Hong Kong Limited Company Compliance Calendar: When to File NAR1, Profits Tax Return, BR and MPF?
- 2 days ago
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After setting up a limited company in Hong Kong, business owners need to manage more than daily operations, sales and cash flow. There are also regular compliance matters that must be handled on time.
For many SME owners, the challenge is not that they are completely unaware of these requirements. The real problem is that each filing has its own deadline, calculation method and responsible government department.
For example, the Annual Return, also known as NAR1, is based on the company’s incorporation anniversary date. The Business Registration Certificate, or BR, follows the expiry date stated on the certificate. Profits Tax Return filing depends on when the Inland Revenue Department issues the return. If the company hires employees, employer’s return filing and MPF obligations also need to be managed separately.
In other words, there is no single “annual tax day” that applies to every Hong Kong limited company. To avoid late filing, penalties and missing documents, it is much more practical to build a compliance calendar based on your company’s own dates.
This guide uses a general Hong Kong local private limited company as an example, and explains the key deadlines for Annual Return filing, Business Registration renewal, Profits Tax Return, audit, Employer’s Return and MPF.
This article is for general reference only. Actual deadlines should be confirmed based on your company’s own documents, circumstances and the latest requirements from the relevant government departments.
✨Key compliance deadlines for a Hong Kong limited company
Compliance item | When to handle it | Main reference date |
Annual Return NAR1 | Within 42 days after the company’s incorporation anniversary | Date of incorporation |
Business Registration Certificate renewal | According to the renewal demand note | BR expiry date |
Profits Tax Return BIR51 | First return usually has a 3-month filing period | Date of issue by the IRD |
Financial statements and audit | Based on year-end and tax filing arrangements | Financial year-end |
Employer’s Return BIR56A / IR56B | Usually issued in April, generally due within one month | Date of issue by the IRD |
MPF enrolment for employees | Generally within the first 60 days of employment | Employee start date |
Monthly MPF contribution | For monthly-paid employees, generally on or before the 10th day of the following month | Each contribution period |
Business record keeping | Ongoing, generally for at least 7 years | Transaction and business records |
As a starting point, business owners can remember the following:
NAR1 follows the company’s incorporation anniversary
BR follows the expiry date of the Business Registration Certificate
Profits Tax Return follows the date issued by the IRD
Employer’s Return is usually handled around April each year
MPF follows employee start dates and monthly contribution deadlines
1. Annual Return NAR1: file within 42 days after the incorporation anniversary
The Annual Return, commonly referred to as NAR1, is filed with the Companies Registry. Its purpose is to update the company’s basic information.
A typical NAR1 includes information such as:
Registered office address
Director details
Company secretary details
Shareholder and share capital details
Principal business activity
For a general local private company in Hong Kong, the Annual Return should be delivered within 42 days after the anniversary of the company’s incorporation date.
For example, if a company was incorporated on 15 March 2026, its first incorporation anniversary would be 15 March 2027. The company would generally need to file its first NAR1 on or before 26 April 2027.
A company usually does not need to file an NAR1 immediately in the year of incorporation. The first Annual Return is normally counted from the first incorporation anniversary.
What happens if NAR1 is filed late?
If the Annual Return is filed within the 42-day period, the annual registration fee for a private company is generally HK$105. If it is filed late, the registration fee increases according to the length of delay, and may range from HK$870 to HK$3,480.
Even if there have been no changes to the company’s directors, shareholders, registered office address or company secretary, the NAR1 still needs to be filed on time. “No change” does not mean “no filing”.
NAR1 is not a tax return
This is one of the most common misunderstandings among new company owners.
NAR1 is filed with the Companies Registry to update company information. A Profits Tax Return is filed with the Inland Revenue Department to report the company’s financial and tax position.
They are separate procedures. Filing NAR1 does not mean the company has completed its tax filing.
2. Business Registration Certificate: keep track of the expiry date and renewal notice
The Business Registration Certificate is commonly referred to as BR. It is handled by the Business Registration Office of the Inland Revenue Department, and the certificate states its validity period.
In general, the IRD will issue a Business Registration renewal demand note around one month before the new certificate begins. Once payment is made, the receipted demand note becomes the valid Business Registration Certificate.
For example, if the new Business Registration Certificate starts in May, the renewal demand note is usually issued around mid-April.
What if the company does not receive the BR renewal notice?
❗The company should not ignore the renewal simply because the notice has not arrived.❗
If the existing Business Registration Certificate has expired and the company has not received a renewal demand note, the company should contact the Business Registration Office or notify the IRD in writing as required.
It is therefore better for companies to record the BR expiry date internally and set reminders in advance, instead of relying entirely on postal notices.
What is the difference between BR, NAR1 and Profits Tax Return?
Item | Responsible department | Main purpose |
NAR1 Annual Return | Companies Registry | To update company information |
Business Registration Certificate | Business Registration Office, IRD | To keep business registration valid |
Profits Tax Return BIR51 | Inland Revenue Department | To report company profits and tax position |
These are three separate compliance matters. They cannot replace one another.
3. Profits Tax Return: start preparing your records before the return arrives
A newly incorporated limited company usually does not receive its first Profits Tax Return within the first few months of incorporation.
In general, the Inland Revenue Department issues the first Profits Tax Return around 18 months after the date of incorporation, although the actual timing may vary depending on the case.
The first Profits Tax Return usually has a 3-month filing period. For subsequent years, the filing deadline should follow the date stated on the return and any applicable extension arrangements.
After receiving a Profits Tax Return, the company may need to prepare:
Completed Profits Tax Return BIR51
Financial statements
Profits tax computation
Auditor’s report
Relevant supplementary forms and supporting documents
Because bookkeeping, financial statement preparation and audit work can take time, companies should not wait until the tax return arrives before looking for invoices and receipts.
A better approach is to keep proper records from the start of business operations, including:
Bank statements
Sales and income records
Invoices and receipts
Supplier bills
Rent and operating expenses
Payroll records
Loan and interest records
Fixed asset purchase records
In general, business records should be kept for at least 7 years.
Does a company with no revenue still need to file a tax return?
If the IRD has issued a Profits Tax Return to the company, the company should complete and submit it based on its actual situation, even if it has no revenue, has not started business, or has made a loss.
Having no revenue does not mean the company can ignore a tax return issued by the IRD.
4. Financial statements and audit: do not confuse them with NAR1
The Annual Return NAR1 is used to update company information. It is not the company’s financial statement.
In general, Hong Kong limited companies are required to keep accounting records, prepare annual financial statements and arrange an audit according to the applicable legal requirements and company circumstances. Companies that have properly become dormant companies under the law may be subject to different arrangements.
The audit timeline is usually affected by:
The company’s financial year-end
The length of the first financial year
The date the Profits Tax Return is issued
The time required by the auditor
The company’s transaction volume and record completeness
After incorporation, a company should confirm its financial year-end and coordinate bookkeeping, audit and tax filing arrangements early.
A company should not assume that it is automatically exempt from audit or record keeping simply because it is small, has no revenue, or has only a few transactions.
5. Employer’s Return: check whether the IRD has issued the form, even if there are no employees
Employer’s Return filing usually involves BIR56A and IR56B.
BIR56A is the Employer’s Return, while IR56B is used to report the remuneration details of individual employees. The IRD usually issues Employer’s Returns in April each year, and employers are generally required to submit them within one month from the date of issue.
Even if the company has no employees, has not started business, or has already ceased business when it receives BIR56A, it should still complete and return the form based on its actual situation, rather than ignoring it.
Employee onboarding, termination or departure from Hong Kong may trigger additional filings
Apart from the annual BIR56A and IR56B, employers may need to submit other forms when an employee joins, leaves or is about to depart from Hong Kong.
Employee situation | Common form | General filing time |
New employee joins | IR56E | Within 3 months after employment begins, where the employee is likely to be chargeable to Salaries Tax |
Employee remains employed | IR56B | Submitted annually with BIR56A |
Employee leaves employment | IR56F | Generally not later than 1 month before cessation of employment |
Employee is about to leave Hong Kong for a long period | IR56G | Generally not later than 1 month before the expected departure date, with tax clearance requirements handled accordingly |
Employer’s Return compliance is therefore not only a once-a-year task. Employee changes can also create separate reporting obligations.
6. MPF: count from the employee’s start date, not the company’s year-end
MPF is an ongoing employer obligation. It is not something to be handled only at year-end or during tax filing.
Except for exempt persons, general full-time or part-time employees aged 18 to 64 who are employed for a continuous period of 60 days or more should normally be enrolled in an MPF scheme within the first 60 days of employment.
The 60-day period is counted by calendar days, including Saturdays, Sundays and public holidays.
For monthly-paid employees, the contribution day is generally the 10th day of each month. For example, contributions for September should normally be made on or before 10 October.
Employers should also pay attention to:
Making contributions on time
Reporting employees’ relevant income correctly
Submitting contribution records
Providing relevant information to employees
Updating records when employees leave
Casual employees in the construction and catering industries may be subject to different industry scheme arrangements, so companies should not apply the general 60-day rule without checking the relevant requirements.
7. Company changes should not wait until the next NAR1 filing
Apart from annual compliance deadlines, companies also need to report certain changes when they happen.
Common examples include:
Appointment or resignation of directors
Change of company secretary
Change in particulars of directors or company secretary
Change of registered office address
Change of business address
Commencement or cessation of business
For example, changes to directors, company secretary or registered office address generally need to be reported to the Companies Registry within a specified period. If the business address changes, the company may also need to notify the Business Registration Office.
These filings are often missed because they do not happen on a fixed annual date. Companies should not wait until the next NAR1 filing to update all changes at once.
Example: what should a company incorporated on 15 March 2026 keep track of?
Assume a local private company was incorporated on 15 March 2026 and holds a one-year Business Registration Certificate. The following simplified example shows how different compliance matters may appear on the company’s timeline.
Shortly after incorporation
The company should start by:
Keeping bank, income, expense and receipt records
Setting up a basic bookkeeping workflow
Confirming the company’s financial year-end
Planning bookkeeping, audit and tax filing arrangements
Recording the BR expiry date
If the company hires employees
The company should track the following based on each employee’s start date:
MPF enrolment deadline
Monthly MPF contribution date
Employer reporting obligations for new joiners, leavers or employees leaving Hong Kong
Payroll, leave and contribution records
Approaching the first incorporation anniversary
The company’s first incorporation anniversary would be 15 March 2027.
In general, the company should file its first NAR1 on or before 26 April 2027. Around the same period, it should also check the BR renewal arrangement and review whether director, company secretary, shareholder and address information is up to date.
Around 18 months after incorporation
In general, the company may receive its first Profits Tax Return around 18 months after incorporation. The actual timing may vary.
Once the first return is issued, the company usually has 3 months to submit it. If the company has maintained proper records from the start, the tax filing and audit process will usually be much smoother.
This example is for illustration only. Actual deadlines depend on the company’s financial year-end, operations, employment situation and the dates of government notices.
Common compliance mistakes made by Hong Kong limited companies
1. Treating the Annual Return as a tax return
NAR1 is a company information filing. The Profits Tax Return is a tax filing. They are submitted to different departments and serve different purposes.
2. Assuming no revenue means no compliance work is needed
A company with no revenue is not automatically exempt from annual return filing, business registration, tax filing or record keeping. If a government department has issued a form or notice, the company should handle it according to its actual situation.
3. Ignoring responsibilities because no notice was received
Companies are responsible for keeping their registered address and business address up to date, and for monitoring key deadlines. If a BR renewal notice or tax document is not received, the company should make enquiries with the relevant department.
4. Waiting until the tax return arrives before organising records
Tax filing and audit usually require financial statements, receipts, bank records and supporting documents. If records are not kept properly during the year, the filing process can become slower, more expensive and more prone to errors.
5. Relying completely on external service providers
Company secretaries, accountants and tax representatives can help handle filings, but directors should still understand key deadlines and responsibilities. They should also ensure that accurate information is provided on time.
How to build your own company compliance calendar
Companies can start by recording the following key information:
Date of incorporation
Business Registration Certificate expiry date
Financial year-end
Date of issue of Profits Tax Return
Date of issue of Employer’s Return
Employee start dates, termination dates and departure dates
Monthly MPF contribution day
Dates of changes to directors, company secretary or addresses
For each important deadline, it is useful to set reminders in advance:
Reminder timing | Suggested action |
60 days before | Check what documents and information are required |
30 days before | Confirm whether records are complete and follow up with service providers |
14 days before | Complete submission, payment or final review |
Companies can also keep documents in separate folders, such as:
Company registration documents
Business Registration documents
Tax filings and correspondence
Audit and financial statements
Bank and operating expense records
Payroll and MPF documents
A clear filing system helps reduce the risk of late filing. It also makes it easier to handle audit, tax filing, loan applications, government funding applications and cash flow analysis later.
Frequently Asked Questions
Does a Hong Kong limited company need to file NAR1 every year?
In general, a local private company must file NAR1 within 42 days after each incorporation anniversary. The company usually does not need to file it immediately in the year of incorporation. The first NAR1 is normally counted from the first incorporation anniversary.
Are NAR1, BR and Profits Tax Return the same thing?
No. NAR1 is filed with the Companies Registry to update company information. BR refers to Business Registration Certificate renewal. Profits Tax Return is filed with the Inland Revenue Department to report the company’s financial and tax position.
They are three separate procedures.
Does a company with no business activity still need to file NAR1?
In general, having no business activity does not automatically remove the company’s annual filing obligations. Unless the company has properly become a dormant company under the law or has been formally dissolved, it may still need to handle applicable compliance matters.
Does a company with no revenue still need to file a tax return?
If the IRD has issued a Profits Tax Return, the company should complete and submit it based on its actual circumstances. Having no revenue, not yet starting business, or making a loss does not mean the return can be ignored.
Does a company with no employees need to handle MPF?
If the company has no employees who are required to join an MPF scheme, it generally does not need to make employer contributions. However, if the company receives an Employer’s Return BIR56A from the IRD, it should still complete and return it according to its actual situation.
What should a company do if NAR1 is overdue?
The company should file the Annual Return as soon as possible and pay the applicable fee. The longer the delay, the higher the registration fee may become, and the company and responsible persons may face further compliance risks.
Final thoughts: a compliance calendar is not only about avoiding penalties
Compliance requirements for Hong Kong limited companies are spread across different departments and timelines. Annual Return filing, Business Registration renewal, Profits Tax Return, audit, Employer’s Return and MPF are not the same thing, and they are not all handled on the same date.
For SMEs, building a clear company compliance calendar is not only about avoiding late filing or penalties. It also helps keep documents, records and responsibilities organised.
When records are properly maintained, future tax filing, audit, funding applications, loan applications and cash flow reviews can become much smoother.
Everpro can help SMEs review their compliance timeline, financial records, cash flow management and day-to-day operating processes, so business owners can better understand what needs to be handled now and what should be planned next.
This article is for general information only and does not constitute legal, accounting or tax advice. Actual requirements should be confirmed based on the company’s circumstances and the latest rules from the relevant government departments.
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