Mr. Zhang from Hangzhou obtained Hong Kong residency in 2024 through the High-Talent Pass (Category A). In August of this year, his renewal application was denied on the grounds that he ”failed to demonstrate a substantial contribution to Hong Kong’s economy.” He was baffled: with an annual salary of 2.5 million, a Hong Kong Mandatory Provident Fund account, a Hong Kong lease agreement, and his children attending school in Hong Kong—wasn’t that enough?

It's not that there isn't enough; it's that“The ”Two Addresses, Two Invoices” documents are incomplete. In 2026, the Immigration Department shifted its focus for renewal reviews from ”formal compliance” to ”substantive contribution”; having money alone is not enough—applicants must also prove that they ”work in Hong Kong, pay taxes in Hong Kong, and live in Hong Kong.” This article clearly explains the ”two addresses, two bills” pathway to a smooth renewal process.

01

Why Have Renewal Requirements Suddenly Become Stricter?

First, let's talk about the background.In 2026, the Hong Kong Immigration Department will comprehensively upgrade its review criteria for High-Talent Pass renewals... moving from the previous focus on ”whether the materials are complete” to ”substantive contributions.”

Three Key Changes:

First.From ”Focusing on Numbers” to ”Looking at Logic”. In the past, Category A applications were assessed solely on whether the annual salary of 2.5 million Hong Kong dollars met the requirement; now, the following questions are considered: ”Is this annual salary genuine?” ”Is it paid by a local Hong Kong company or a mainland company?” ”Is the job based in Hong Kong?” If the salary is paid by a mainland company and the applicant is not working in Hong Kong on a long-term basis, the renewal application will be denied.

Second.From ”Formal Compliance” to ”Substantive Contribution”. A Hong Kong rental contract, Mandatory Provident Fund (MPF) contributions, and tax returns alone are not enough; authorities will also examine ”whether you are actually working, living, and paying taxes in Hong Kong.” For example, if you rent an apartment but only live there for 30 days a year, contribute only 500 Hong Kong dollars monthly to your MPF, or file taxes but have an annual income far below 2.5 million—the Immigration Department will view these situations as ”fake residency.”

Third.From ”Application Materials” to ”Supporting Documents”. In addition to the basic application documents, you must also provide ”supporting documents”—such as the company’s Business Registration Certificate, office lease agreement, list of Hong Kong employees, monthly bank statements from a Hong Kong bank, utility bills from Hong Kong, and records of local spending in Hong Kong.

The rejection rate for the first batch of High-Talent Pass renewals in 2026 was approximately15-20%...which is three times the 5% figure from 2024.

02

Two Addresses: Home Address + Work Address

“Two Sites”This is a key requirement for the 2026 renewal application with the Immigration Department, which stipulates that both the ”residential address” and ”work address” must be in Hong Kong and show evidence of actual use.

Residential Address (”Address”):

Requirements: You must provide a valid residential address in Hong Kong and be able to prove that you ”actually reside there.”

Supporting Documents: ① Lease Agreement (lease term ≥ 6 months) ② Rent Payment Records (monthly bank transfers) ③ Utility Bills (HK Electric/CLP Power/Water Supplies Department) ④ Hong Kong Cell Phone Usage Records (bills) ⑤ Hong Kong Local Bank Monthly Statements (showing address).

New Regulations for 2026:”Utility bills” must be provided.”, and the address on the utility bills must match the address on the lease agreement. If you are renting but your utility bills show that the property is vacant (zero usage), it will be considered ”not actually occupied.”

Practical Advice: You must reside in Hong Kong for at least180 days per year...so that utility bills reflect actual usage data.

Work Address (”Work Location”):

Requirements: You must provide a valid business address in Hong Kong, and the company must be actively operating (not a shell company).

Supporting Documents: ① Business Registration Certificate (BR) ② Certificate of Incorporation (CI) ③ Lease Agreement for the Company’s Office Space ④ List of Company Employees (≥2 local Hong Kong employees + Mandatory Provident Fund contribution records) ⑤ Company Bank Statements (showing genuine business transactions each month) ⑥ Company Financial Statements (annual revenue ≥ HKD 3 million).

New Regulations for 2026:A company must have a ”physical office.”(It cannot be a shared workspace or a virtual office), and the office lease must be for a term of at least one year.

Practical Recommendations: Office space ≥ 300 square feet (approximately 28 square meters), monthly rent ≥ 20,000 HKD, and at least 2 employees (each with a monthly salary of ≥ 20,000 HKD plus MPF contributions).

03

Two tax statements: Payroll Tax Statement + Capital Gains Tax Statement

“Two Orders”These are two tax certificates: the ”Salary Tax Statement” and the ”Capital Gains Tax Statement,” which correspond to ”individual taxation” and ”corporate taxation,” respectively.

Payroll Tax Statement (Individual Tax Certificate):

Requirements: You must have ”employment income” or ”self-employment income” in Hong Kong and have filed a salary tax return with the Hong Kong Inland Revenue Department.

Supporting Documents: ① ”Salary Tax Assessment Notice” issued by the Hong Kong Inland Revenue Department (commonly known as a ”tax bill”) ② ”Proof of Income” issued by the employer (specifying monthly salary, job title, and employment relationship) ③ Hong Kong Mandatory Provident Fund (MPF) contribution records (employer’s portion + employee’s portion, with a combined monthly total of ≥3,000 HKD).

New Regulations for 2026: Renewal of the High-Talent Pass (Category A),The ”assessable income” on the salary tax return must be at least 2 million HKD per year.(Actual taxable income equivalent to an annual salary of approximately 2.5 million HKD). If the amount shown on the tax return is significantly lower than 2.5 million, it may raise suspicions of ”nominal employment.”

Practical Advice: If an employee is assigned to work in Hong Kong by a mainland company, it is necessary to clearly define the ”portion of employment in Hong Kong”—for example, signing an employment contract with a Hong Kong company, receiving salary payments from a Hong Kong company, and having the Mandatory Provident Fund contributions made by a Hong Kong company.

Income Tax Return (Corporate Tax Payment Certificate):

Requirement: Your company in Hong Kong has ”taxable profits” and has filed a profits tax return with the Hong Kong Inland Revenue Department.

Supporting Documents: ① ”Profits Tax Return + Assessment Notice” issued by the Hong Kong Inland Revenue Department; ② The company’s audited financial statements; ③ The company’s Business Registration Certificate and Certificate of Incorporation; ④ The company’s monthly bank statements (showing actual business transactions for each month); ⑤ The company’s Mandatory Provident Fund (MPF) contribution records.

New Regulations for 2026:Company annual revenue ≥ HK$3 million, taxable profit ≥ HK$500,000...in order to meet the ”substantive business operations” requirement for renewing a High-Talent Pass (Category A).

Practical Advice: If your company is newly established, wait at least 12 months after commencing operations before applying for renewal. Companies with zero revenue or operating at a loss will be considered ”shell companies.”

04

Renewal Timeline: When to Start Preparing

”Early Start Timeline” for the 2026 High-Talent Pass (Category A) Renewal:

T-12 months (1 year before renewal):Review the company's operations—office leases, number of employees, revenue, and profits. If the figures fall short of targets, immediately take steps to strengthen the business (hire employees, expand operations).

T-9 months (the 9 months prior to renewal):File Your First Tax Return—If your company has been in operation for 12 months, file your first profits tax return; if you have been working in Hong Kong for more than 12 months, file your first salaries tax return.

T-6 months (6 months before renewal):Submit your tax return to the tax authority—the tax authority will issue a tax assessment notice within 1 to 3 months, ensuring that you receive your tax bill before you apply for renewal.

T-3 months (3 months before renewal):Prepare the documents for the renewal application—in addition to the ”two addresses and two receipts,” you’ll also need to prepare basic documents such as your passport, visa, entry records, and proof of family relationships.

T-0 (4 weeks before the visa expires):Submit a renewal application online—submit it through the Immigration Department’s official website; the processing time is typically 2–4 weeks.

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