1. What the Employer's Return Actually Is
The Employer's Return of Remuneration and Pensions — form BIR56A — is Hong Kong's annual mechanism for the Inland Revenue Department (IRD) to find out what every employer paid every employee, so it can assess each individual's salaries tax. It is separate from your company's Profits Tax Return, and separate from MPF filings with your MPF trustee. It is purely a reporting obligation about pay, not a tax bill in itself.
The IRD issues BIR56A in bulk to all registered employers on 1 April each year, covering the year of assessment that just ended (1 April – 31 March). If you're a first-time employer that the IRD hasn't yet put on this annual cycle, you may instead receive individual notices later in the year — but once your company is on record as an employer, expect the 1 April batch every year going forward.
BIR56A is issued 1 April. You have one month to file it. For the return issued 1 April 2026, that means the filing deadline is 4 May 2026 (1 May falls on Labour Day, a general holiday, so the working deadline rolls to the next business day — always confirm the exact date printed on your own notice).
This obligation applies to every employer, regardless of size. A Hong Kong private limited company with a single director who also happens to be its only "employee" for salary purposes is still an employer under the Inland Revenue Ordinance, and still gets a BIR56A. There is no small-company exemption.
2. BIR56A vs IR56B: What Each Form Does
The Employer's Return is really a package of two form types working together, and startup founders often confuse which one is which:
| Form | What it is | How many you file |
|---|---|---|
| BIR56A | The cover form for the whole company — confirms how many employees you had during the year and declares the return complete | One per company, per year |
| IR56B | A per-employee schedule reporting that individual's full remuneration details for the year | One for every employee/director paid during the year |
| IR56F | Filed separately (not part of the annual return) when an employee ceases employment — due at least 1 month before the employee leaves | Per departing employee, on cessation |
| IR56G | Filed separately when an employee is about to leave Hong Kong for good, or for more than a month, on any employment matter — required before departure so the IRD can settle tax first | Per departing employee, before they leave HK |
For the annual cycle, you always submit BIR56A together with one IR56B for each person paid remuneration in the year — including yourself, if you draw a director's fee or salary from your own company. IR56F and IR56G are separate, event-triggered filings you handle whenever someone actually leaves — not part of the once-a-year batch, but easy to forget alongside it if your only "employee" moves on mid-year.
3. What Counts as "Remuneration" on the IR56B
The IR56B asks for gross income, not just base salary. Founders running payroll for the first time consistently under-report because they think only the monthly salary line counts. It doesn't — the IRD wants the full picture of everything an employee (including a director) received as a result of the employment.
Reimbursements of genuine, receipted business expenses (a client dinner, a flight for a sales trip) are not remuneration and don't belong on the IR56B. But a flat monthly "allowance" paid regardless of actual expense — even if you internally call it a "reimbursement" — is treated as taxable income and must be reported. If in doubt, ask whether the payment depends on the employee producing a receipt for an actual cost: no receipt requirement generally means it's an allowance, not a reimbursement.
4. Nil Returns: When You Genuinely Have No Employees
A newly incorporated company with no paid director and no staff during the year of assessment still has to respond to the BIR56A — you cannot simply ignore it because nobody was paid. In that situation, you complete BIR56A declaring that no remuneration was paid to any person during the period, and submit it as a nil return rather than skipping the filing.
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Confirm nobody was actually paid. If a director drew even a small monthly fee, or the company reimbursed a founder's own salary from a related entity, this is not a nil year.
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File the BIR56A on time regardless. A nil return is still a return — the one-month deadline applies exactly as it does to a company with paid staff.
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Keep evidence of the nil position. Board minutes or bank statements showing no director's remuneration was paid are useful if the IRD later queries the filing.
The moment the company starts paying anyone — even a part-time director's fee of a few thousand dollars a month — the nil-return period ends and full IR56B reporting kicks in for that person from the year it started.
5. Penalties for Late or Incorrect Filing
The Inland Revenue Ordinance treats a late or inaccurate Employer's Return as an offence, not just an administrative slip. The IRD's own guidance sets out that failure to file, or filing an incorrect return, without reasonable excuse can lead to prosecution, with a maximum fine and, in some circumstances, a further penalty calculated by reference to the tax undercharged as a result of the omission. In practice the IRD's first response to a late filer is usually a written reminder or a fixed penalty notice rather than an immediate court summons — but the legal exposure is real, and it compounds the longer the return sits unfiled, because every affected employee's own salaries-tax assessment is stalled behind it.
The most common failure mode isn't refusing to file — it's simply not noticing the notice. BIR56A typically arrives by post to the company's registered office or its nominated correspondence address. A startup that has moved office, uses a virtual address, or has an inattentive company secretary can miss the 1 April issue date entirely and only discover the return exists once the one-month window has already closed.
Beyond the statutory penalty, a late or missing Employer's Return holds up every employee's own individual tax return, which creates real friction with staff and directors who are trying to file their own salaries tax on time — worth keeping in mind on top of the direct financial exposure.
6. Preparing the Return From Your Payroll: Step by Step
If your payroll records are in reasonable shape, actually completing the Employer's Return is a mechanical exercise — the hard part is remembering the deadline and pulling the right numbers together, not the paperwork itself.
Pull a full-year payroll summary per person
For every director and employee paid between 1 April and 31 March, export total salary, bonus, director's fees, allowances, and the value of any benefit in kind (e.g. housing) for the year.
Confirm personal particulars match IRD records
HKID number, full name, and residential address for each person must match what the IRD already holds — mismatches are the single biggest cause of rejected e-filings.
Complete one IR56B per person
Use the IRD's electronic filing software (or a properly formatted spreadsheet upload for larger headcounts) to generate an IR56B for every individual paid, including yourself as director.
Complete the BIR56A cover form
Declare the total headcount and confirm the return is complete — or mark it as a nil return if no remuneration was paid during the year.
File within one month of the 1 April issue date
Submit via the IRD's e-filing portal or by post so it's received before the deadline printed on your own notice (4 May 2026 for the 2026 batch) — don't rely on the postmark date alone for postal filings.
Give each employee their copy
Employees need their IR56B figures to complete their own individual salaries tax returns, so distribute copies (or the relevant figures) promptly after filing.
Set a recurring reminder for 15 March every year — two weeks before the 1 April issue date — to close out that year's payroll numbers and check your registered correspondence address is current with the IRD. That gives you the full one-month window to file rather than discovering the notice with days to spare.
7. CompanyForge Compliance Support
Founders running a lean HK entity often handle payroll themselves in a spreadsheet — which is fine, until the annual Employer's Return, MPF reconciliation, and Profits Tax filing all land in the same quarter. CompanyForge's ForgeOps compliance service keeps the statutory calendar for you, so a missed 1 April notice never turns into a penalty.
ForgeOps Compliance — Payroll & Filing Calendar Included
CompanyForge's ongoing compliance package tracks your Employer's Return, MPF contributions, Profits Tax, and NAR1 annual return deadlines in one calendar, and prepares the IR56B schedules directly from your bookkeeping records via our licensed company secretarial partners.
Our compliance support includes:
- Deadline tracking: Every statutory filing date — Employer's Return, Profits Tax, NAR1, MPF — on one calendar with advance reminders
- IR56B preparation: Per-employee schedules built from your existing payroll or bookkeeping records
- Nil-return handling: Correct filing for pre-revenue companies with no paid staff, so the obligation is met without over-reporting
- Registered address management: Ensuring statutory notices actually reach you instead of an old registered office