Hong Kong New CIES: proving six months of net assets

The requirement covers the full six-month period

Hong Kong’s New Capital Investment Entrant Scheme (New CIES) requires at least HK$30 million, or the foreign-currency equivalent, in net assets to which the applicant is absolutely beneficially entitled throughout the six months before applying for Net Asset Assessment. A Hong Kong Certified Public Accountant (Practising) must be engaged, at the applicant’s expense, to issue the Fulfillment document with supporting evidence.1

The assessment concerns a continuing personal net position. A balance that rises shortly before submission cannot alone establish the preceding period. Asset sales, transfers and changes in borrowing during those months need to be explained as well.

Joint ownership is assessed through the applicant’s share

The official FAQs allow the applicant’s beneficial share of assets jointly held with qualifying family members to be counted.2 Family ownership does not make the entire value the applicant’s personal asset.

A simplified example illustrates the distinction. An asset valued at HK$10 million has HK$4 million of related debt. If both the equity and debt are attributable to the applicant in a 50% share, the indicative net interest is HK$3 million. The actual amount requires an accountant’s review of ownership, liability allocation and the applicable valuation.

Business interests require comparable care. Turnover, company cash and a shareholder’s personal interest describe different things. A value already included in a company valuation should not be counted again as a separate personal asset.

Net assets and qualifying investment are separate assessments

The Scheme Rules allow certain non-publicly traded assets, supported by appropriate valuations, to be used for Net Asset Assessment. That treatment does not make the same assets eligible for the subsequent investment requirement.3

The HK$30 million test should consequently not be described as a requirement to hold that sum in cash in one account for six months. Nor does meeting the net asset threshold demonstrate that the required investment has been made. Liquidity, realisation dates and the eligible investment categories need separate consideration.

This distinction also helps organise the evidence. Title, valuation and borrowing records establish net assets; account, transaction and holding records explain compliance with the investment requirements.

Certification needs to be coordinated with submission

Normally, no more than 14 calendar days may elapse between the issue of the Fulfillment document and the Net Asset Assessment application. If the final day is a weekend or public holiday, the official FAQs allow submission on the next weekday that is not a public holiday.12 The accountant’s issue date therefore needs to fit the completion of the evidence and the intended filing date.

A file grouped by asset class, owner, holding period, valuation and liabilities is easier to follow. Matching names across originals and translations also helps. Immigration and investment assessments remain separate procedural steps after the net asset review.4

November applications face an additional account consideration

The official guidance states that, for Net Asset Assessment applications submitted on or after 1 November 2026, financial assets bought through non-designated accounts will not be accepted towards the subsequent investment requirement. Moving those assets into a designated account afterwards will not remedy the position.2

The measure is not yet applicable at this article’s review date. Applicants planning to file from November should nevertheless confirm the account route before acquiring financial assets they intend to count.

Financial preparation also presupposes that the applicant meets the scheme’s personal entry criteria. Nationality and status, net assets and the investment procedure each require consideration under the relevant Immigration Department and New CIES Office rules.4

Government sources and legislation

1. InvestHK New CIES Office: net asset assessment
2. New CIES Office: net asset and investment FAQs
3. Rules for the New Capital Investment Entrant Scheme, 2026
4. Hong Kong Immigration Department: New CIES

This article provides general information. Before applying, check the current rules, fees and procedures against your individual circumstances.