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First Published October 2, 2019 – Updated October 12, 2026

PRACTICE UPDATE: How the content must now be read in light of current ImmD policy:

Historically, this advisory addressed the common dilemma of digital nomads and remote professionals living in Hong Kong on visitor status, freelancing solely for overseas clients with offshore revenue. The Geeza laid down the strict legal reality—that providing services while physically present in the territory without employment or investment authorization breaches visitor conditions of stay—while offering a practical, accessible path to regularize status. A remote freelancer could establish a local sole proprietorship or limited company and apply for an investment as entrepreneur visa, comfortably relying on a lean operating model, modest capital reserves of a few hundred thousand dollars, a serviced office desk, and foreign contracts to convince ImmD that the business was viable and contributed to the local economy.

The game has changed from a manageable regularization pathway for solo freelancers into an insurmountable institutional barrier. While ImmD remains vigilant regarding unlawful work on visitor status, regularizing an offshore freelance practice via the GEP entrepreneur visa is no longer viable for a lean operator. Adjudication is now strictly tethered to TTPS Category A operational substance (~HKD 2.5M enterprise scale). ImmD will not entertain a solo digital consultancy: the corporate vehicle must substantiate HKD 1.5M–2.0M in deployed corporate bank liquidity, an executed commercial lease for exclusive physical premises (“four walls”), and active MPF payroll for 2–3 local permanent residents. Without meeting these non-negotiable corporate thresholds upfront or securing backing from an accredited government incubator, attempting to transition an offshore freelance venture into an investment visa results in immediate, summary refusal.

What is the law about visitors working in Hong Kong as freelancers but not engaging in the local economy? Whilst this question was first asked 4 years ago, I have received three very similar questions in the last week so now’s the time to republish it. So ..

Do you need an investment visa if all your income is sourced overseas?

QUESTION

Hi Stephen,

I’ve lived in Hong Kong for 2 years and now I’m freelancing and getting all of my income from overseas.

I wish to stay in HK, so am I required to get a work / investment visa even if I generate no income here?

Thank you so much for your help.

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