Hong Kong New CIES: changing intermediaries and the seven-working-day notice
Changing a designated intermediary involves asset-transfer rules and separate reporting duties. The seven-working-day notice period is not a universal deadline for completing a transfer.
Seven working days is a notification requirement, not a universal transfer-completion deadline. Ordinary Saturdays can count.
Hong Kong’s New Capital Investment Entrant Scheme permits changes of financial intermediary subject to its rules. When changing to another eligible intermediary in the same category, the permissible financial assets in the former designated account must be transferred to the new intermediary’s designated account as required by the rules. The applicant or entrant must notify the Director-General of Investment Promotion in writing within seven working days of the relevant change.[1]
That is a notification deadline. It should not be rewritten as a universal requirement to complete every asset transfer within seven working days. Transfer conditions, notification triggers and settlement progress need to be tracked separately.
Identify which type of change is taking place
Paragraph 6.1(a)(v) addresses both a change of intermediary within the same category and switches of permissible financial assets between designated accounts with intermediaries in different categories. Cross-category switches are therefore not categorically prohibited.[1]
This article focuses on the first situation. Before instructing a move, establish that the receiving institution is eligible, the account has been opened for the scheme and it can receive the assets concerned. If a product cannot be transferred directly, first resolve the applicable disposal, reinvestment and transfer treatment. Changing providers is not a reason to step outside the scheme’s asset controls.
Preserve the link between the accounts and assets
For a same-category change, the rules require the relevant permissible financial assets to move in their entirety, with a stated exception for directly arising cash dividends and interest. That exception should not be expanded into permission to move investment capital through an ordinary personal account and replenish a designated account later.[1]
A useful handover file connects the outgoing and incoming designated accounts, identifies the assets and records instructions and settlement dates. This is an evidence-management method: it helps avoid a transfer leaving only a final balance, with no clear record of how the assets remained within the scheme’s requirements.
The investor and intermediary have separate duties
The investor’s written-notification duty is not automatically replaced by the bank’s transfer process. The official contract template separately requires the intermediary to report specified events within seven working days of acquiring actual knowledge. These include an instruction to appoint a new intermediary and relevant withdrawal instructions or withdrawals.[1][2]
The triggering events are not identical. Both parties should identify what starts their respective deadline and retain their notifications or submission records. An assurance that the institution will report does not remove the need to address the investor’s own obligation.[1][2]
| Responsibility | What to establish |
|---|---|
| Asset transfer | Account category, transfer scope and continuity of the designated-account records |
| Investor notification | The relevant change and the seven-working-day written notice |
| Intermediary reporting | The specified event, actual knowledge and its independent reporting duty |
A working day can include Saturday
The scheme defines a working day by excluding Sundays, public holidays and the gale-warning or black-rainstorm-warning days specified in law. An ordinary Saturday is not automatically excluded. The official FAQ’s worked example expressly counts a Saturday.[1][3]
Do not substitute a bank branch’s opening calendar or a Monday-to-Friday office week for that definition. Calculate the deadline using the scheme’s rules, the relevant Hong Kong holidays and applicable weather-warning days. Notification planning should begin before settlement, rather than being reconstructed afterwards.
The intermediary’s asset-control and reporting responsibilities start when the scheme’s designated account is opened, rather than only after formal immigration approval.[4] A clear asset list, receiving-account confirmation and allocation of reporting responsibilities before instructions are issued can make a change of provider much easier to explain later.
Official sources
General policy information; individual circumstances and the competent authority’s requirements govern each application.