Accounting Services

The Agreement on Trade in Services covers and consolidates commitments relating to liberalisation of trade in services provided in CEPA and its Supplements and also the Agreement between the Mainland and Hong Kong on Achieving Basic Liberalisation of Trade in Services in Guangdong.

Agreement on Trade in Services
Liberalisation Measures under Cross-border Services (Positive List)
Sectors or Sub-sectors	Business services Professional services Accounting, auditing and bookkeeping services (CPC862)
Specific commitments	Hong Kong accountants who have already qualified as Chinese Certified Public Accountants (CPAs) and practised in the Mainland (including partnership) are treated on par with Chinese CPAs in respect of the requirement for annual working period in the Mainland. To allow consultancy companies in the Mainland established by Hong Kong accountants that have satisfied the requirements of the Mainland's "Provisional Measures for the Administration of the Provision of Bookkeeping Services" to provide bookkeeping services. The person in charge of the bookkeeping services should hold the relevant Mainland's professional qualification (professional title) of accountant or above, or be in practice of accounting for not less than three years and be a full-time practitioner. Hong Kong accountants providing bookkeeping services should fulfil the relevant requirements set by the responsible Mainland financial ministries. When Hong Kong accountants apply for a practising licence in the Mainland, the length of auditing experience that they have acquired in Hong Kong is equivalent to the length of auditing experience acquired in the Mainland. The validity period of the "Provisional Licence to Perform Audit-Related Services", applied for by Hong Kong accounting firms for the purpose of conducting auditing business on a temporary basis in the Mainland, is extended to five years. To permit the setting up of an examination centre in Hong Kong for holding the Mainland's Accounting Professional Technician Qualification Examination. To suitably simplify the documentation requirements for applications for conducting business on a temporary basis in the Mainland by Hong Kong accounting firms. When Hong Kong permanent residents who have obtained the Chinese Certified Public Accountants (CPAs) qualification apply to become partners of accounting firms in the Mainland, the length of auditing experience that they have acquired in Hong Kong is considered equivalent to the length of auditing experience acquired in the Mainland. When determining the duration of residency in the Mainland for Hong Kong certified public accountants who hold the Mainland certified public accountant qualification and practise as partners of accounting firms in the Mainland, the days spent on travelling between the Mainland and Hong Kong are counted towards the days of residency in the Mainland, and any part of a day is counted as a full day.
Reserved Restrictive Measures under Commercial Presence (Negative List)
Sector	Business services
Sub-sector	Professional services Accounting, auditing and bookkeeping services (CPC862)
Obligations concerned	National Treatment
Reserved Restrictive Measures	Commercial Presence Apply national treatment.

For details about the cooperation in accounting under the Agreement on Economic and Technical Cooperation (Ecotech Agreement), please refer to the Ecotech Agreement.

Rules and regulations promulgated by the Mainland authorities relating to the implementation of commitments under CEPA :

Bookkeeping Services

According to the "Measures on the Administration of Bookkeeping Services" (2019 Revision - Mar 2019) (in Chinese only), an agency filing an application for bookkeeping qualification in the Mainland shall meet the following requirements simultaneously:
1. the agency should be established in conformity with legal provisions;
2. there should be no less than 3 full-time practitioners;
3. the person in charge of the bookkeeping business should hold the relevant Mainland's professional qualification of accountant or above, or be in practice of accounting for not less than three years and be a full-time practitioner;
4. the agency should have sound internal rules for the bookkeeping business.

Temporary Auditing Business

To conduct auditing business on a temporary basis ("temporary practice") in the Mainland, Hong Kong accounting firms shall submit a written application to the provincial Department of Finance at the location of its temporary practice. Hong Kong accounting firms may only carry out temporary practice in the Mainland upon approval and issuance of the "Provisional Licence to Perform Audit-Related Services" by the Department of Finance. The validity period of the "Provisional Licence to Perform Audit-Related Services" applied for by Hong Kong accounting firms is 5 years.
For details, please refer to:

Serve as Partners of Accounting Firms

When applying to be the partner of a partnership accounting firm in the Mainland, Hong Kong accounting professionals shall meet the requirements set out in the "Law of the People's Republic of China on Certified Public Accountants" (2014 Revision - Aug 2014) (in Chinese only), "Regulation on Practice Licensing and Supervision of Accounting Firms" (2019 Revision - Jan 2019) (in Chinese only) and other rules and regulations on the qualification and requirements of partners, such as being qualified as a Certified Public Accountant in the Mainland, having the required length of auditing experience and no record of administrative punishment, etc.
According to the Agreement on Trade in Services, when eligible Hong Kong accounting professionals apply to become partners of accounting firms in the Mainland, the length of auditing experience that they have acquired in Hong Kong is considered equivalent to the length of auditing experience acquired in the Mainland. For details, please refer to the "Notice by the Ministry of Finance on Issues Concerning Vigorously Supporting Accounting Professionals from Hong Kong and Macao Special Administrative Regions in Serving as Partners of Accounting Firms in the Mainland" (No. 9 [2016] Ministry of Finance) (in Chinese only).

Accounting Professionals

Certified Public Accountant Qualification
- Hong Kong residents may apply to take the National Uniform Certified Public Accountant Examination of the Mainland if they have full civil capacity and:
  1. hold a college degree or above recognized by the relevant administrative departments of the People's Republic of China that are responsible for education; or
  2. hold Certified Public Accountant certificates (or other equivalent qualifications) recognized by laws of Hong Kong, Macao, Taiwan or foreign countries.
- Furthermore, individuals may apply to be exempted from 4 papers under the National Uniform Certified Public Accountant Examination of the Mainland, namely "Financial Management and Cost Management", "Auditing", "Accounting" and "Corporate Strategies and Risk Management" if they:
  1. have attended the Hong Kong Institute of Certified Public Accountants (HKICPA) Qualification Programme Module Examinations and passed all of the subjects; or
  2. have passed the inspection and became a member of HKICPA on or before 29 July 2008 even they have not fully completed the Qualification Programme of HKICPA.
- For details, please refer to:
Accounting Professional Technician Qualification
- Accounting professionals may acquire the Accounting Professional Technician Qualification after passing the national uniform examination. There are 3 levels in the qualification framework, namely the elementary, the intermediate and the advanced. Acquiring the qualification of a particular level means that one is capable of performing the accounting technical duties specified for that level.
- Hong Kong residents who meet the application criteria in the "Interim Provisions on the Accounting Professional Technician Qualification Examination" may apply to take the examination at the corresponding level. For details, please refer to:
  - "Notice on Revising and Issuing the 'Interim Provisions on the Accounting Professional Technician Qualification Examination' and its Implementation Measures" (Circular of the Ministry of Finance No. 11 - Sep 2000) (in Chinese only)
  - "Notice on Adjustments of Subjects for the Accounting Professional Technician Qualification Examination and Related Issues" (Circular of the Ministry of Finance No. 25 - Aug 2004) (in Chinese only)

For other details, please refer to:

"Circular on Deepening the Reform of 'Separating Operating Permits and Business Licenses' to Further Boost the Vitality of Market Entities for Development" (May 2021) (in Chinese only)

Enquiries concerning the application procedures and requirements for the provision of accounting services in the Mainland can be directed to:

Frequently Asked Questions