How To Start A Business In Hong Kong As A Foreigner – Three Elements To Approval
Posted by The Visa Geeza / in Investment Visas, Musing / 1 response
I recently gave a talk at Campfire Collaborative Space on the topic of how to start a business in Hong Kong as a foreigner, which in essence is the journey of getting a Business Investment Visa as an Entrepreneur after the implementation of the Enhancement Measures in 2015 and the Audit Commission Report Number 66 from 2016.
PRACTICE UPDATE: How the content must now be read in light of current ImmD policy:
Historically, this presentation segment outlined the foundational “three elements to approval”—the famous three legs of the approvability stool that underpinned every successful investment as entrepreneur visa. The Geeza explained that ImmD evaluated whether a venture would make a substantial contribution to Hong Kong by examining three interconnected themes: commercial sustainability, capital resources, and local employment creation. In practice, the approvability stool was remarkably elastic: an applicant did not need massive funding or immediate corporate scale. Case officers took a holistic, qualitative view, regularly approving lean consultancies and boutique agencies that brought modest seed capital of a few hundred thousand dollars, operated out of serviced offices or co-working desks, and presented a credible narrative showing how the business would gradually achieve profitability and hire local staff over a two- to three-year horizon.
The game has changed from a flexible, qualitative stool into an unyielding, high-threshold institutional audit. ImmD no longer balances these three elements through narrative forecasts or early-stage commercial leeway. Under post-April 2026 administrative practice aligned with TTPS Category A operational substance (~HKD 2.5M enterprise scale), all three legs have been replaced by rigid, empirical prerequisites that must exist on day one. Financial adequacy now strictly means HKD 1.5M–2.0M in deployed corporate bank liquidity; commercial presence strictly requires an executed commercial lease for exclusive physical premises (“four walls”), permanently disqualifying serviced desks; and local contribution strictly demands active MPF payroll contributions for 2–3 local Hong Kong permanent residents. Unless a venture has gained admission into an accredited government incubator (such as Cyberport or HKSTP), relying on the historic approvability stool to justify a lean or phased startup will result in swift and summary refusal.
In this segment I talk about the 3 themes that present themselves in all approved Business Investment Visas as an Entrepreneur – the 3 Legs of the Approvability Stool.
The Rest of the Talk
Introduction
How We Got Here
Must Have Resources
The Startup Visa
Business Investment As An Entrepreneur (Visa)
Three Elements To Approval
Have You Got Enough Money?
Is Your Business Sustainable?
A Properly Set Up Office
How About Local Jobs?
Economic Sector Advantages
Hiring Yourself
D-I-Y Application
Important Materials Referenced In The Presentation
10 Must-Have Resources for Any Hong Kong Investment Visa Application
Accredited Startup Programmes in Hong Kong
Hong Kong Visa Handbook Free Kits
Your Questions Answered
More Stuff You May Find Useful Or Interesting
10 Steps to a Successful Hong Kong Entrepreneur Visa Application – Step 5 – 3 Crucial Elements for Approval
Relocating to Hong Kong for work or business – the visa implications!
How to apply for the right of abode in Hong Kong without any professional help
Hong Kong investment visa – the three legs of the approvability stool
The Hong Kong Visa Geeza on RTHK Radio 3
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The Hong Kong Visa Geeza (a.k.a Stephen Barnes) is a co-founder of the Hong Kong Visa Centre and author of the Hong Kong Visa Handbook. A law graduate of the London School of Economics, Stephen has been practicing Hong Kong immigration since 1993 and is widely acknowledged as the leading authority on business immigration matters here for the last 24 years.
