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Number of Shareholders
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At least 1 person, no upper limit (usually fewer)
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p to 50 people (including individuals and legal entities)
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No upper limit; public companies usually have more shareholders
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Directors/Board of Directors
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Must have at least 1 director; can choose to have a board (3+ directors). No requirement for a board of supervisors.
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Can choose to have a board (3+ directors) or 1–2 directors.
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Must have a board (at least 3 directors); public companies must have independent directors (as per law, at least 2 or one-third of the board)
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Supervisors/Audit Committee
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Not mandatory; optional per articles of incorporation. If set up, at least 1 supervisor required. Responsible for overseeing financial operations. Audit committee not applicable.
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Not mandatory; if set up, at least 1 supervisor or audit committee (must have 3+ independent directors).
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Must have at least 1 supervisor or use an audit committee (at least 3 independent directors). Public companies often use audit committees.
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Minimum Capital Requirement
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No minimum requirement; set in articles of incorporation.
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No minimum requirement; set in articles of incorporation.
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No minimum requirement, but public companies must meet competent authority regulations.
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Share Issuance
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No shares issued; cannot issue common or preferred shares.
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Can issue common/preferred shares (as stated in articles), but not publicly offered.
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Can issue common/preferred shares; public offerings must comply with securities laws.
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Share Transfer Restrictions
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Transfer requires approval of over half of shareholders (unless otherwise stated).
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Transfer is restricted; requires board or shareholder approval (unless otherwise stated).
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Freely transferable; public companies can trade shares in the market.
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Shareholder Liability
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Limited to capital contribution.
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Limited to capital subscription.
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Limited to capital subscription.
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Shareholder Meetings
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Flexible; may be conducted in writing or via teleconference.
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Flexible, more convenient (written or video conferencing).
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Must hold regular shareholder meetings (corporate governance is stricter).
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Corporate Governance
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No board required; only 1 director needed; may appoint supervisor.
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Can opt out of board; 1–2 directors acceptable. No supervisor required, but audit committee is optional.
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Must have board (min. 3); supervisors or audit committee required.
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Financial Disclosure
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No audit required unless stipulated by law.
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No audit required unless stipulated by law.
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Public companies must publish audited financial reports and accept supervision.
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Supervision Level
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Less supervised; suitable for micro-businesses.
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Moderately supervised; suitable for SMEs.
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Heavily supervised; subject to public company management and securities regulations.
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