Do I need to file my accounts with the Companies Registry

Do I Need to File My Accounts with the Companies Registry

No. Audited financial statements are not filed with the Companies Registry. The confusion stems from two distinct filing obligations. The Companies Registry receives your annual return (Form NAR1). Your audited financial statements go to the Inland Revenue Department with your profits tax return.

Hong Kong Companies Registry Accounts Filing

The Companies Registry does not require a standalone submission of your audited financial statements. Under the Companies Ordinance (Cap. 622), the only periodic filing delivered to the Companies Registry is the annual return (Form NAR1). This return contains particulars of the company's directors, secretary, registered office, shareholders and share capital, but not the financial statements themselves.

Audited Financial Statements Filing

File your audited financial statements with the Inland Revenue Department, not the Companies Registry. When the department issues a profits tax return (Form BIR51), you must attach the audited financial statements and tax computations. A practising certified public accountant registered with the HKICPA must conduct the audit. This statutory audit requirement applies to every Hong Kong incorporated company, regardless of size.

Annual Return Accounts Attachment

Accounts are not attached to the annual return. Form NAR1 is filed separately from the financial statements. The annual return is due within 42 days after the anniversary of incorporation or re-domiciliation. For a private company filed on time, the registration fee is HK$105. A private company that has declared itself dormant is exempt from delivering an annual return, but this exemption does not remove the audit requirement unless the company has no significant accounting transactions.

Profit Tax Return Accounts

When you receive a profits tax return from the Inland Revenue Department, you must file it with your audited financial statements. The department issues Form BIR51 to corporations, and the return is generally due within one month of issue. Where a tax representative is appointed, the department publishes a block extension letter setting later dates by accounting date. The financial statements must be prepared in accordance with the applicable financial reporting framework, which may be HKFRS, HKFRS for Private Entities, or the SME-FRF and SME-FRS for companies qualifying for the reporting exemption under section 359.

Reporting Exemption and Audit

A company that qualifies under section 359 of the Companies Ordinance may prepare financial statements under the reporting exemption, applying the SME Financial Reporting Framework and Standard (SME-FRF and SME-FRS) with reduced disclosure requirements. The reporting exemption does not remove the audit requirement. The company must still have its financial statements audited by a practising certified public accountant registered with the HKICPA, and the audited statements must still be filed with the Inland Revenue Department together with the profits tax return.

What to Do Next

File your annual return (Form NAR1) with the Companies Registry within 42 days of the return date. File your audited financial statements with the Inland Revenue Department together with your profits tax return (Form BIR51) by the due date stated on the return or the block extension deadline. Keep your accounting records for seven years as required by the Companies Ordinance. If you qualify for the reporting exemption under section 359, confirm this with your auditor before preparing the financial statements under the SME-FRF and SME-FRS framework.