Hong Kong annual returns can now be filed with iAM Smart+ without an e-filing account

Since 17 August 2026, directors and company secretaries of Hong Kong companies who hold an iAM Smart+ account have been able to file two forms with the Companies Registry without first registering a user account or subscribing to its e-Filing Services. The Registry announced the change in Companies Registry External Circular No. 1/2026, "e-Filing Services for Unregistered Users with 'iAM Smart+'", dated 3 August 2026. It applies to local companies and covers the annual return (Form NAR1) and the notice of change of address of registered office (Form NR1).

What the rules say

Until this change, anyone who wanted to sign or submit documents to the Registry online had first to register a user account and subscribe to the e-Filing Services. The circular presents the new feature as a set of "ready-to-use e-services" for people who file only one or two documents a year.

An eligible user works entirely through the e-Services Portal, completing and submitting the form online, signing it directly with iAM Smart+ and paying any registration fee online before submission. For the annual return, the Registry pre-fills the company's key particulars from its records as at the made-up date of the return. The Registry calls NAR1 and NR1 the initial scope, which suggests other forms may follow, though it has published no list.

iAM Smart is the Hong Kong government's digital identity, operated by the Digital Policy Office. Its basic version offers log-in and form-filling. iAM Smart+ adds digital signing and step-up authentication, and it is the signing function that allows a filing to be made without a Registry account.

Who is affected

The service is open to individuals with an iAM Smart+ account who are directors or company secretaries of a company, or directors or company secretaries of a corporate officer of a company. It applies to local companies only; non-Hong Kong companies registered in Hong Kong cannot use it.

What limits it is eligibility for iAM Smart itself. The Digital Policy Office says iAM Smart is open to holders of a Hong Kong Identity Card aged 11 or above. Registration is through the iAM Smart mobile app, or in person with an identity card at kiosks, service counters or mobile registration teams.

For groups based in the UAE, Mauritius or the Seychelles that own Hong Kong subsidiaries, that requirement decides the matter. Where neither the directors nor the company secretary hold a Hong Kong Identity Card, the new route is closed to the company, and its filings will continue through a registered e-filing account or the other existing channels. Where a Hong Kong resident director or secretary is in place, the new route may remove the need to open an account for a single annual filing.

Key dates

• 3 August 2026: External Circular No. 1/2026 issued.
• 17 August 2026: service launched. From the same date, an iAM Smart+ self-registration kiosk is available at the Registry's e-Services Centre on the 13th floor of Queensway Government Offices, and a demonstration video is published on the Registry's website and the e-Services Portal.

What it means in practice

None of the underlying obligations has changed. The Registry says a private company must deliver its annual return within 42 days after the anniversary of its incorporation, and that the Registrar has no power to extend that limit. A return delivered on time carries a fee of HK$105. Late returns attract higher fees on a sliding scale, from HK$870 for a return more than 42 days late but within three months, up to HK$3,480 for one more than nine months late, and the Registrar cannot waive them. Late delivery is also a criminal offence under section 662 of the Companies Ordinance, with a maximum fine of HK$50,000 and a daily default fine of HK$1,000.

Take a hypothetical Hong Kong trading company owned by a Mauritius holding company, with one Hong Kong resident director who holds iAM Smart+ and another director based in Port Louis. The local director can log in to the e-Services Portal, check the pre-filled particulars, sign the NAR1 with iAM Smart+ and pay the HK$105 fee, all without the company opening a Registry account. The Port Louis director cannot use the route unless they hold a Hong Kong Identity Card.

The return still has to be right. Pre-filled data reflects only what the Registry already holds, so any change in directors, shareholders or the registered office that has not been notified will need to be dealt with separately.

What we do not yet know

The circular does not list the payment methods it accepts, nor does it say which forms will be added next.