At 25%, Hong Kong and Mainland shareholding tests give different results.
Follow one fictional ownership chain from Hong Kong through the BVI to Shenzhen. Each layer has its own record, its own disclosure rules and its own idea of who counts as an owner.
By Matthew Lee
On shareholding alone, Hong Kong’s AMLO threshold is more than 25%, the Mainland’s is 25% or more, and the BVI collects filings from 10%. Voting rights and other control are assessed separately; the same percentage does not settle every UBO question.
The worked example applies each regime’s shareholding threshold to the same fictional structure. Additional control rights could change the result for any of these people.
The structure
A fictional chain, of the kind a Hong Kong bank sees every week:
- Harbour Crest Trading Limited, a Hong Kong company, is wholly owned by
- Silvermine Bay Holdings Limited, a BVI business company, which is wholly owned by
- Shenzhen Hongyuan Holdings Co., Ltd., a Mainland holding company, owned by Zhou Jianguo (60%), Liu Min (25%) and Chen Hui (15%).
Every layer above Harbour Crest holds 100%, so each person's effective interest in the Hong Kong company equals their stake in the Mainland parent.
Layer by layer
| Layer | Record that names the next owner | Public? | What fills the gap | Owner test |
|---|---|---|---|---|
| Harbour Crest Trading Limited, Hong Kong | Annual return, list of members | Yes | Certified extract of the significant controllers register, from the client | More than 25% |
| Silvermine Bay Holdings Limited, BVI | Register of members, kept by the registered agent | Only if the company opts to make its filed copy public | Certified register of members or certificate of incumbency, from the registered agent | 10% or more filed with the Registrar |
| Shenzhen Hongyuan Holdings Co., Ltd., Mainland | Shareholders and contributions on the company record | Yes, in Chinese | Beneficial owner filing with the PBOC, which is not public; the client's declaration | 25% or more |
Hong Kong. The annual return names Silvermine Bay as sole member. The significant controllers register, kept at the company and closed to the public, should name Zhou Jianguo. Ask the client for a certified extract and compare it with the chain you build.
BVI. A BVI company search confirms Silvermine Bay exists and shows its registered agent, not its members. The member evidence comes from that agent. Beneficial ownership is filed with the Registrar from 10%, so all three individuals should be on the filing. Since 1 April 2026 an applicant with a legitimate interest can ask for limited fields, and only for owners at 25% or more. See the BVI jurisdiction page.
Mainland. The company record shows Shenzhen Hongyuan Holdings' shareholders with their subscribed and paid-in contributions. Under PBOC and SAMR Order No. 3 of 2024 the company files its beneficial owners at 25% or more, so Zhou Jianguo and Liu Min. That filing is open to state agencies and to financial institutions carrying out AML duties through the PBOC. It is not public. The Mainland UBO and multi-layer shareholder tracing search follows the public shareholdings; see also the Mainland China jurisdiction page.
Who counts as an owner, and where
| Person | Interest in Harbour Crest | Hong Kong UBO (more than 25%) | Mainland filing (25% or more) | BVI filing (10% or more) |
|---|---|---|---|---|
| Zhou Jianguo | 60% | Yes | Yes | Yes |
| Liu Min | 25% | No, on ownership alone | Yes | Yes |
| Chen Hui | 15% | No | No | Yes |
Liu Min is the case to watch. She appears as a beneficial owner in two filings that are not public, and falls just under the line at the customer you are onboarding. Nothing stops a bank verifying her on risk. An EU bank onboarding the same structure would have to, because the EU test is 25% or more.
The BVI layer adds one more consideration for EU firms: the British Virgin Islands has been on the EU's high-risk third countries list since 29 January 2026, which brings enhanced due diligence under the EU rules.
The evidence a bank keeps
- Hong Kong: company particulars, the latest annual return and the certified extract of the significant controllers register.
- BVI: the company search report and the agent's certified register of members or certificate of incumbency.
- Mainland: the company record with shareholders and contributions, translated, and the client's beneficial ownership declaration.
- People: identity verification for each beneficial owner, and for anyone else your policy names.
- The working: an ownership chart, the calculation at each layer and the date each record was retrieved.
The order of work, and where a declaration becomes necessary, is in our UBO tracing guide.
How Fill Easy fits in
Send the Hong Kong company name to agent@fill-easy.com, or call the API, and ask for the ownership chain. The Hong Kong and BVI searches come through CorpVerify. The Mainland company search and UBO tracing come through China Cross-Border Data, returned to Hong Kong under our filed Standard Contract, Filing No. 202500031, and translated into English. Each result records its source, retrieval time and request ID.
For the people at the top, China eID confirms a Mainland resident's identity with their consent. The BVI agent's certificate and the significant controllers register extract still come from your client.
Where does your team record a 25% shareholder that one registry counts and another does not?