Mr. Chen, who runs an international trade business in Shenzhen, ran into a snag last year: the auditor asked him to provide bank statements, and he had to dig through emails from half a year ago to gather them all. As a result, the filing of his annual report was delayed, and he nearly faced a fine. Auditing a Hong Kong company isn’t just a matter of submitting a form—the completeness of the documentation directly determines efficiency and risk.

In 2026, the tax authorities will enforce stricter inspections regarding the ”three-way match” (where contracts, invoices, and bank statements correspond one-to-one). This article provides you with a checklist of the standards.

01

Which Companies Are Required to Undergo an Audit?

Under Chapter 622 of the Companies Ordinance, all Hong Kong limited liability companies must be audited annually byHong Kong licensed accountantsAudits are required by law, and the audit report must be filed along with the income tax return. As of January 2024, the audit exemption for small companies has been eliminated; all companies, regardless of size, are now required to undergo an audit.

Unlimited liability companies are only required to maintain accounting records and do not need to undergo an audit; dormant companies must submit a non-operational audit report once every three years. Therefore, you should first determine which status your company falls under.

If you’re facing a similar situation—such as preparing for your Hong Kong company’s first accounting audit and aren’t sure which documents to gather—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you develop a comprehensive compliance solution.

02

Basic Qualification Documents

Four essential documents: Certificate of Incorporation (CI), Business Registration Certificate (BR), the most recent Annual Return (NAR1), and the Articles of Incorporation. In addition, proof of identity for directors and shareholders, and the Significant Controllers Register (SCR).

If this is not your first filing, you must also submit the previous year’s audit report and the filed income tax return (BIR51). It is recommended that you retain the originals of all documents for at least seven years, as the tax authority may conduct an audit at any time.

03

Financial and Business Documents

During the fiscal yearMonthly Statements for All Bank Accounts(including offshore accounts and e-wallets) is key; transaction statements and receipts must be available for every deposit and withdrawal.

Revenue-related documents: sales/service contracts, invoices, bills of lading and waybills, payment receipts, and customer statements. Expense-related documents: purchase contracts, supplier invoices, payment vouchers, logistics documents, as well as receipts for rent, wages, travel expenses, and office supplies.

Assets: List of fixed assets (purchase contracts + invoices + depreciation schedule), inventory count, and detailed accounts receivable and payable. For foreign currency transactions, provide evidence of the exchange rate in effect on the transaction date.

04

Specialized Materials on Cross-Border and Offshore Operations

For those engaged in cross-border e-commerce, foreign trade, or applying for an offshore exemption, an additional step is required: a chain of evidence proving that profits do not originate from Hong Kong—including that the place where contracts are signed or services are provided is not in Hong Kong, that overseas customers and suppliers are not Hong Kong residents, and that there is a complete record of payment transactions and communication.

For related-party transactions, you must prepare transfer pricing documentation (in accordance with OECD standards). If these materials are incomplete, your application for an offshore exemption is likely to be denied.

Transactions without supporting documents will be deemed fraudulent and immediately trigger an audit—so don't throw away your documents carelessly.

If you’re facing a similar situation—wanting to prepare all your bookkeeping, auditing, and offshore exemption documents at once—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you implement a comprehensive compliance solution.

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