Business immigration in Hong Kong: overview

A Q&A guide to business immigration in Hong Kong.

This Q&A gives an overview of the key factors affecting business immigration, including information on the jurisdiction's sources of immigration law; relevant government entities; requirements for unsponsored and sponsored immigration; requirements for sponsors; civil and criminal penalties for sponsors; common issues and concerns; dependants; settlement and citizenship; recent trends and proposals for reform.

To compare answers across multiple jurisdictions, visit the Business Immigration Country Q&A tool.

The Q&A is part of the global guide to business immigration. For a full list of jurisdictional Q&As visit www.practicallaw.com/immigration-guide.

Eugene Chow, Chow King & Associates
Contents

Relevant governmental entities

1. What are the relevant government entities (agencies, departments, branches, bodies, and so on) relating to immigration in your jurisdiction?

Administration

The Immigration Department of the Hong Kong Special Administrative Region (HKID) is responsible for immigration control in the Hong Kong Special Administrative Region (HKSAR) and has sole responsibility for the processing and approval of employment visa applications. It is one of the departments under the Security Bureau headed by the Secretary for Security, who reports to the Chief Secretary for Administration and ultimately to the Chief Executive of the HKSAR government.

The HKSAR Labour Department is responsible for processing applications for the import of labour under the Supplementary Labour Scheme (SLS), a programme to import workers at technician level or below. After approval is secured on an "approval in principle" basis, the employer (the local sponsor in Hong Kong) and the candidate must submit relevant application forms and support documents to the HKID. The HKID will process those and issue an entry "employment as imported worker" visa to enable the worker to enter Hong Kong.

Enforcement

The HKID is responsible for controlling the movement of people in and out of Hong Kong. It also provides services to local residents including the:

  • Issuance of:

    • HKSAR passports and other travel documents;

    • visas and identity cards.

  • Handling of nationality matters.

  • Registration of births, deaths and marriages.

Considerable effort also goes into detecting and prosecuting immigration law offenders, and removing illegal immigrants.

Policies are framed to:

  • Limit population growth through immigration to an acceptable level.

  • Control the entry of foreign workers.

Immigration procedures for Hong Kong residents, tourists and businessmen are streamlined. Nationals of about 170 countries and territories can enter Hong Kong on a visa-free basis for periods ranging from seven to 180 days. While ensuring that professionals and businessmen are welcome to work and invest in the local community, effort is also made to prevent the entry of undesirable persons and ensure the departure of persons wanted for criminal offences.

Legislative

While Hong Kong is a part of the People's Republic of China (PRC), the HKSAR Government can apply immigration controls on entry, stay, and departure by persons from foreign states (Article 154, Basic Law (HKSAR Constitution). This includes PRC citizens who are mainland residents and must obtain an exit-entry permit to enter Hong Kong, unless they are in transit for less than seven days while on a trip to another destination.

The Immigration Ordinance (Cap. 115) and the Immigration Regulations (Cap. 115A) of HKSAR primarily cover the following:

  • Right of abode (permanent residence).

  • Immigration control.

  • Illegal immigration.

  • Vietnamese refugees.

  • Detention and removal issues.

  • Conditions of stay.

  • Criminal penalties for the employment of persons not legally authorised to work and for breach of conditions of stay.

 

Sources and conflicts of law

Sources of law

2. What are the principal sources of law relating to immigration in your jurisdiction?

Domestic statutes, international law and international treaties

Under the Sino-British Joint Declaration (Joint Declaration), the PRC assumed sovereignty over Hong Kong on 1 July 1997 and Hong Kong became a Special Administrative Region of the PRC under the model of "one country, two systems". The following remain in force in Hong Kong:

  • The International Covenant on Civil and Political Rights (ICCPR), which was ratified by the United Kingdom in 1976 and extended to Hong Kong, remained in force in Hong Kong after 1997 (Article 13, Annex 1, Joint Declaration).

  • The International Covenant on Economic, Social and Cultural Rights and the International Labour Convention as applied to Hong Kong (Article 39, Basic Law).

These treaties address human rights, civil rights and labour rights. However, they do not:

  • Confer any benefits on specific nationalities.

  • Apply to residence permits, right to work and so on.

The actual policy and procedures on entry for employment in Hong Kong are not addressed in the Immigration Ordinance and the Immigration Regulations (see Question 1), but are set by way of government policy. This policy is subject to changes, depending on new work visa policies and schemes announced and implemented in response to the perceived needs of employers in the business community and the economy of Hong Kong.

Case law

Case law is another source of law relating to immigration. Challenges to certain provisions of the Immigration Ordinance have occurred and are likely to occur in future on the ground that these provisions contravene or are inconsistent with the Basic Law and are therefore unconstitutional (see Question 3).

Conflicts of law

3. What potential conflicts (if any) arise between the various sources of law?

A recent example of the challenges to certain provision of the Immigration Ordinance is the Court of Final Appeal's (CFA) decision in Vallejos v Commissioner of Registration (FACV 19/2012) and a related case, Domingo v Commissioner of Registration of Persons Tribunal (FACV 20/2012). The court held that a domestic helper is not entitled to permanent residency and that section 2(4)(a)(vi) of the Immigration Ordinance, which had excluded foreign domestic helpers from accumulating "ordinary residence" towards permanent residency in Hong Kong was not unconstitutional and not in violation of Article 24(2)(4) of the Basic Law.

The CFA decision was based on a thorough analysis of the meaning of "ordinarily resident" without the need to consider "extrinsic materials". The CFA held that:

  • The case was within the Hong Kong Special Administrative Region's (HKSAR) limits of autonomy under Article 158(2) of the Basic Law.

  • There was no need to refer the case to the National People's Congress Standing Committee (NPCSC) for clarification of the national government's 1999 interpretation of the permanent residency law.

Under the Basic Law, the CFA must seek an interpretation from Beijing if the relevant provisions of the Basic Law concern affairs that are Beijing's responsibility, or related to Beijing-Hong Kong ties.

The CFA judgment clearly analysed the court's jurisdiction under Article 158 of the Basic Law and noted that before the CFA can make a reference to the NPCSC, it must be satisfied that the following conditions are fulfilled:

  • Classification.

  • Necessity.

  • Arguability.

HKSAR courts (including the CFA) can adjudicate on their own the provisions of the Basic Law which are within the limits of the autonomy of the HKSAR. However, CFA must refer a question of interpretation to the NPCSC if the provision of the Basic Law in question relates to affairs which are the responsibility of the Central People's Government, or concerning the relationship between the Central Authorities and the HKSAR. Referral also only needs to be made if it is necessary to interpret such provisions of the Basic Law, and if there is an arguable case. The resulting interpretations of the NPCSC are then binding on the courts.

This judgment has:

  • Confirmed that a domestic helper is not entitled to permanent residency in Hong Kong.

  • Set out the circumstances and requirements where the CFA will be obliged to seek an interpretation of the Basic Law from the NPCSC.

The Vallejos decision has serious implications for children born in Hong Kong of mainland Chinese parents, as the 1999 interpretation by the NPCSC had included comments on the status of both domestic helpers and such children.

The 1999 ruling stated that the legislative intent of the Basic Law on permanent residency was "reflected" in the opinions of the Preparatory Committee of the HKSAR in 1996, which stated that Chinese citizens born in Hong Kong were permanent residents if a parent was lawfully living in Hong Kong when the child was born.

However, in 2001 the CFA ruled that the Committee's opinions were not binding, and decided that children born in Hong Kong to mainland parents had the right of residence regardless of whether the parents were lawful residents.

The Basic Law provides that people who have been "ordinarily resident" in the city for at least seven years are entitled to permanent residency. However, Hong Kong's Immigration Ordinance states that a person living in the city as a contract worker will not be considered "ordinarily resident" during his time in Hong Kong. In deciding not to seek a legal interpretation on the right of residence issues from the Standing Committee in Beijing, the CFA left unresolved another acrimonious issue in Hong Kong, that is, whether the children of mainland Chinese nationals should continue to be entitled to full Hong Kong citizenship if born in Hong Kong.

Hong Kong's strong educational system, excellent medical care, along with the visa-free access that HKSAR passport holders enjoy to 154 countries and territories, led to a surge in mainland women coming to the city to give birth.

In response, the HKSAR Government has banned mainland mothers without a Hong Kong husband from scheduling births at Hong Kong hospitals. It has also said that it will continue to review legal measures that may make citizenship harder to obtain for the Hong Kong-born children of mainland couples.

 

Business immigration

Unsponsored business-related immigration

4. What are the primary options available for unsponsored work and investment in your jurisdiction?

The primary option available for unsponsored business-related immigration is the Entry for Investment as Entrepreneurs and the Quality Migrant Admission Scheme (QMAS). The Capital Investment Entrant Scheme (CIES), which was first introduced on 27 October 2003, was suspended on 15 January 2015.

Self-employment

There is no independent or unsponsored employment visa category. However, persons interested in unsponsored work or self-employment can apply for an employment visa under the category of Entry for Investment as Entrepreneurs by:

  • Establishing a business in Hong Kong.

  • Actively engaging in the provision of services rendered by that business.

Dependants of visa holders can:

  • Be self-employed.

  • Take up employment.

  • Join in or establish a business in Hong Kong.

This does not apply to those who are under the sponsorship of persons admitted into Hong Kong to study, unless they have obtained prior permission from the Hong Kong Immigration Department (HKID).

Entrepreneurs

Entrepreneurs who wish to establish or join in a business in Hong Kong can submit an application for Entry for Investment as Entrepreneurs. This visa category is not available to Chinese residents of mainland China. The essential requirement for approval is whether the business in which the entrepreneur has invested is of substantial benefit to the economy of Hong Kong. HKID will also favourably consider applications by start-up businesses if both:

  • The business is supported by a government-backed programme that includes a rigorous vetting and selection process.

  • The applicant is the proprietor of the business or the partner of a key researcher of the relevant project.

Process. The applicant must submit evidence that he has:

  • A good educational background and technical qualifications.

  • Proven professional activities and relevant experience.

  • Professional achievements.

There is no prescribed minimum investment amount or a minimum number of jobs that must be created. However, a successful application almost always includes evidence supporting that:

  • Local jobs have been created or will be created by the business within a reasonable time.

  • Local vendors and suppliers will benefit from the commercial activities of the investor's company.

The actual amount of capital invested to qualify for this visa category will depend on the nature of the business and its financial viability. At a minimum, the business must be sufficiently capitalised to finance the start-up costs, including:

  • Securing physical premises.

  • Hiring one to two local employees.

  • Fulfilling the short-term cash flow needs of the company as its business activities get underway.

Depending on the nature of the business and the nationality and professional background of the investor, it is possible to invest as little as HK$390,000 to HK$780,000 and still qualify for an employment (entry for investment) visa. While all applicants must officially meet the same criteria, in the author's experience, a more relaxed standard seems to apply to well-educated Americans, Canadians, and nationals of Western European countries with strong prior professional/business experience. However, this does not mean that a one-man business operating from home on a low budget or subleasing a small part of an office with limited capital at risk and which generates modest revenues will be approved.

Generally, if the investor invests less than HK$1 million, the application will be much more closely scrutinised. In any event, an applicant must, at a minimum, demonstrate that he has made a long-term commitment to Hong Kong by:

  • Executing a commercial lease for adequate business premises.

  • Demonstrating that the entity has been adequately capitalised for the type of business activities it is embarking on.

  • Providing:

    • documentary evidence of the business entity created;

    • a detailed and comprehensive business plan to explain how that business will substantially benefit Hong Kong in the long term.

The HKID will also require:

  • A business profile with explanation of the mode of operations of the business.

  • A listing of its business connections and partnerships in Hong Kong and overseas.

  • Proof of business activities (such as letters of credit, bills of lading, shipment papers, contracts/agreements reached and realised).

  • A full résumé of the applicant's background, as well as a full description of the post to be taken up by the applicant.

  • Letters of reference from local business associates, vendors, providers of service or manufacturers.

  • Documents verifying the financial standing and source of finance of both the applicant and the company, including:

    • bank account statements;

    • bank reference statements;

    • banking facilities letters; and

    • financial statements.

A business entity that seems small and marginal may however be of substantial benefit to the economy of Hong Kong if either:

  • It is the buying, liaison, or representative office of a substantial and reputable overseas company that has given the investor's newly established business the full financial support of the overseas entity.

  • It already has well-established, reputable, and reliable Hong Kong customers and suppliers.

If the business is already well established and has audited financial statements and a good track record, the applicant can be readily approved for the employment (entry for investment) visa on the basis of his shareholdings in the business enterprise. In this case, once the application is approved, the applicant's representative in Hong Kong can collect the visa/entry permit label and send it to the applicant and any dependants so that they can affix the label to their passports and enter Hong Kong as "employment" and dependant visa holders.

Length of leave. The maximum validity of an initially approved Entry for Investment as Entrepreneurs employment visa is 24 months. Once approved, the notification is sent by fax to the applicant's representative in Hong Kong. The representative collects an employment entry visa sticker label by paying a visa fee at the HKID. The entry visa sticker label is valid for three months from the day of issuance and must be forwarded to the applicant overseas to affix to a blank visa page of his passport. The applicant must apply for admission to Hong Kong within three months.

Extensions. Visa extensions under the Entry for Investment as Entrepreneurs visa are granted on a "three-three" year pattern, and can be applied for no later than four weeks before the visa expiry date. The applicant must submit:

  • The relevant visa extension application forms.

  • Employment confirmation in the form of an employment reference letter issued by the applicant's company.

Sometimes, the HKID will conduct a business review while adjudicating the visa extension. In such cases, the HKID will issue a letter to the applicant and/or his or her representative to request additional documents and information concerning the company's business.

Investors

The Capital Investment Entrant Scheme (CIES) was first launched by the HKSAR government on 27 October 2003 as a passive investment scheme to attract investors who:

  • Were looking to make a substantial capital investment in Hong Kong.

  • Did not wish to set up, join in, or run a business themselves.

The CIES was applicable to foreign nationals and Chinese nationals who have obtained permanent resident status in a foreign country.

The CIES programme was suspended on 15 January 2015 until further notice, as the government believes that attracting passive capital investment into Hong Kong is no longer a priority and that the focus should now be on attracting talent, professionals, and innovative entrepreneurs to contribute to the economy.

As a result, the only category of visa now available for investors is Entry for Investment as Entrepreneurs.

Length of leave. The approved CIES visa is valid for a maximum of 24 months.

Extensions. Although the CIES programme has been suspended, the following applicants can still apply for visa extensions:

  • Applicants who already hold a CIES visa.

  • Dependants of these applicants who hold Hong Kong dependant visas.

The maximum validity of each CIES visa extensions is two years. An application can be submitted several months before the visa expiry date. The applicant must submit the following in a timely manner and in accordance with the CIES rules:

  • The required visa extension application forms.

  • An annual declaration that the funds remain in "eligible investment".

CIES entrants can apply to renew their CIES visa for a cumulative period of seven years. Once they exceed the seven-year period, they can apply for permanent residency if they can prove that they have been "continuously ordinarily resident" for seven years. Some CIES entrants may not be able to fulfil the continuous ordinary residence requirement as they may have prolonged periods of absences from Hong Kong during their seven year period of "continuous residence".

However, in recognition of the contribution the CIES entrants have made to the local economy through investing in the permissible investment assets in Hong Kong for at least seven years, they can apply for "unconditional stay" at the end of the seventh year. If successful, they can freely dispose of the permissible investment assets under the CIES without jeopardizing their status.

A person who is granted unconditional stay can enter and stay in Hong Kong without being subject to any conditions or limitations. However, he/she can lose his or her status if he/she is absent from Hong Kong for a continuous period of 12 months.

Quality Migrant Admission Scheme

Quality Migrant Admission Scheme (QMAS) was implemented on 28 June 2006 to attract highly skilled or talented people from mainland China and overseas to settle in Hong Kong without the need for employer sponsorship.

The scheme is open to all applicants except to nationals from countries which the HKSAR government believes pose security or immigration risks. These countries include:

  • Afghanistan.

  • Cambodia.

  • Cuba.

  • Laos.

  • Democratic People's Republic of Korea (North Korea).

  • Nepal.

  • Vietnam.

To apply for assessment under of the two point-based tests, the applicant must be:

  • Aged 18 years old or above at the time of filing the application.

  • Able to demonstrate that he is capable of supporting and accommodating himself and his dependants (if any) on his own financial resources without relying on public assistance during his stay in Hong Kong.

  • Of good character (that is, he must not have any criminal record or adverse immigration record in Hong Kong or elsewhere).

  • Be proficient in written and spoken Chinese (Putonghua or Cantonese) or English.

  • Of good education background, usually a university degree from a recognised university or a tertiary educational institution. In special circumstances, good technical qualifications, proven professional abilities and/or experience and achievements supported by documentary evidence can be considered.

Applicants who meet the above conditions can choose whether to be assessed under a general points test or an achievement-based points test.

General points test (maximum 165 points) . The five factors of the general points test are:

  • Age. An applicant can be awarded points on a scale according to age, the maximum being 30 points for those aged 18 to 39.

  • Academic/professional qualifications. An applicant can acquire points for either academic or professional qualifications, the maximum being 45 points for those with two or more doctoral degrees.

  • Work experience. The maximum of 50 points is awarded for ten or more years of graduate or specialist level work experience (including at least five years in a senior role).

  • Language proficiency. The maximum of 20 points is awarded for being proficient in written and spoken Chinese (Putonghua or Cantonese and English).

  • Family background. The maximum 20 points are awarded as follows:

    • five points for one immediate family member (spouse, parents, siblings, children) if he or she is a Hong Kong permanent resident residing in Hong Kong;

    • five points for each accompanying married spouse educated to the equivalent level of a degree or above;

    • five points for each unmarried dependant child under 18 years old (with maximum of ten points).

The minimum passing mark is subject to change but is currently set at 80.

Achievement-based points test. This test is for individuals with exceptional talent or skill who have outstanding achievements.

A person who applies under this test is either awarded a full score of 165 points or granted no points and refused immediately. To qualify, an applicant must meet either of the following criteria:

  • He has received an award of exceptional achievement (such as Olympic medals, a Nobel Prize and other national/international awards).

  • He can show that his work:

    • has been acknowledged by his peers; or

    • has contributed significantly to the development of his field (such as obtaining a lifetime achievement award from industry).

However, applicants who pass the general points test or the achievement-based points test will be ranked according to the scores awarded. High-scoring applicants are not necessarily granted a quota allotment. Instead, these applicants will be short-listed for further assessment and passed on to the Advisory Committee for the recommendation of the allocation of available quota based on:

  • The socio-economic needs of Hong Kong.

  • The sectoral mix of candidates. "Sectoral" is generally interpreted as referring to the applicant's involvement or background in education, business, industry, the professions, the arts, or culture.

  • Other relevant factors.

The Advisory Committee, which is appointed by the Chief Executive, comprises of official and non-official members and will consider the following factors before determining if the applicant qualifies under the QMAS:

  • The university from which the applicant graduated.

  • Whether the applicant furthered his or her studies overseas.

  • The experience of the applicant.

  • His achievement in school or at work.

Approval-in-principle. The Advisory Committee meets on a quarterly basis to issue successful applicants with a quota through an approval-in-principle letter by the HKID. The Advisory Committee will invite these applicants to come to Hong Kong for an interview in person to verify the documents they have submitted. At the interview, the applicant must satisfy the HKID that all statements made and information provided are true and complete before a formal approval is granted.

Length of leave. Successful applicants admitted through the general point test are granted an initial stay of 24 months. Successful applicants admitted through the achievement-based points test are granted a stay of eight years.

Extensions. For persons admitted through the general points test, the extension pattern is "three-three" year. The applicant must provide evidence that he or she has taken steps to settle in Hong Kong by taking up residence (that is, by securing gainful employment or establishing a business). To be eligible for a further extension of stay, the applicant must provide evidence that he or she has:

  • Settled in Hong Kong.

  • Made a contribution to Hong Kong (such as engaging in graduate, specialist or senior level gainful employment or establishing a business of a reasonable size in Hong Kong).

If the applicant cannot meet this requirement, an extension of shorter duration may be granted by the Director of Immigration if he deems this appropriate. However, if the applicant is still not able to prove that he or she has settled in and a made a contribution to Hong Kong by the end of the second year, further extensions of stay will normally not be granted.

In addition, persons admitted through the general points test may benefit from a longer visa extension if they qualify as "top-tier" entrants. A top tier entrant is an entrant who has:

  • Been permitted to take up employment for not less than two years.

  • Had an assessable income of not less than HK$2 million in the previous year of assessment.

Successful top-tier entrants will be granted a six-year extension of stay.

For persons admitted through the achievement-based points test, the initial duration of stay has been relaxed from one to eight years. Because of the increased duration of initial stay, subsequent extension is usually not needed, unless a shorter period of stay is granted due to the limited validity of the passports or travel documents of the entrants. If an extension of stay is required, the applicant must demonstrate that he is capable of supporting and accommodating himself and his dependants, if any, on his own financial resources during his stay in Hong Kong.

Admission scheme for the second generation of Chinese Hong Kong permanent residents (ASSG)

ASSG is a pilot programme launched on 4 May 2015 as another measure to:

  • Attract talents and professionals to work or reside in Hong Kong.

  • Enhance the economic competitiveness of Hong Kong.

Specifically, ASSG targets the second generation of Chinese Hong Kong permanent residents to return to Hong Kong from overseas. Applicants are not required to have secured an offer of employment in Hong Kong on application for entry under this scheme. Applicants must:

  • Be aged between 18 and 40 years old.

  • Be born overseas (that is, not in mainland China, Hong Kong, the Macao Special Administrative Region, or Taiwan).

  • Have at least one parent who:

    • holds valid Hong Kong permanent identity card at the time of application; and

    • was a Chinese national who had settled overseas at the time of the applicant's birth.

  • Be proficient in written and spoken Chinese or English.

  • Have sufficient financial means.

  • Be able to meet his or her living expenses (and those of any dependants) for maintenance and accommodation in the HSAR without resource to public funds.

  • Have a good education background, usually a university degree, but also (in special circumstances):

    • good technical qualifications;

    • proven professional abilities and/or relevant experience; and

    • achievements supported by documentary evidence .

Length of leave. Applicants will normally be granted an initial stay of 12 months.

Extensions. To apply for an extension of stay, persons admitted through the ASSG must either:

  • Submit proof that they have secured an offer of employment (which is at a level commonly taken up by degree holders and with a remuneration package at market level).

  • Have established or joined a business in Hong Kong.

Successful applicants will normally be permitted to remain on the "two-two-three" year pattern.

Business visitors

Nationals of about 170 countries and territories can enter Hong Kong as business visitors or for tourism purposes on a visa-free basis for a period of entry ranging from seven days to 90 days, depending on the visitor's nationality.

Sponsored business-related immigration

5. What are the options available for sponsor-based employment in your jurisdiction?

Types of sponsor-based employment visas

Sponsor-based employment visa categories include employment as a professional under the:

  • General Employment Policy (GEP).

  • Admission Scheme for Mainland Talents and Professionals (ASMTP).

  • Immigration Arrangements for Non-local Graduates (IANG).

  • Training visa.

General requirements

GEP. GEP has been a long standing category of employment visa for foreign nationals who meet the employment eligibility criteria and normal immigration requirements such as:

  • Holding a valid travel document with adequate returnability to his/her country of residence or citizenship.

  • Being of clear criminal record and raise no security or criminal concerns to the Hong Kong Special Administrative Region (HKSAR).

  • Having no likelihood of becoming a burden to the HKSAR.

GEP is quota-free and non-sector specific. Chinese nationals can also apply under this category if the following requirements are met:

  • They have their permanent residence overseas.

  • They have been residing overseas for at least one year immediately before the submission of the application.

  • They submit their application from an overseas country.

In these cases, "overseas" means residence in countries or territories outside mainland China, the Macao Special Administrative Region and the HKSAR.

An application for a visa/entry permit to take up employment under the GEP may be favourably considered if the following requirements are met (see www.immd.gov.hk/pdforms/id939a.pdf) There is no security objection and no known record of serious crime in respect of the applicant.

  • The applicant has a good education background, usually a university degree in the relevant field, but in special circumstances, good technical qualifications, proven professional abilities and/or relevant experience and achievements supported by documentary evidence may also be accepted.

  • There is a genuine job vacancy.

  • The applicant has a confirmed offer of employment and is employed in a job relevant to his academic qualifications or working experience that cannot be readily taken up by the local work force.

  • The remuneration package including income, accommodation, medical and other fringe benefits is broadly commensurate with the prevailing market level for professionals in the HKSAR.

ASMTP. ASMTP was established on 15 July 2003 to:

  • Meet Hong Kong's manpower needs.

  • Facilitate local economic and other development.

  • Enhance Hong Kong's competitiveness in the globalised market.

It is equivalent to the GEP but is specifically for Chinese residents of mainland China who meet the employment eligibility criteria (that is, they possess qualifications and professional experience which are not readily available in Hong Kong). The ASMTP requirements are similar to the GEP ones. Like the GEP, the ASMTP is quota-free and non-sector specific. The maximum validity of an initial approved employment visa is 24 months.

The employing companies must submit the application in Hong Kong directly to the Hong Kong Immigration Department (HKID). Mainland residents visiting Hong Kong cannot request to prolong their stay on the grounds of having submitted applications under this scheme.

IANG. IANG is a visa category specifically tailored for applicants who:

  • Are non-local graduates.

  • Have obtained a degree or higher qualification in a full-time and locally accredited programme in Hong Kong which allows them to stay or return to work in Hong Kong.

IANG applicants who submit applications to the HKID within six months after the date of their graduation (that is, the date shown on their graduation certificates) are classified as "non-local fresh graduates". Those who submit applications after six months of the date of their graduation are classified as "returning non-local graduates".

Non-local fresh graduates who wish to apply to stay and work in Hong Kong are not required to have secured an offer of employment on application. Returning non-local graduates who wish to return to work in Hong Kong must secure an offer of employment on application. The application will be considered if the job is at a level commonly taken up by degree holders and the remuneration package is at market level.

Training visa. Foreign national applicants with lesser professional experience can apply for a training visa. Chinese residents of mainland China are not eligible to submit applications under this category unless they are employees and business associates of well-established and multinational companies based in Hong Kong. In certain situations, a training visa is convenient for overseas companies who wish to send junior employees to their branch offices in Hong Kong (with the Hong Kong office being the local sponsor) on short-term rotation training or internship programmes.

An application may be favourably considered if the following apply:

  • The applicant has no criminal record.

  • There is no security objection against the applicant.

  • The bona fides of the applicant and the sponsoring company are satisfied. The sponsoring company is a well-established company, capable of providing the proposed training.

  • There is a contract signed between the sponsoring company and the applicant.

  • The sponsoring company guarantees in writing that will:

    • maintain and repatriate (where necessary) the applicant;

    • provide the applicant with training in the sponsor's premises until the end of the agreed period, after which the applicant will return to his place of residence.

  • The proposed duration and content of the training programme can be justified.

Length of leave

GEP and ASMTP. The maximum validity of an initial approved visa is 24 months. Similar to Entry for Investment for Entrepreneurs visas, once the application is approved, the notification is sent by fax to the applicant's representative in Hong Kong or the sponsoring company. The applicant's representative or the sponsoring company pay a visa fee at the HKID and collect an employment entry visa sticker label. The entry visa sticker label is valid for three months from the day of issuance, and must be forwarded to the applicant overseas to affix to a blank visa page of his passport. Once he has affixed the label, the applicant can apply for admission to Hong Kong within three months.

IANG. Both non-local fresh graduates and returning non-local graduates can be granted an initial stay of 12 months with no other conditions of stay, provided that normal immigration requirements are met. The normal immigration requirements include:

  • Holding a valid travel document with adequate returnability to his/her country of residence or citizenship.

  • Being of clear criminal record and raise no security or criminal concerns to the HKSAR.

  • Having no likelihood of becoming a burden to the HKSAR.

Training visa. The maximum validity of an approved training visa is 12 months.

Extensions

GEP and ASMTP. Visa extensions are granted on a "three-three" year pattern. Visa holders can apply for an extension within four weeks of the visa's expiry date. The applicant must submit:

  • The required visa extension application forms.

  • A support letter to confirm the employment from the employer or the sponsoring company.

"Top-tier" entrants can also apply for an extension. The top-tier category is applicable to entrants under the GEP and ASMTP. A top tier entrant is an entrant who has:

  • Been permitted to take up employment for not less than two years.

  • Had an assessable income of not less than HK$2 million in the previous year of assessment.

Successful top-tier entrants will be granted an extension of stay for a period of six years without other conditions of stay. The six-year visa extension policy for top-tier does not apply to entrants under the Entry for Investment as Entrepreneurs visa.

IANG. Persons admitted under the IANG can apply for extension of stay within four weeks before their visa expires. Non-local fresh graduate applicants must have secured an offer of employment which is at a level commonly taken up by degree holders and the remuneration package is at market level. In addition, the local employment sponsors of the applicants must submit:

  • The required visa extension application forms.

  • Employment confirmation in the form of an employment reference letter.

Those who have established or joined a business in Hong Kong under the IANG present proof of their business. Successful applicants will normally be permitted to remain on the "two-two-three" year pattern.

Training visa. Training visas are not renewable.

Requirements for sponsors

6. What are the requirements for becoming a sponsor of employment-based migrants and what are the role and reporting duties of sponsors?

Requirements to become a sponsor

Generally, a local Hong Kong sponsor must:

  • Be an entity properly established under the Companies Registry of the Hong Kong Special Administrative Region.

  • Possess a valid Business Registration Certificate.

  • Demonstrate that it is financially viable and is engaged in active business. 

If the sponsor is a new business venture that is being set up to sponsor overseas professionals, the Hong Kong Immigration Department (HKID) is likely to:

  • Raise questions on the business's financial viability.

  • Scrutinise the business plans, infusion of capital and so on more closely to ensure there is a financial capability to sponsor the employees sought to be brought into Hong Kong.

Role of sponsors

A local employment sponsor must ensure its foreign national employees have proper authorisation from the HKID to work under its sponsorship in Hong Kong. It must also provide up-to-date and accurate information on:

  • Its business activities and financial viability.

  • The qualifications of the applicant for the HKID's adjudication of the applicant's employment visa application.

Reporting duties of sponsors

A local employment sponsor assumes responsibility for the employment visa applicant's repatriation to his place of domicile if the applicant fails to leave Hong Kong at expiry of the limit of stay granted by the HKID. In addition, a local employment sponsor must report the following to the HKID immediately:

  • The termination of employment of the employment visa holder.

  • Any changes in the corporate set-up of the local employment sponsor due to corporate restructuring.

  • Any changes to the entity's name.

Civil and criminal penalties for sponsors

7. What are the types of civil and criminal penalties that sponsors may face for non-compliance with the rules?

Civil penalties

Not applicable in Hong Kong.

Criminal penalties

Persons admitted to Hong Kong on visitor status cannot be lawfully employed without first obtaining approval from the Director of Immigration.

The employer of a person who is employed unlawfully commits an offence and is liable to both (section 17I, Immigration Ordinance, Cap 115):

  • A fine of HK$350,000.

  • Three years' imprisonment.

A person with visitor's status who works without obtaining approval is in breach of his/her condition of stay and is liable to both (section 41, Immigration Ordinance, Cap 115):

  • A fine of HK$50,000.

  • A maximum of two years' imprisonment.

Common issues or concerns for business immigration

8. What common issues or concerns may arise under business immigration in your jurisdiction?

As an international financial centre, Hong Kong maintains an extremely flexible employment policy for highly skilled business professionals. There is, however, growing concern among some employers who have been unable to successfully sponsor employees from mainland China who have practical and unique skills acquired on the job, which may not necessarily be reflected in an academic degree or a certificate from a traditional entity.

 

Dependants

9. What persons qualify as dependants (for example, family members)? What are the general requirements and restrictions for bringing dependants into your jurisdiction for sponsored and unsponsored business-related immigration?

Persons qualifying as dependants

Spouses and children. The spouse and any unmarried dependent children below the age of 18 qualify as dependants. Foreign nationals who entered Hong Kong as business visitors or for tourism purposes on a visa-free basis are not considered residents of Hong Kong. Their spouse and children can travel to Hong Kong as visitors on a visa-free basis but will not be admitted as dependants.

Parents. Parents of the principal applicants under the following visa categories are not eligible for dependant visas:

  • Entry for Investor as Entrepreneurs.

  • Quality Migrant Admission Scheme (QMAS).

  • General Employment Policy (GEP).

  • Admission Scheme for Mainland Talents and Professionals (ASMTP).

  • Immigration Arrangements for Non-local Graduates (IANG).

  • Training visa.

The ASSG scheme does not provide for dependent visas for parents because an ASSG applicant must establish that he or she has at least one parent who:

  • Holds a valid Hong Kong permanent identity card at the time of application.

  • Was a Chinese national who had settled overseas at the time of the applicant's birth. If the other parent does not have legal status, the permanent resident parent can apply for a dependent visa for his/her spouse to reside in Hong Kong as a dependant.

Same-sex marriage and same-sex or heterosexual domestic partnerships. Same-sex marriage and same-sex or heterosexual domestic partnerships are not recognised by the Hong Kong Special Administrative Region (HKSAR) government and are not eligible to apply for Hong Kong dependant visas.

However, they can apply for long-term/prolonged visitor visas to accompany the principal applicant if they can demonstrate a pre-existing cohabitating relationship before coming to Hong Kong

A prolonged visitor visa holder is not entitled to work, start a business, or take up a formal course of study unless he/she applies for and is granted an employment, investment, or student visa based on his or her own qualifications.

General requirements and restrictions

Dependants can apply for dependant visas under the sponsorship of the principal applicant applying for employment visas under one of the following categories:

  • Entry for Investor as Entrepreneurs.

  • QMAS.

  • ASSG.

  • GEP.

  • ASMTP.

  • IANG.

  • Training visas.

To obtain a visa, dependants must:

  • Meet the normal immigration requirements. The normal immigration requirements include, among others (see www.immd.gov.hk/pdforms/ID(E)998.pdf):

    • holding a valid travel document with adequate returnability to his/her country of residence or citizenship;

    • being of clear criminal record and raise no security or criminal concerns to the HKSAR;

    • having no likelihood of becoming a burden to the HKSAR.

  • Provide reasonable proof of a genuine relationship between them and the sponsor.

  • There is no known record to the detriment of the dependant.

  • Prove that the sponsor can:

    • support the dependant's living at a standard well above the subsistence level; and

    • provide him/her with suitable accommodation in Hong Kong.

The length of stay of dependants will normally be linked to that of their sponsors. Any subsequent applications for extension of stay will be considered only if both the:

  • Applicant continues to meet the eligibility for entry for residence as dependant.

  • Sponsor remains a bona fide HKSAR resident living in Hong Kong.

Dependants can take up employment or studies in Hong Kong.

 

Settlement and citizenship

10. What is the general time frame and processes for obtaining permanent residence and citizenship in your jurisdiction for the above-mentioned business categories?

General process and time frame for obtaining permanent residence

Under the Immigration Ordinance, a person can apply for permanent residence or a "right of abode" if he/she has ordinarily resided in Hong Kong for a continuous period of seven years on a qualifying residence visa such as:

  • Student visa.

  • Entry for Investment as Entrepreneur visa.

  • Quality Migrant Admission Scheme (QMAS).

  • General Employment Policy (GEP).

  • Admission Scheme for Mainland Talents and Professionals (ASMTP).

  • Immigration Arrangements for Non-local Graduates (IANG).

  • Admission scheme for the second generation of Chinese Hong Kong permanent residents (ASSG).

  • Training visa.

However, holders of foreign domestic worker employment visas are not eligible to apply.

A person is regarded as "ordinarily resident" in Hong Kong if he:

  • Remains in Hong Kong legally, voluntarily and for a settled purpose.

  • Does not cease to be ordinarily resident if he is temporarily absent.

The applicant must submit a Form ROP145 (Application for Verification of Eligibility for Permanent Identity Card) and:

  • Specify absences from Hong Kong (especially for a continuous period of six months or more) on the application form.

  • Provide an explanation and reasons for the absence.

The following factors are considered when determining whether the absence is interruptive of "continuous ordinary residence":

  • The reason, duration and frequency of any absence from Hong Kong.

  • Whether the applicant has a habitual residence in Hong Kong.

  • Whether the applicant is employed by a company based in the Hong Kong Special Administrative Region.

  • The whereabouts of the principal members of his family (spouse and minor children).

The Hong Kong Immigration Department (HKID) will consider all the facts of the case, including any circumstances that may indicate that the applicant is no longer habitually a HKSAR resident.

Employment visa holders or their dependants will usually have their cases reviewed within four to six weeks.

General process and time frame for obtaining citizenship

A foreign national or a stateless person who is willing to abide by China's Constitution and Laws can apply for naturalisation as a Chinese national if either of the following applies (Article 7, Nationality Law of the People's Republic of China):

  • He has near relatives who are Chinese nationals.

  • He has settled in China.

  • There are other legitimate reasons.

A foreign national who has the right of abode or permanent residence in Hong Kong can apply for naturalisation. The present processing time for an application is about ten to 12 months.

Although each application will be considered on its own merits, there are many factors considered in an application for naturalisation, such as whether the applicant has:

  • A near relative who is a Chinese national having the right of abode in Hong Kong.

  • The right of abode in Hong Kong.

  • Habitually resides in Hong Kong.

  • A reasonable income to support himself and his family.

  • Paid taxes in accordance with the law.

  • Sufficient knowledge of the Chinese language.

  • Any principal members of his family (spouse and minor children) living in Hong Kong.

It is also important to consider whether:

  • The applicant:

    • is of good character and sound mind;

    • intends to continue to live in Hong Kong once the naturalisation application is approved.

  • There are other legitimate reasons to support the application.

The HKID has a great deal of discretion in adjudicating naturalisation cases, with emphasis given to different factors at different points in time based on policy and security considerations.

A case can only be "approved in principle", subject to the applicant providing proof that he/she has renounced his/her present nationality. Any person whose application for naturalisation has been approved must renounce any other foreign nationality (Article 8, Nationality Law of the People's Republic of China).

Formal approval will be granted and a Certificate of Naturalisation as a Chinese National will be issued once the applicant can present documentary proof that he has renounced his/her present nationality. He/she can then apply for a:

  • New HKSAR identity card to signify his or her new identity as a HKSAR permanent resident and a Chinese national.

  • HKSAR passport, which provides visa-free entry to some 154 countries and territories.

Currently, many foreign nationals obtain naturalisation even if they do not have Chinese language proficiency if they:

  • Are highly educated senior business executives who pay substantial taxes in Hong Kong.

  • Have shown their commitment to Hong Kong.

  • Have been permanently settled for many years in Hong Kong.

  • Are of benefit and an asset to the Hong Kong community.

 

Present climate and future legislation

Present climate and trends

11. What are the recent trends, both political and social, that have impacted your jurisdiction with regard to immigration policy and law?

One of the most significant changes in immigration policy in Hong Kong in 2015 is the emphasis of retaining and attracting talent, professionals, and innovative entrepreneurs to build up Hong Kong's talent pool. Many tangible measures have already been implemented by the Hong Kong Immigration Department (HKID) in the second quarter of 2015 in this respect.

In view of the steady growth and improvement of the economy of Hong Kong, attracting capital investment entrants is no longer a priority. Therefore, the Capital Investment Entrant Scheme (CIES) has been suspended as of 15 January 2015. However, the HKID will continue to process and approve the applications already submitted before this date. The HKID will also continue to allocate manpower and resources to service entrants and their dependants on valid CIES visas in annual review matters and visa extension applications.

While the HKID continues to use its existing visa categories as channels to attract talents and professionals, from May 2015 the HKID relaxed the initial duration of stay from 12 months to 24 months for all entrants admitted under the following schemes:

  • Entry for Investment as Entrepreneurs.

  • General Employment Policy (GEP).

  • Admission Scheme for Mainland Talents and Professionals (ASMTP).

  • General point test of the Quality Migrant Admission Scheme (QMAS).

The extension pattern has also been changed from the "two-two-three" year pattern, to a "three-three" year pattern.

In addition, the HKID has also set up a new policy for "top-tier" entrants under the following schemes:

  • GEP.

  • ASMTP.

  • General Point Test of QMAS.

A top-tier entrant is an entrant who has:

  • Been permitted to take up employment for not less than two years.

  • Had an assessable income of not less than HK$2 million in the previous year of assessment.

Successful top-tier entrants will be granted an extension of stay for a period of six years without other conditions of stay. The six-year visa extension policy for top-tier does not apply to entrants under the Entry for Investment as Entrepreneurs scheme.

For entrants under the achievement-based points test of QMAS, the initial duration of stay has been relaxed from one year to eight years. Because of the increased duration of initial stay, subsequent extension is usually not required.

Another way to attract and retain talent in Hong Kong is through the enhancement of the existing entry arrangement for non-local students. From 17 March 2014, eligible non-local students can apply to enter Hong Kong to take up studies in:

  • Full-time locally accredited local programmes at sub-degree level. These students can also take up mandatory and study/curriculum-related internships.

  • Full-time non-local programmes at undergraduate or above level. These students can also take up study/curriculum-related internships.

Once they complete their studies, the non-local students can apply for visas under IANG to remain or return to Hong Kong to work.

All of these flexible arrangements are targeted at attracting and retaining talent through offering a longer duration of stay in the initial visas and subsequent visa extensions. This reduces the paperwork that entrants must submit to apply for visa extensions applications. The initial stay and pattern of visa extensions for these visa schemes:

  • Add up to eight years of stay in Hong Kong.

  • Can facilitate the entrants' applications for right of abode to become permanent residents of Hong Kong (a minimum of seven years of ordinary residence).

Future legislation

12. Are there any anticipated changes in the immigration laws of your jurisdiction?

Domestic legislation

The liberal, transparent and flexible immigration policy towards businesses, investors and professionals who wish to invest and work in Hong Kong is a well-established policy. The Government of the Hong Special Administrative Region (HKSAR) will make every effort to continue to facilitate the efficient processing of visas for persons who are seen to contribute to Hong Kong's economic development and prosperity, to attract and retain talent and professionals from overseas and mainland China.

To achieve this, the HKSAR Government will ensure its immigration policies and directions align with the domestic legislation, policies in other areas and issues that concern and/or affect the people of Hong Kong. The Court of Final Appeal's decision in Vallejos v Commissioner of Registration (FACV 19/2012) reaffirmed the principle that the HKSAR Government has:

  • Discretionary power to decide who is eligible for residency.

  • The sovereign authority to decide the extent to which the status of permanent resident should be granted to foreign nationals.

The HKSAR Government will also strive to make sure that the right of abode will not be granted to unskilled workers, such as foreign domestic workers.

In collaboration with various HKSAR departments, the Hong Kong Immigration Department (HKID) will continue to enforce its administrative and immigration measures to control and deter the large influx of mainland China women who seek ways to enter Hong Kong to give birth in Hong Kong so that that their children can automatically acquire the right of abode in Hong Kong under the Basic Law.

International issues

On the matters of refugees and non-refoulement, the HKID commenced a unified screening mechanism (USM) operation on 3 March 2014. Under the USM, the HKID must assess claims for non-refoulement lodged by foreigners not having the right to enter and remain in Hong Kong on applicable grounds, including:

  • Risks of torture, as defined under Part VIIC of the Immigration Ordinance (Cap. 115, Laws of Hong Kong).

  • Torture or cruel, inhuman or degrading treatment or punishment under Article 3 of section 8 of the Hong Kong Bill of Rights Ordinance (Cap. 383, Laws of Hong Kong).

  • Persecution with reference to the non-refoulement principle under Article 33 of the 1951 Convention Relating to the Status of Refugees (Refugee Convention) based on the statutory mechanism of the Immigration Ordinance for assessing torture claims that meet high standard of fairness as required by law.

USM does not affect the HKSAR Government's position that the Refugee Convention and its 1967 Protocol have never been applied to Hong Kong. It is the HKSAR Government's firm policy to not determine the refugee status of or granting asylum to anyone. Therefore, persons making a non-refoulement claim in Hong Kong will not be treated as "refugees" and will not be allowed to settle in Hong Kong, regardless of the result of their claim, and must leave when the risk or torture they allegedly face ceases to exist. However, if a non-refoulement claim is substantiated under the USM ground of persecution, the claimant will be referred to the United Nations High Commissioner for Refugees for consideration of arrangement of resettlement in a third country.

Non-refoulement claimants in Hong Kong who are illegal immigrants or overstayers cannot take up employment in Hong Kong even if their claims are substantiated. A breach of the condition of stay is a criminal offence punishable on conviction by (section 41, Immigration Ordinance, Cap. 115):

  • A maximum fine of HK$50,000.

  • Imprisonment for two years.

Illegal immigrant or people who are subject to a removal order or deportation order cannot take up any employment, whether paid or unpaid, or establish or join any business (section 38AA, Immigration Ordinance).

There has been an increase of claimants lodging claims for non-refoulement on arrival in Hong Kong:

  • 150 cases were referred from control points in the period from 3 March 2013 to 2 March 2014.

  • 200 cases from the start of USM on 3 March 2014 to the end of 2014.

  • 322 cases in 2015.

As of December 2015, there were 10,922 outstanding protection claims which the HKSAR must screen as signatory to the UN Conventions against Torture.

Indians are the second largest group by nationality making protection claims, with 2,093 cases pending in the fourth quarter of 2015 and January 2016. The HKSAR Government has said that Indians could face visa restrictions. Local enforcement agencies have travelled to India in December 2015 to study measures to deal with the abuse of the system.

The HKID is currently conducting investigations on whether anyone has intentionally arranged doubtful visitors to lodge claims for non-refoulement. The HKSAR Government is especially concerned with recent reports concerning some agencies in certain countries suspected of arranging foreign nationals to come to Hong Kong, providing a range of "services" including:

  • Transporting them from the countries to Hong Kong.

  • Providing legal services to ensure that they enter successfully.

  • Lodging a non-refoulement claim for them.

  • Arranging unlawful employment for them while they are pending screening.

Apart from serious abuses to the non-refoulement screening mechanism, these "services" exposed in the reports may also possibly involve a number of serious criminal offences amounting to human trafficking.

 

Online resources

Immigration Department of the Government of the Hong Kong Special Administrative Region

Description. Contains detailed descriptions of different types of visas, eligibility, requirements, application forms and required support documents.

W www.immd.gov.hk/eng/services/index.html

Immigration Department of the Government of the Hong Kong Special Administrative Region

Description. A list of the foreign countries/territories with visa-free status and the period of visa-free admission granted to their nationals.

W www.immd.gov.hk/eng/services/visas/visit-transit/visit-visa-entry-permit.html

Immigration Department of the Government of the Hong Kong Special Administrative Region

Description. Contains the Nationality Law of the People's Republic of China.

W www.immd.gov.hk/eng/residents/immigration/chinese/law.html

Immigration Department of the Government of the Hong Kong Special Administrative Region

Description. Contains a list of countries/territories granting HKSAR passport holders visa-free access or visa-on-arrival. Also contains information on eligibility and requirements for application for right of abode.

W www.immd.gov.hk/pdf/Full_List_of_Visa-free_Access_or_Visa-on-arrival_for_HKSAR_Passport_en.pdf

Labour Department of the Government of the Hong Kong Special Administrative Region

Description. Contains detailed information on applications for the importation of labour under the Supplementary Labour Scheme (a programme to import workers at technical level or lower).

W www.labour.gov.hk/eng/news/content.htm



Contributor profiles

Eugene Chow, Principal

Chow King & Associates

T +(852) 2838 1878
F +(852) 2838 4362
E eugene@chowking-visas.com
W www.chowking-visas.com

Professional qualifications. Pennsylvania, 1976, California, 1978, US

Areas of practice. US, Hong Kong and international immigration matters, including acquisition of alternative citizenship, expatriation of US citizenship, employment visas and permanent residency.

Recent transactions

  • Providing customised advice on the advantages and disadvantages and legal consequences of expatriation.
  • Advising on the acquisition of an alternative citizenship to ensure the person will not be rendered stateless, including:
    • performing due diligence to ensure the legislative basis and legality of a recommended passport programme are sound;
    • liaising and strategising with tax professionals on tax consequences;
    • working with expert professional contacts in various jurisdictions to put into place options in alternative jurisdictions post-expatriation to serve the sophisticated multi-jurisdictional immigration needs of clients in this globalised world.

Languages. English, Chinese (Mandarin and Cantonese)

Professional associations/memberships. Board member, California Board of Legal Specialization Certified Specialist in Immigration & Nationality Law; State Bar of California; Pennsylvania Bar; International Bar Association (IBA); Alliance of Business Immigration Lawyers (AILA); American Immigration Lawyers Association (ABIL).

Publications

  • Contributing author, AILA's Immigration Options for Investors and Entrepreneurs, the Global Business Immigration Practice Guide by the Alliance of Business Immigration Lawyers (LexisNexis Publishers) (2012 – 2015 editions).
  • Contributing author, The Corporate Immigration Review (Law Business Research Ltd.) (Second to Fifth Editions, 2012 – 2015).
  • Contributing author, Immigration Law, Jurisdictional Comparisons, European Lawyer Reference Series (Thomson Reuters) (First Edition, 2013).

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