Annual Return Fee 2026 | Complete Guide to NAR1 Annual Return Registration Fees, Late Fees and the 42-Day Deadline for Hong Kong Companies
Every local private company must deliver an annual return in Form NAR1 to the Companies Registry (CR) each year. The registration fee for on-time delivery is HK$105, and filing must be completed within 42 days after the company's anniversary date; late fees start at HK$870 and escalate up to HK$3,480. Failing to deliver NAR1 involves not only higher registration fees — the company and every responsible person may also face criminal prosecution. NAR1 is a statutory filing under the Companies Ordinance; it is not the same as tax filing, nor is it the annual fee for the Business Registration Certificate. For more compliance essentials, see Chan & Chung Hong Kong company compliance resources.
How Much Is the NAR1 Registration Fee? On-Time vs Late at a Glance
On-Time Registration Fees (by Company Type)
| Company Type | Form | On-Time Registration Fee |
|---|---|---|
| Private company limited by shares | NAR1 | HK$105 |
| Company limited by guarantee | NAR1 | HK$105 |
| Public company | NAR1 | HK$140 |
| Registered non-Hong Kong company | NN3 | HK$180 |
Escalating Late Fee Schedule (Private Companies; Current CR Fee Schedule)
| Late Period (counted after the anniversary date) | Higher Registration Fee |
|---|---|
| Within 42 days (on time) | HK$105 |
| More than 42 days – 3 months | HK$870 |
| More than 3 – 6 months | HK$1,740 |
| More than 6 – 9 months | HK$2,610 |
| More than 9 months | HK$3,480 |
Beware: Outdated Fee Tables Online
Some older online articles still quote the late fee for private companies as HK$2,400–4,800; those figures reflect the old fee regime. The fees in this article follow the Companies Registry's current fee schedule (as of August 2026).
How Is the 42-Day Deadline Calculated? The Saturday Trap
The reporting date of the annual return is the anniversary of the company's incorporation or, for companies re-domiciled to Hong Kong, the anniversary of the transfer of registration. NAR1 must reach the Companies Registry within 42 days after that date.
Two points to note when counting the deadline:
- Sundays and public holidays count towards the 42 days; they are not skipped.
- If the 42nd day falls on a Sunday or a public holiday, the deadline is postponed to the next working day that is not a holiday; but if the 42nd day is a Saturday, the deadline is not extended.
Useful tool: the Companies Registry provides a Deadline Calculator, available directly on the CR website (https://www.cr.gov.hk/tc/compliance/annual-return/calculator.htm).
Late or Missing Filing: Higher Registration Fees + Criminal Consequences
The Registrar of Companies has no power to extend the deadline, nor to waive or reduce the higher registration fee. Even if no reminder letter was ever received, the payment obligation is not waived. If the fee submitted is insufficient, the entire NAR1 will be returned, and the fee applicable on the date of resubmission will apply. For postal submissions, the postmark date determines the applicable fee, but delivery is only complete once the document actually reaches the CR.
Also note that the higher registration fee and criminal liability are handled separately. Section 662 of the Companies Ordinance provides that the company and every responsible person may be prosecuted; each default carries a maximum fine of HK$50,000, plus a further fine of HK$1,000 for each day during which the default continues.
Four Annual Costs Distinguished: NAR1 ≠ Business Registration ≠ Tax Filing ≠ Annual Secretarial Fee
Which Are Government Fees
| Item | Collecting Body | Legal Basis | Nature | Statutorily Required |
|---|---|---|---|---|
| NAR1 registration fee | Companies Registry | Companies Ordinance | Annual filing | Yes |
| Business Registration Certificate (BR) | Inland Revenue Department | Business Registration Ordinance | Business registration | Yes |
| Profits Tax return (BIR51) | Inland Revenue Department | Inland Revenue Ordinance | Tax filing | Yes |
The three fees fall under different government departments and different ordinances. Even after paying the business registration fee or completing the Profits Tax return, NAR1 must still be delivered separately.
Which Are Market Service Fees
Annual return filing services provided by company secretaries or licensed TCSP (Trust or Company Service Provider) firms are common services available in the market — they are neither government fees nor a statutory mandatory requirement under the Companies Ordinance. The HK$105 covers only the Companies Registry registration fee; it does not include the business registration fee, audit and tax filing costs, or service fees charged by secretarial providers in the market.
How to Submit NAR1: Step-by-Step Guide
Electronic Submission
The Companies Registry's e-services website (e-services.cr.gov.hk) is available 24 hours a day. Starting in 2026, individual directors or company secretaries who hold iAM Smart+ can deliver NAR1 or NR1 directly by digital signature without having to open an account in advance (External Circular No. 1/2026).
Paper Submission
- Download Form NAR1 from the Companies Registry website
- Complete all items in Chinese or English
- Have the form signed by a director or the company secretary
- Send by post or deliver in person to the Companies Registry, 14/F, Queensway Government Offices
- Make the cheque payable to 'Companies Registry'
Three Common Pitfalls
- Any changes to directors / secretary / registered office during the year? You must deliver a separate NR1 (notice of change) or ND2B (change of directors); you cannot simply record the changes on NAR1.
- Private companies are not required to attach financial statements to NAR1; only public companies and companies limited by guarantee must submit them.
- A dormant company may still have to deliver NAR1 for the year in question (see next section).
No Business Activity — Do You Still Have to File? Legitimate Exemption Routes
Companies with no business activity and shell companies are, in principle, still required to deliver NAR1 on schedule.
There are only two exemption routes:
- Formally declaring the company dormant under section 5 of the Companies Ordinance
- Completing deregistration (under section 750) or entering into winding-up proceedings
Timing trap: if the company declares dormancy only after the 42-day period following its anniversary date has expired, NAR1 for that year must still be delivered. Tax and exemption arrangements vary case by case; consult a professional adviser.
DIY vs Using a Service Provider? Comparing Common Market Options
| Approach | Cost | Pros | Considerations |
|---|---|---|---|
| Handle it yourself | HK$105 (CR registration fee only) | Lowest cost | You must track the anniversary date and the 42-day deadline, complete the forms and follow up yourself |
| Company secretary / TCSP agent | Market fees vary | Usually includes deadline reminders, plus form preparation and filing on your behalf | An external licensed service; verify that the provider holds a valid TCSP licence |
Checklist when choosing a service provider:
- Does the provider hold a valid TCSP licence?
- Are government fees and service fees itemised separately?
- Does it provide anniversary-date deadline reminders?
For more on compliance support options, see the Chan & Chung services overview.
FAQ
1. How much do I pay if I file NAR1 on time? Which tier applies if I am late?
The on-time registration fee for a private company is HK$105. Late fees escalate by period: more than 42 days – 3 months HK$870; more than 3 – 6 months HK$1,740; more than 6 – 9 months HK$2,610; more than 9 months HK$3,480.
2. If the company has no business activity or is a shell company, do I still have to file?
Yes. Only formally declaring the company dormant under section 5 of the Companies Ordinance, or completing deregistration (section 750) / winding-up, grants exemption. If dormancy is declared only after the 42 days following the anniversary date have passed, NAR1 for that year must still be delivered.
3. I have paid the business registration fee / Profits Tax — do I still need to submit NAR1?
Yes. The Business Registration Certificate (BR) is governed by the Inland Revenue Department under the Business Registration Ordinance; the Profits Tax return (BIR51) falls under the Inland Revenue Ordinance; NAR1 is a Companies Registry document under the Companies Ordinance. The three are independent and do not substitute for one another.
4. I did not receive a reminder letter — can the higher registration fee be waived?
No. The Registrar of Companies has no discretion to waive or reduce the higher registration fee. To avoid missing the deadline, you can subscribe to the e-reminder service on the CR website.
5. Is HK$105 the total annual compliance cost?
No. The HK$105 is only the Companies Registry NAR1 registration fee. The business registration fee, audit and tax filing costs, and secretarial service fees available in the market are all additional costs.
For more information on Hong Kong company compliance and fees, visit the Chan & Chung website.
Source references (as of August 2026, based on the current Companies Registry fee schedule):
- Companies Registry ─ Fee Schedule for Principal Services: https://www.cr.gov.hk/tc/about/fees.htm
- Annual Return NAR1 for Private Companies: https://www.cr.gov.hk/tc/compliance/annual-return/private.htm
- Companies Registry FAQ: https://www.cr.gov.hk/tc/faq.htm
- Deadline Calculator: https://www.cr.gov.hk/tc/compliance/annual-return/calculator.htm
- e-Services Portal: https://e-services.cr.gov.hk
- External Circular No. 1/2026 (Delivery of NAR1 via iAM Smart+)