The answer first
A Hong Kong company has a small number of fixed annual deadlines and a longer list of "event" deadlines that start when something changes. Most penalties we see come from the second group, such as a new director not notified or a departing employee not reported, rather than from the annual filings.
The five annual dates every director should know
- Annual Return (NAR1)
- Within 42 days after the anniversary of incorporation
- Business Registration renewal
- Before the certificate expires (every 1 or 3 years)
- Profits Tax Return
- Issued around the beginning of April; due within 1 month unless an extension applies
- Employer's Return
- Issued around the beginning of April; due within 1 month
- Annual general meeting
- Within 9 months after the end of the accounting reference period, unless dispensed with
Your annual compliance calendar
The table assumes a private company limited by shares with a 31 March financial year end.
| When | Obligation | Who acts | Notes |
|---|---|---|---|
| Every month, by the 10th | MPF contributions for the previous month | Employer | Applies once you have employees |
| Beginning of April | Profits Tax Return issued | Inland Revenue Department | First return usually issued about 18 months after incorporation |
| Beginning of April | Employer's Return (BIR56A and IR56B) issued | Inland Revenue Department | File within 1 month, even if there were no employees, if a return has been issued |
| Within 1 month of issue | Employer's Return filed | Company | Covers the year to 31 March |
| Within 1 month of issue, or block extension date | Profits Tax Return filed | Company or tax representative | Extended dates depend on the year-end code |
| Around January and April | Provisional tax instalments | Company | Shown on the notice of assessment |
| By 31 December (31 March year end) | AGM held, or written resolution or dispensation in place | Directors and members | Audited financial statements laid before members |
| Within 42 days after anniversary of incorporation | Annual Return (NAR1) | Company secretary | HK$105 on time; up to HK$3,480 late |
| Before certificate expiry | Business Registration renewal | Company | HK$2,350 for 1 year (government fee) |
Profits Tax Return deadlines
The standard deadline is one month from the date of issue. Companies represented by a tax representative usually benefit from the Inland Revenue Department's Block Extension Scheme, which sets later dates according to the company's accounting year end.
| Year-end code | Accounting year ends between | Extended due date for 2025/26 returns |
|---|---|---|
| N | 1 April and 30 November | 4 May 2026 |
| D | 1 and 31 December | 17 August 2026 |
| M | 1 January and 31 March | 16 November 2026 (later for loss cases) |
Please noteBlock extension dates are set each year by the Inland Revenue Department and change slightly from year to year. Always check the date on the return actually issued and on the current year's block extension letter.
Event-driven deadlines
These start when something happens. Put a process in place so that the company secretary hears about each event in time.
| Event | Form | Deadline |
|---|---|---|
| Change of directors or company secretary, or their particulars | ND2A / ND2B | Within 15 days |
| Change of registered office | NR1 | Within 15 days |
| Allotment of new shares | NSC1 | Within 1 month |
| Change of company name | NNC2 (special resolution) | Within 15 days of the resolution |
| Change in significant controllers | Significant Controllers Register (not filed) | Update within 7 days of confirming particulars |
| New employee who may earn above the basic allowance | IR56E | Within 3 months of starting |
| Employee leaving (remaining in Hong Kong) | IR56F | At least 1 month before the last day of employment |
| Employee leaving Hong Kong for more than 1 month | IR56G | At least 1 month before departure |
| New employee aged 18 to 64 | MPF enrolment | Within the first 60 days of employment |
| Change of business address or nature of business | Business Registration notice | Within 1 month |
What missing a deadline costs
| Default | Maximum penalty |
|---|---|
| Annual Return not filed | HK$50,000 plus HK$1,000 per day, plus late fees up to HK$3,480 |
| ND2A, ND2B or NSC1 not filed | HK$25,000 plus HK$700 per day |
| NR1 not filed | HK$50,000 plus HK$1,000 per day |
| Significant Controllers Register not kept | HK$25,000 plus HK$700 per day |
| Profits Tax Return not filed without reasonable excuse | HK$10,000 plus up to three times the tax undercharged; an estimated assessment may be issued |
| Failure to enrol an employee in MPF | HK$350,000 and 3 years' imprisonment |
Key takeawayMost of these fines are imposed on directors personally as well as on the company. A reliable calendar, owned by one named person, is the cheapest compliance tool there is.
How DBMS Global can help
- Building a compliance calendar for your company, based on your incorporation date, year end and staff.
- Tracking every deadline on your behalf and sending reminders well in advance.
- Preparing and filing Companies Registry forms, the Annual Return, the Employer's Return and the Profits Tax Return.
- Coordinating the audit and the AGM paperwork, so the timetable works backwards from the filing dates.
Dates for your company depend on its incorporation date, year end, tax status and staff; we confirm them in writing when we take you on.
Official references
- Companies Registry: Filing Requirements of a Local Limited Company after Incorporation, www.cr.gov.hk
- Inland Revenue Department: Block Extension Scheme letter and Employer's Return guidance, www.ird.gov.hk
- Mandatory Provident Fund Schemes Authority, www.mpfa.org.hk