Notifying a Change of Registered Office: The 15-Day Deadline, Form NR1 and Penalties (2026)

At a glance

Moving office and changing the registered office are two different things. If you move premises but the registered office stays as it is (for example, you have always used a company secretary’s address), no NR1 is needed. Conversely, once the registered office changes, the 15-day clock starts even if your own desk has not moved.

When do the 15 days start?

From the day the address actually changes — not from the day you finish unpacking, and certainly not from the day you remember to file.

The safest approach is to work backwards: as soon as the effective date of the new address is settled, prepare the NR1 immediately rather than waiting until the move is over. The first fortnight after a move is always the most chaotic, and this is exactly the form that gets forgotten in it.

What happens if it is filed late?

Under the Companies Ordinance, failure to comply with a filing requirement exposes the company and every responsible person — including each director, the company secretary and the manager — to prosecution and, on conviction, a default fine, with a further daily fine for a continuing default.

On amounts, the Companies Registry’s filing guidance sets out that failing to deliver a notice within the specified time carries a fine of up to HK$25,000 per default, with a further HK$700 a day for a continuing default (fine levels are revised from time to time; the most recent publication governs).

The phrase to note is “every responsible person”. Many owners assume it is the company that gets fined, and that a company with no money has no problem — in fact the list of people prosecuted includes every director, which means you.

Does the IRD need separate notice?

It depends on whether your business address changed too. The registered office (registered with the Companies Registry) and the business address on the business registration (registered with the IRD) are two separate things, and the law allows them to differ.

If the two addresses are the same: when filing Form NR1 electronically, you can also select the “one-stop e-filing service”, which simultaneously notifies the IRD that the business address is changing to the new registered office — handled in one go. After registering the NR1, the Companies Registry also passes the new registered office address to the Business Registration Office.

If the two addresses differ (say the registered office is at your company secretary’s and the trading address is your own premises) and it is the trading address that has changed, you have to notify the IRD separately. A change of business address has to be notified to the Business Registration Office in writing within 1 month of the change, on Form IRC 3111A or through eTAX. Failing to do so is an offence, with a maximum fine of $5,000 and one year’s imprisonment.

Two different deadlines, two departments, two forms. Do one side only and the other still runs out of time — this is the most commonly missed part.

What can be used as a registered office?

The registered office must be in Hong Kong, and is used to receive all communications and notices. The Companies Registry does not accept a non-Hong Kong address, a “care of” (c/o) address, or a PO box number.

The reason is straightforward: this is the address for legal service. What the Government and the courts send there is treated in law as having reached you. A PO box has nobody to sign for it, and responsibility for a c/o address is unclear — neither meets that requirement.

So the first criterion for a new address is not whether the rent is cheap or expensive, it is whether somebody will actually deal with the post. There is more detail in the registered office address requirements.

Is there a way to avoid changing the address every time?

The common arrangement is to separate the two: use a service provider’s Hong Kong office as the registered office, and your actual premises as the trading address. Then moving shop, moving office or even moving house does not require the registered office to follow.

To be clear, though, this arrangement does not mean “no filing required”. If the trading address changes, the IRD’s one-month deadline still runs. What separating them removes is the risk on the Companies Registry’s 15-day deadline — not both.

Before you move, draw up a list

Missing the NR1 is rarely a matter of not wanting to file. It is almost always “the move was chaotic and I forgot”. The practical answer is to write down everything that has to follow on the day the new address is settled: NR1, the IRD business address, the bank, licences, addresses in customer contracts.

We provide company secretarial services: when the address changes we prepare the form and track the deadline, follow through on a change of company name and a change of director — which carry the same 15-day deadline — and make sure it all lines up with the annual return NAR1. Get started, or talk to us.

The deadlines and penalties described here are as set out in the Companies Ordinance (Cap. 622) and most recently published by the Companies Registry and the Inland Revenue Department; government fines and fees are revised from time to time and the official publication governs. This is general information only and does not constitute professional advice; for individual situations, consult a professional.