The “Reward for Reporting Abuse of Public Rental Housing” will be implemented on January 15, 2025. As a result, we have received many enquiries about changing company addresses and virtual offices. At the same time, many entrepreneurs intending to set up a company are concerned about whether using a PRH flat as a business/company address constitutes abuse of PRH(1)。
General Accounting is the first to share Hong Kong’s requirements and uses for a company registered address, explain in detail the difference between a company registered address and a business address, key considerations when using PRH/residential premises as a business address, and solutions if you do not have a suitable registered address.
More details: Business Registration Certificate Guide | Virtual Office
What is a company registered address?
A company registered address—”Registered Office of Company” (“RO”) in English—is mandatory information for incorporating a private limited company in Hong Kong. It can be understood as the official correspondence address recorded with the Companies Registry for a Hong Kong-incorporated limited company, i.e., the “registered office of the company” under section 658 of the Companies Ordinance (Cap. 622)(2).
In addition, the NNC1 Incorporation Form must state the registered office address. The registered office is also the default address in Hong Kong for keeping the company’s statutory records/books and documents.
Requirements for a company address
1. It must be a physical address within Hong Kong; overseas or Mainland addresses cannot be used
2. It must be able to receive mail
3. A PO Box or private mailbox service cannot be used
What is the difference between a business address and a company registered address?
The differences between a business address and a company registered address are as follows:
1. Only Hong Kong limited companies have a registered office address, whereas sole proprietorships/partnerships only have business addresses. This is because limited companies are incorporated under the Companies Ordinance (Cap. 622) and are separate legal entities; while sole proprietorships/partnerships are established under the Business Registration Ordinance (Cap. 310).
Further reading: Differences between limited companies and unlimited companies
2. A company may apply for multiple business registration addresses, but it will have only one company registered address.
3. The company registered address can be searched by downloading documents via the Companies Registry e-Services website, whereas a business address must be searched through the Business Registration Office.
Uses of a company registered address
1. Default contact address of a limited company
A limited company may have multiple business addresses, but only one registered office address. As a separate legal entity, if a third party needs to contact the company, they can obtain the company’s correspondence details through a company search.
Example: If you need to file a small claim against a limited company, you can download the Annual Return from the Companies Registry and send legal documents to the other party’s RO.
Further reading: 10 key benefits of incorporating a limited company
2. The company address displayed at the Companies Registry
When conducting a company search, the image records of Companies Registry filings—such as incorporation forms or annual returns—will show the company registered address.
3. Contact address between government departments and the company
Most licence application forms require a registered address, such as applying for an APEC Card. Unless you separately report a different correspondence address to different organisations, government departments and statutory bodies—such as the Inland Revenue Department, the Companies Registry, or the Transport Department—will use the company registered address as the company’s contact address.
4. Correspondence address for company officers
Under Phase 1 of the Companies Ordinance new search arrangements(3), starting from August 23, 2021, the correspondence address of directors shown on the register will be the company registered address, replacing the directors’ residential addresses used previously.
5. Place for keeping the Significant Controllers Register
Unless a Notice of Location of Registers and Company Records is filed, the Significant Controllers Register is by default kept at the company registered address(4).
Example: Companies Registry staff may visit the registered address stated by the company to conduct spot checks on whether the company maintains the Significant Controllers Register, the Register of Members, and whether the company name plate is properly displayed.
6. Place for keeping the Register of Members
Unless Form NR2 is filed, the Register of Members—including the Register of Directors, Register of Shareholders, Register of Company Secretaries, and charges—must be kept at the company’s registered office(5).
Can a PRH flat be used as a company address?
No. Under the Hong Kong Housing Authority’s requirements(6), all subsidised housing—including PRH, HOS flats and Green Form Subsidised Home Ownership Scheme (GSH) flats—may only be used for residential purposes and must not be used for commercial purposes. In recent years, the Housing Department has been actively combating abuse of PRH(7). If a serious breach of the tenancy is found, the tenancy may be terminated without warning. Do not break the rules.
Image source: Hong Kong Housing Authority website
To strengthen enforcement, the “Reward for Reporting Abuse of Public Rental Housing” will be implemented on January 15, 2025. Members of the public who successfully report PRH abuse may receive a reward of up to $3,000 and a certificate of appreciation. There may then be more cases of tenancies being terminated.
The Secretary for Housing, Winnie Ho Wing-yin, earlier cited on a radio programme several examples that may constitute reportable PRH abuse:
“She cited a few rather outrageous situations. If tenants notice similar situations among their neighbours, they should stay alert:
1. The flat is kept closed for a long time, which may mean the person is not living there at all
2. If different people frequently come and go, and some even pull suitcases, it may have been rented out to others
3. Suspected commercial use, e.g., setting up mahjong tables and taking a cut
4. Placing many fitness machines or other equipment not typically used by ordinary households
5. Being used for storing goods”
Source: Reward for Reporting Abuse of PRH | 5 types of suspicious situations
Many people mistakenly believe that incorporating a company requires only one address to apply for a Business Registration Certificate, or that using one address as the company registered address is sufficient. In fact, the business address on the BR is also regarded as a place for business use.
As mentioned above, a business address is the commercial address where the company operates; it is not merely for BR registration. Therefore, General Accounting strongly does not recommend using a PRH address as a company address!
Industries that commonly use subsidised housing as a company address are mostly online shops or freelancers who do not genuinely need to rent an office or shop, such as designers, coaches, or renovation contractors. Although their work may not necessarily require a physical office, a physical operating address is still required when applying to set up a company.
Further reading:[Tax deductions for setting up a company] Tax filing guide for the self-employed: Tax-saving benefits of incorporating a company
Can a residential address be used as a company registered address/business address?
The Companies Ordinance and the Business Registration Ordinance do not expressly prohibit this. However, we remind entrepreneurs to first verify whether the residential address may be used for commercial purposes. Using a residential address as a business address may breach the land lease conditions, as many large private housing estates stipulate that units are for residential use only. If the premises are approved for mixed residential and commercial use, then they may be used as a business address.
In addition, even for mixed-use premises, you should consider privacy issues. Since a company search or BR search reveals the company’s registered address, General Accounting generally recommends using a commercial address for company incorporation to provide better protection.
How can you proceed if you do not have a suitable registered address?
Start-ups or freelancers may not need a real office, but still need a physical address to incorporate a company. You may consider using a virtual office service. This allows you to use a Central address as your registered address to enhance your professional image, avoid PRH abuse and breaches of land lease conditions, and better protect the personal privacy of directors, shareholders, and business owners.
What is a registered address service?
A registered address service, also known as a virtual office, means renting a commercial address provided by a company secretary firm to use as the company’s registered address, business registration address, correspondence address, and contact address for company members.
How does a virtual office service work?
1. Provide a commercial address for clients to use as the company’s registered address
2. Provide a commercial address for company members to use as a correspondence address
3. Receive letters and small parcels addressed to the company or company members, and forward them to the client as instructed
4. Provide an electronic company name plate service / company name display service
5. Value-added services such as answering calls in the company name
Key points to note when using a virtual office service
- Choose a company secretary firm that holds a “Trust or Company Service Provider” licence to ensure legality and compliance.
- Selecting a one-stop company secretary firm allows you to handle company incorporation, company secretarial services, annual returns, or designated representative services for the Significant Controllers Register at the same time—saving time and effort.
- Consider the location of the registered address. As the company address will be used on business cards, social media, or websites, a prime business district such as Central can enhance a professional image.
- Pay attention to value-added services: Will they forward mail on your behalf? Do they provide call-answering and other add-on services?
- The company secretary firm’s track record is also a factor. If the firm is a start-up and suddenly ceases operations, in addition to losing prepaid service fees, you would need to urgently find another registered address, reprint business cards, and spend time updating your company bank account, social media, website, and company details with various government bodies—time-consuming and costly.
- Confirm whether the fee includes the electronic company name plate service.
General Accounting has been established for over 20 years and provides one-stop company incorporation, company secretarial, and virtual office services. Entrepreneurs may arrange an initial free consultation.
Why must the company name/name plate be displayed at the company registered address?
By law, the company’s registered name (company name plate) must be displayed in a conspicuous place at the registered address. However, if there are more than six registered companies at the same premises, the company name may be displayed by means of an electronic company name plate(8)。
When choosing a company address service, be sure to check whether the service fee includes the electronic name plate charge.
Guide to changing a company address
Forms for changing a company address:
Limited company: Notice of Change of Address of Registered Office (Form NR1) and Form IRC 3111A (Notification of Change of Business Address).
Unlimited company: Form IRC 3111A (Notification of Change of Business Address).
Download Form NR1Notice of Change of Address of Registered Office
Download IRC 3111ANotification of Change of Business Address Form
Forms for changing a company address:
Process for changing a limited company address
1. Submit NR1 to the Companies Registry
2. Submit IRC 3111A to the Inland Revenue Department
3. Receive the Business Registration Certificate with the new address in about one week
Note: You must file the Notice of Change of Address of Registered Office within 15 days
Process for changing an unlimited company address
Submit IRC 3111A to the Inland Revenue Department
Note: You must notify the Inland Revenue Department within 1 month of the address change
Frequently Asked Questions
Can a PRH address be used to register a company or as a business address?
The Hong Kong Housing Authority strictly stipulates that all subsidised housing (including PRH, HOS flats and GSH flats)is for residential use only, and commercial use is strictly prohibited.
- Legal risks: Using a PRH flat as a company address or business address constitutes abuse of PRH. The "Reward for Reporting Abuse of Public Rental Housing", implemented from January 15, 2025, encourages the public to report such cases. Once verified, the Housing Department may terminate the tenancy. Do not break the law.
- Common misconception: Even if the address is used only to apply for a Business Registration Certificate (BR), it is legally regarded as a business address, and is therefore still subject to housing regulations.
What is the difference between a company registered address and a business address?
- Company registered address: Under section 658 of the Companies Ordinance, this is a limited company’sstatutory official correspondence address. Each limited companycan have only one registered address, which is used to receive government mail and legal documents, and to keep the Significant Controllers Register.
- Business address: This is where the company actually operates or carries on business. A company may havemultiple business addresses (e.g., chain outlets), and must apply for Business Registration for each address.
If you do not have a physical office, can you use a residential address to register a company?
- Land lease restrictions: Many private residential estates have land lease terms stating that units may be used for residential purposes only. Using them for business registration may breach the land lease.
- Loss of privacy: Search records at the Companies Registry and the Business Registration Office are public. If you use a residential address, your home address will be publicly accessible, seriously affecting personal privacy.
- Recommendation: For compliance and privacy protection, it is recommended to use a commercial address or a virtual office service.
What is a virtual office, and how does it work?
- Key features:
- Provide an address in a business district (e.g., Central) as the company’s registered address and correspondence address.
- Receive government and bank mail on your behalf and forward it to you as instructed.
- Provide an electronic company name plate service to meet the legal requirement to display the company name.
- Some services also include secretarial support such as call answering.
What is the process for changing a company’s registered address?
- Companies Registry: File Form NR1 (Notice of Change of Address of Registered Office) within 15 days after the change.
- Inland Revenue Department: File Form IRC 3111A (Notification of Change of Business Address). Typically, the Business Registration Certificate with the new address can be received in about one week.
- Inland Revenue Department: Only Form IRC 3111A is required, and you must notify the IRD within 1 month after the address change.
What should you look out for when choosing a virtual office service?
- Licence verification: Ensure the provider holds a valid "Trust or Company Service Provider" licence.
- Hidden fees: Confirm whether the fee includes the "electronic name plate" service and mail forwarding charges.
- Company reputation: Choose an established company secretary firm to avoid the risk of the address becoming invalid if the provider suddenly ceases operations, which may affect the company’s receipt of important legal documents.
Conclusion
The above is a guide to company registered addresses and how to change a company address. Freelancers or start-ups may not need to rent a physical office, and may consider using a virtual office service and understanding the key points to note. Do not use PRH or other government-subsidised housing as a company address to avoid being deemed to be abusing PRH and having your tenancy terminated.
SMEs need to understand the importance, uses, requirements, and relevant legal provisions of a Hong Kong company’s “registered address”. Under the Companies Ordinance, a company’s official correspondence address must be provided upon incorporation. Its uses include receiving government documents and official correspondence, appearing in public search records, and keeping the Significant Controllers Register. Please note that the registered address must be able to receive mail and be confirmed for commercial use, and it cannot be a private mailbox or PO Box address. If the address is changed, the relevant forms must be filed and completed within the prescribed time limits.
If you do not have a suitable address, General Accounting provides virtual office services, offering a commercial address as a registered address service and receiving mail on your behalf—meeting statutory requirements while maintaining a professional image.
Further reading:
[Online Company Incorporation] What is e-Incorporation? Same-day limited company setup guide
Sources
1. Government News – Reward for Reporting Abuse of PRH to be implemented next Wednesday https://www.news.gov.hk/chi/2025/01/20250108/20250108_142658_500.html
2. Companies Ordinance (Cap. 622) — Section 658 Registered office of company
https://www.elegislation.gov.hk/hk/cap622!zh-Hant-HK/s658?_lang=zh-Hant-HK
3. Companies Registry: Restricted Disclosure of Residential Address and Identification Number
https://www.cr.gov.hk/tc/legislation/companies-ordinance/cap622/keychanges/protected-information.htm
4. Companies Registry – Overview of the Significant Controllers Register
https://www.cr.gov.hk/tc/publications/docs/Guidelines_scr_c.pdf
5. Brief introduction to the Companies Records (Inspection and Provision of Copies) Regulation https://www.cr.gov.hk/tc/companies_ordinance/docs/BN-CR(IPC)R-c.pdf
6. Hong Kong Housing Authority (HA) — Rights and responsibilities of service users
https://www.housingauthority.gov.hk/tc/common/pdf/about-us/policy-focus/policies-on-public-housing/C01/C01.pdf
7. Combating abuse of PRH
https://www.housingauthority.gov.hk/tc/public-housing/tenancy-matters/combating-housing-abuses/index.html
8. Disclosure of company name and whether it is a limited company
https://www.cr.gov.hk/tc/legislation/companies-ordinance/cap622/keychanges/disclose-comp-name-liab.htm
