IRBR200: How to Notify Commencement of Business in Hong Kong

If your Hong Kong company was incorporated through the Companies Registry, you must tell the Inland Revenue Department (IRD) when it actually starts doing business, within one month of that date. You do it with Form IRBR200 or a letter, sent by post, handed in at the Business Registration Office in Kai Tak, or submitted online through the GovHK e-form. Missing the deadline is an offence with a maximum fine of HKD 5,000 and one year's imprisonment.

Why Your Business Registration Isn't Finished Yet

The Business Registration Certificate in your incorporation pack looks like the end of the paperwork. For most new companies, it's a placeholder. Until you notify commencement, the IRD has no business description or start date on file, and newly incorporated companies' certificates show "CORP" as the nature of business.

Most founders hit two questions at once. When exactly did my business start? And does anything I did before the first invoice count?

Get the date wrong and you either miss a legal deadline or report a start date your records can't support.

This guide covers what counts as commencement, the deadline, how to file IRBR200 (including online), what dormant companies need to do, and how the commencement date connects to your first profits tax obligations.

What Is the Commencement of Business in Hong Kong?

Commencement of business is the date your Hong Kong company first carries on its trade, profession or business. It isn't the date of incorporation, and it isn't the date on your Business Registration Certificate.

Under the Business Registration Ordinance (Cap. 310), a company registered through the one-stop company and business registration service must notify the IRD in writing within one month of commencement. The notice gives four particulars: the business name (if different from the company name), a description and nature of the business, the business address (if different from the registered office) and the date of commencement.

Does Your Business Registration Certificate Cover Commencement?

No. When you incorporate, the Companies Registry and the IRD process your company and business registration together, and the Companies Registry issues your Business Registration Certificate with the Certificate of Incorporation. That certificate is issued before your company has done anything, so it can't record when trading began.

You need both. Once you notify, the IRD updates your business registration record with your actual business details. If you need a BRC showing those details quickly, you can hand in Form IRBR200 at the Business Registration Office counter.

What Counts as Commencement of Business?

The Ordinance doesn't give a checklist. In practice, the test is whether your company is actually carrying on its business. These are common signs that it has started:

• Issuing your first invoice to a client
• Signing your first commercial contract with a customer or supplier
• Hiring your first employee or engaging contractors for operational work
• Launching a website that takes orders or payments
• Receiving your first payment from a customer

Preparatory steps usually don't count: opening a business account, registering a domain name, applying for licences, or signing a lease that only takes effect later.

When Does the One-Month Deadline Start?

The clock starts on your commencement date, the day your company first carried on business. Not your incorporation date, and not the date on your BRC.

You can't file early. The form states that advance notice won't be accepted, so wait until business has actually started, then file within the month.

How to File Form IRBR200

You can notify by completing Form IRBR200 or by writing a letter with the same information. You can submit it by post, in person or online.

Step 1: Get the Form

Download Form IRBR200 from the IRD website, or use the GovHK online version ("Notification of Commencement of Business by Corporation").

Step 2: Fill In the Business Particulars

The form asks for:

• Business Registration Number and name of the corporation, exactly as on your BRC. Our guide explains where to find your Business Registration Number.
• Business name, only if it's different from the company name (up to 120 characters in English).
• Business commencement date. This field is mandatory.
• Business description and nature, up to 60 characters in English, such as "Software development services".
• Business address, only if it's different from your registered office address.
• Signer's details: name, Hong Kong identity card or passport number, designation and telephone number.

Step 3: Have It Signed

The notice must be signed by a director, the company secretary or a manager. If the signer is a corporate director or a corporate secretarial firm, enter its Business Registration Number instead of a personal ID number, or, if it doesn't have one, attach a copy of its Certificate of Incorporation.

Step 4: Submit It

Don’t fax or email the form, as the IRD says it won’t accept either. Keep a copy of what you sent and your proof of posting or the online confirmation.

What If Your Company Is Dormant?

A dormant company has been incorporated but hasn't started any business. If yours is genuinely dormant, with no invoicing, staff or operational contracts, the IRBR200 obligation hasn't been triggered yet. It starts the day you first carry on business.

Dormant doesn't mean nothing to do. You still renew your BRC when it expires, keep statutory records, file any Profits Tax Return the IRD sends you even if there's no profit to report, and file your annual return unless the company has formally declared itself dormant with the Companies Registry. Our guide to what a dormant Hong Kong company still needs to file covers the full list.

How Commencement Connects to Your Profits Tax

IRBR200 is a business registration filing, but the date you report matters for tax too, because your company is liable to profits tax on assessable profits from the time it starts carrying on business.

Two timelines run in parallel:

• The first Profits Tax Return. GovHK says a newly registered business generally receives its first Profits Tax Return about 18 months after the date of commencement of business or the date of incorporation. For a company, plan from your incorporation date: the return can arrive before you've earned anything, and you still have to file it.
• Notification of chargeability. If your company earns assessable profits and hasn't received a return, the Inland Revenue Ordinance requires you to tell the IRD in writing within four months after the end of the basis period for that year of assessment. Failing to do so can lead to prosecution or additional tax.

A commencement date that matches your accounting records keeps both timelines simple. Report the date your records show, not an estimate.

Penalties for Not Notifying Commencement

Failing to notify the IRD within one month of commencement is an offence under the Business Registration Ordinance. The maximum penalty is a fine of HKD 5,000 and one year's imprisonment.

If you’ve already missed the deadline, file now. A late notice puts your records right, but no notice leaves the offence open.

How Statrys Helps After Incorporation

IRBR200 is one of several filings that follow incorporation, alongside your BRC renewal, annual return and first Profits Tax Return. A company secretary keeps track of them so a one-month deadline doesn't slip.

Statrys’ Hong Kong company registration package includes:

• All government incorporation fees
• A company secretary
• A registered address
• Assistance with opening a multi-currency business account

You apply online with a passport copy and proof of address, and the Statrys team handles the incorporation filings from there.