A check of public notices from the Inland Revenue Department, the Companies Registry and the BVI Financial Services Commission on 12 November 2026 found no substantial new announcement that requires a separate news post. This is a standing compliance reminder of the Registry’s current rules on delivering an annual return (Form NAR1) for a local private company, and of the option, from 17 August 2026, for holders of “iAM Smart+” to e-file without a portal account — general information only, not legal advice. Due dates and fees for any particular company follow the Companies Ordinance, the relevant regulations and the Registrar’s records.
Key point: A local private company must, in respect of every year, deliver Form NAR1 to the Registrar of Companies within 42 days after the anniversary of its incorporation in that year. A private company that is a re-domiciled company counts 42 days from the anniversary of its re-domiciliation date. The Registrar has no power to extend the statutory time limit. If the return is delivered within the prescribed period, the annual registration fee is HK$105. Late delivery attracts the higher fees in the Companies (Fees) Regulation (Cap. 622K), which the Registrar has no power to waive.
How the 42-day period is counted
The Registry’s FAQs state that Sundays and public holidays are included when counting the 42 days. If day 42 falls on a Sunday or a public holiday, the due date is moved to the next day that is not a Sunday or a public holiday. If the last day of the period is a Saturday (and is not a public holiday), the deadline remains unchanged — the Registrar cannot extend it, and delivery on the following Monday attracts the higher fee. If you plan to deliver in person, it is safer to do so on the Friday before. If you are unsure of the due date, use the Registrar’s Annual Return Filing Calculator.
On-time and late fees (local private companies)
According to the Registry’s compliance page and its price guide to main services, the annual registration fees for a local private company are:
- Within 42 days after the company’s return date: HK$105
- More than 42 days after but within 3 months: HK$870
- More than 3 months after but within 6 months: HK$1,740
- More than 6 months after but within 9 months: HK$2,610
- More than 9 months after the return date: HK$3,480
For a local private company, the return date is the anniversary of the date of incorporation or the re-domiciliation date in that year. In addition, under section 662 of the Companies Ordinance, failure to deliver the annual return within the prescribed time is a criminal offence. The company and every responsible person are liable to prosecution and, if convicted, to a maximum fine of HK$50,000 for each breach and, in the case of a continuing offence, a daily default fine of HK$1,000.
A return that has not been properly signed, or is not accompanied by the correct fee, is treated as unsatisfactory and will be rejected. It is not regarded as having been delivered; the fee is calculated by reference to the date of re-delivery, which may result in a higher fee. If the return is sent by post and the Registrar does not receive it, it is not treated as delivered. Changes relating to directors, the company secretary and similar particulars that have not yet been reported should be filed on the appropriate forms.
e-Filing for unregistered users with “iAM Smart+” (from 17 August 2026)
Under Companies Registry External Circular No. 1 / 2026 (3 August 2026), from 17 August 2026 an individual director or company secretary of a company — or a director or company secretary of a non-individual officer of the company — who holds an “iAM Smart+” account may submit certain commonly used forms electronically without first registering a user account or subscribing to e-Filing Services on the e-Services Portal. Initially, the forms covered are the Annual Return (Form NAR1) and the Notice of Change of Address of Registered Office (Form NR1) for local companies.
Key company particulars are pre-filled from the Registry’s records as at the made-up date of the return. The user signs with “iAM Smart+” and pays any registration fee online before submission. “iAM Smart” is a free account for Hong Kong Identity Card holders aged 11 or above; electronic signing requires the “iAM Smart+” version, which includes a digital signing function. Details are on the Digital Policy Office iAM Smart website. A self-registration kiosk is available at the Registry’s e-Services Centre on 13/F of the Queensway Government Offices. This is a convenience option; it does not change the statutory time limit or the fees. Users who already subscribe to e-Filing Services, and companies that prefer to file in hard copy by post or in person, may continue to do so.
The return dates and fees for registered non-Hong Kong companies, public companies and companies limited by guarantee are different. Use the Registrar’s pages for those types; do not apply the private-company figures above.
How this differs from business registration and profits tax
The informal term “annual review” in Hong Kong often bundles the NAR1 filing at the Companies Registry with business-registration renewal and profits-tax filing at the Inland Revenue Department. The statutory deadlines and the responsible departments are not the same, and one filing does not replace another. For 2025/26 “M” code Profits Tax returns, the IRD has a separate block-extension arrangement; see our earlier note on the extended “M” code due dates. It is sensible to check particulars of directors, the secretary, the registered office and shareholders before the incorporation (or re-domiciliation) anniversary, and to allow enough time to deliver the return — especially if the last day of the period falls on a Saturday.
Sources: Companies Registry: Compliance — Annual Return (local private company) · Companies Registry External Circular No. 1 / 2026 (3 Aug 2026, PDF) · Companies Registry: Principal fees under the Companies Ordinance · Companies Registry FAQs: Local limited companies — Annual return · Annual Return Filing Calculator
Related services:Hong Kong annual review / company secretary · Hong Kong company incorporation · Hong Kong profits tax filing · BVI / offshore companies · Hong Kong accounting