (BRN) as the UBI for all entities administered by the Companies Registry. This creates a new, clear hierarchy:

• The BRN is now the sole primary identifier for all interactions with both the IRD and the Companies Registry.

  
  

• For new companies (incorporated on or after December 27, 2023), the Certificate of Incorporation issued by the CR now displays the BRN as the company’s UBI. They are never issued a separate CRN.

  
  

• For existing companies (incorporated before the transition), their pre-existing BRN was automatically adopted as their UBI.

  
  

The CRN has been officially replaced by the BRN/UBI as the main identification number for companies. While not erased from historical records, its function is now purely as a legacy identifier. For all practical purposes—legal, administrative, and commercial—the BRN is the single correct number to use for an incorporated company in Hong Kong.

What This Means for Your Business: Practical Scenarios

To understand the real-world impact, let's look at how the UBI system affects different business setups.

Scenario A: Registering a New Local Limited Company

An entrepreneur wants to start "Innovate HK Limited." They use the one-stop registration service, submitting the incorporation form (NNC1) and business registration notice (IRBR1) to the Companies Registry simultaneously.

• Outcome: The CR issues a Certificate of Incorporation (CI) and a Business Registration Certificate (BRC). The CI prominently features the new 8-digit UBI, which is the company's BRN. The separate BRC shows the exact same BRN. The company has only one primary number from day one: its BRN.

  
  

Scenario B: Registering a Sole Proprietorship

A freelance consultant starts their own business. As a sole proprietor, they do not need to deal with the Companies Registry.

• Outcome: Within one month of starting, the consultant registers directly with the IRD's Business Registration Office. After submitting Form 1(a), the IRD issues a BRC containing the business’s 8-digit BRN. This business only has a BRN; a CRN is not applicable.

  
  

Scenario C: An Existing Company Navigating the Transition

"Global Traders Limited" was incorporated in 2020. It was issued a 7-digit CRN (e.g., 7654321) on its CI and a separate 8-digit BRN (e.g., 98765432) on its BRC.

• Outcome: After the reform, the company’s 8-digit BRN (98765432) automatically became its UBI. Its old CRN is now a legacy number. When filing its next Annual Return, the company secretary must use the BRN/UBI (98765432) as the company’s identifier on the form.

Your Compliance Checklist in the UBI Era

With the UBI system in full effect, adapting your compliance procedures is essential to avoid administrative errors and penalties.

✅BRC Renewal: Ensure you renew your 1-year or 3-year Business Registration Certificate with the IRD on time.

✅Display Your BRC: Always display the valid BRC at your registered place of business.

✅Notify the IRD of Changes: Report any changes to your business particulars (address, name, etc.) to the IRD within one month.

✅ Use the BRN/UBI for All CR Filings: All filings with the Companies Registry, including your Annual Return, must now use the BRN as the company identifier.

✅ Update Your Records: Update your internal templates, legal agreements, and accounting systems to reference the BRN/UBI as the primary identifier.

Failure to comply with the Business Registration Ordinance can lead to a fine of up to HKD 5,000 and imprisonment for one year. The Companies Ordinance has its own escalating fines for late filings.

Strategic Recommendations for a Smooth Transition

To ensure your business operates smoothly in the UBI environment, here are a few strategic recommendations:

• Conduct an Internal Identifier Audit: Review all your company records—legal agreements, document templates, accounting systems—and systematically replace references to the legacy CRN with the BRN/UBI.

• Proactively Update Stakeholders: Inform your bank, auditors, lawyers, and key suppliers that your BRN is now your company’s official UBI. This will prevent confusion and streamline future communications.

• Embrace Government e-Services: Familiarize yourself with the Companies Registry’s e-Services Portal and the IRD’s eTAX platform. These digital tools are designed around the UBI system and offer the most efficient way to manage your compliance obligations.

• Seek Professional Advice: If you are uncertain about your obligations, consult a professional corporate services provider. They can ensure you navigate the nuances of the transition correctly and maintain full compliance.

Conclusion

Hong Kong's shift to the Unique Business Identifier is a significant step towards modernizing its corporate administration. By making the Business Registration Number (BRN) the single source of truth for all businesses, the government has simplified a complex system, reduced administrative burdens, and enhanced regulatory efficiency.

For entrepreneurs, this change brings welcome clarity. While it requires a conscious effort to update records and processes, the long-term benefit is a more streamlined and integrated compliance environment. Understanding that the BRN is now your company's universal ID—for tax, legal, and operational purposes—is the key to navigating Hong Kong's business landscape with confidence and success.