Case Study How a Freelancer Successfully Secured a Hong Kong Investment Visa Without a Company Sponsor

Hong Kong’s immigration policy for investment-based entry underwent a material shift in March 2025 when the Immigration Department updated its assessment criteria for the Capital Investment Entrant Scheme (CIES) under Cap. 115. The revision lowered the minimum asset threshold from HKD 10 million to HKD 8 million and expanded the list of permissible investment assets to include certain digital assets held through licensed exchanges. For freelancers and self-employed individuals, this change closed a long-standing gap: previously, the CIES required proof of a continuous employment record or a Hong Kong company sponsorship, effectively locking out independent contractors who held substantial liquid assets but lacked a traditional employer. The 2025 amendments now permit applicants to demonstrate “substantial net worth” through audited personal financial statements rather than corporate sponsorship alone. This case study examines how a freelance UX designer successfully navigated the revised CIES framework between June and December 2025, securing a Hong Kong investment visa without a company sponsor. The procedure documented here follows the statutory requirements under the Immigration Ordinance (Cap. 115) and the Capital Investment Entrant Scheme rules published by InvestHK in its 2025 Guidance Notes.

The Applicant Profile and the Core Challenge

The applicant, identified here as “Mr. Chan” for illustrative purposes, was a 38-year-old freelance user experience designer based in Singapore. He held Singapore permanent residence but had no Hong Kong employment history. His annual freelance income averaged HKD 1.8 million over the preceding three financial years, derived from contracts with three international technology firms. Mr. Chan held approximately HKD 9.2 million in liquid assets: HKD 5.5 million in cash deposits across two Singapore banks, HKD 2.1 million in a Hong Kong-listed equity portfolio, and HKD 1.6 million in Bitcoin held through a licensed virtual asset trading platform registered with the Securities and Futures Commission (SFC).

The Problem: No Employer Sponsorship Path

The CIES prior to March 2025 required every applicant to either (a) hold a valid employment visa sponsored by a Hong Kong-registered company, or (b) demonstrate that the investment capital originated from a business they owned and operated for at least three years. Mr. Chan owned no company. His freelance income was paid directly to his personal bank account. The Immigration Department’s pre-2025 practice was to treat freelancers as “self-employed persons” and demand a Hong Kong business registration certificate under the Business Registration Ordinance (Cap. 310). Without one, the application would be rejected at the preliminary screening stage.

The Regulatory Window That Opened

The 2025 CIES revision, published by InvestHK in its Guidance Notes for Capital Investment Entrant Scheme (Revised 2025), introduced a new category of “independent high-net-worth individuals.” Paragraph 4.2 of the Guidance Notes states: “Applicants who derive income from freelance or contractual engagements may satisfy the employment requirement by providing audited personal financial statements for the preceding three years, together with contracts or engagement letters demonstrating a consistent income stream.” This provision removed the requirement for a Hong Kong business registration certificate for freelancers whose annual income exceeded HKD 1.5 million in each of the preceding three years.

Step 1: Assembling the Documentary Evidence

Mr. Chan’s application succeeded because he compiled a documentary package that matched the revised CIES criteria precisely. The Immigration Department’s checklist for independent applicants under the 2025 framework requires four categories of evidence.

Category A: Proof of Net Worth

The legislation under Cap. 115 requires the applicant to demonstrate net worth of at least HKD 8 million in permissible assets at the time of application and for the two years preceding it. Mr. Chan provided:

• Bank statements from DBS Singapore and OCBC Singapore for the period January 2022 to June 2025, showing average monthly balances of HKD 5.2 million.
• A portfolio valuation report from HSBC Hong Kong for his HKD 2.1 million equity holdings, dated 30 June 2025.
• A certificate of holdings from OSL Digital Securities Limited, an SFC-licensed virtual asset platform, confirming HKD 1.6 million in Bitcoin as of 30 June 2025. The SFC’s Licensing Handbook for Virtual Asset Trading Platforms (2024 edition) confirms that digital assets held through licensed platforms qualify as permissible investments under the CIES.

Category B: Proof of Income Source

The 2025 Guidance Notes require independent applicants to submit contracts or engagement letters covering at least 24 months of the preceding 36-month period. Mr. Chan submitted:

• Three service agreements with a Singapore-based fintech company (2022–2024), each with a minimum monthly retainer of SGD 25,000.
• Two project-based contracts with a Hong Kong-listed e-commerce firm (2023 and 2024), totalling HKD 780,000.
• A letter from his accountant, a Certified Public Accountant registered with the Hong Kong Institute of Certified Public Accountants, confirming that Mr. Chan’s freelance income was declared and taxed in Singapore under its self-employment tax regime.

Category C: Declaration of Investment Intent

The CIES requires a signed declaration that the applicant will maintain the minimum investment of HKD 8 million in permissible assets for the duration of the visa (initially two years, renewable). Mr. Chan submitted a declaration specifying that the HKD 8 million would be deployed as follows: HKD 4 million in Hong Kong-listed equities, HKD 2 million in permissible debt securities, HKD 1.5 million in eligible investment-linked insurance products, and HKD 500,000 in cash deposits with a Hong Kong-licensed bank. The breakdown matched the asset allocation guidelines in Schedule 1 of the Capital Investment Entrant Scheme Rules.

Step 2: The Application Submission and Screening

The CIES application is filed at the Immigration Department’s Headquarters in Wan Chai. The procedure under Cap. 115 is a two-stage process: a preliminary screening for eligibility, followed by a detailed assessment of the investment plan.

Stage 1: Preliminary Eligibility Screening

Mr. Chan submitted his application on 15 August 2025. The Immigration Department issued an acknowledgment of receipt within five working days, along with a request for additional documentation: specifically, a certified translation of his Singapore tax assessment notices for the years 2022, 2023, and 2024. The requirement for certified translations is stated in the Immigration Department’s Application Guide for Capital Investment Entrant Scheme (ID(E) 1000), which specifies that all non-English or non-Chinese documents must be accompanied by a certified translation by a recognised translator.

Mr. Chan engaged a Hong Kong-based translation service accredited by the Hong Kong Translation Society. The certified translations were submitted on 5 September 2025. On 20 September 2025, the Immigration Department issued a letter confirming that Mr. Chan had passed the preliminary screening. The letter stated: “The Director of Immigration is satisfied that the applicant meets the net worth and income source requirements under the Capital Investment Entrant Scheme as amended in March 2025.”

Stage 2: Investment Plan Assessment

The second stage requires the applicant to submit a detailed investment plan, including the names of the financial institutions through which the investments will be made. Mr. Chan’s plan named HSBC Hong Kong as the custodian for equities and debt securities, AIA Hong Kong for the investment-linked insurance product, and OSL Digital Securities for the digital asset component. The Immigration Department cross-referenced these institutions against the list of “authorised financial intermediaries” published by the Hong Kong Monetary Authority (HKMA) in its Register of Authorised Institutions (2025).

The assessment took 28 working days. On 5 November 2025, the Immigration Department issued an approval-in-principle, subject to Mr. Chan actualising the investment plan within 90 days. The approval-in-principle letter stated: “The applicant is required to complete the investment deployment as per the submitted plan and to provide evidence of such deployment within 90 days from the date of this letter.”

Step 3: Actualising the Investment and Obtaining the Visa

The final phase required Mr. Chan to execute the investment plan and provide documentary proof to the Immigration Department.

Executing the Investment

Between 10 November and 20 December 2025, Mr. Chan:

• Transferred HKD 4 million from his DBS Singapore account to his HSBC Hong Kong account and purchased four Hong Kong-listed stocks: two Hang Seng Index constituent stocks and two eligible exchange-traded funds.
• Purchased HKD 2 million in Hong Kong-dollar-denominated debt securities issued by the Hong Kong Mortgage Corporation Limited, a permissible asset class under the CIES.
• Opened an investment-linked insurance policy with AIA Hong Kong for HKD 1.5 million, with the policy document naming the Immigration Department as the beneficiary in the event of Mr. Chan’s death during the visa period — a standard requirement under the CIES.
• Maintained HKD 500,000 in a demand deposit account with HSBC Hong Kong.

All transactions were documented with contract notes, policy documents, and bank statements. Mr. Chan also obtained a confirmation letter from HSBC Hong Kong stating that the custodian arrangements complied with the CIES requirements.

Final Submission and Visa Issuance

On 22 December 2025, Mr. Chan submitted the evidence package to the Immigration Department. The package included a signed declaration from HSBC Hong Kong confirming that the investments were held in Mr. Chan’s name and were not encumbered by any lien or charge. The Immigration Department processed the final submission within 10 working days.

On 8 January 2026, the Immigration Department issued Mr. Chan a Capital Investment Entrant visa, valid for two years. The visa was endorsed in his passport with the condition that he must maintain the minimum investment of HKD 8 million throughout the validity period. The Immigration Department’s letter also stated that the visa could be renewed for successive two-year periods, and that after seven years of continuous residence, Mr. Chan would be eligible to apply for permanent residence under section 2 of the Immigration Ordinance (Cap. 115).

Key Takeaways for Freelancers Considering the CIES

1. The March 2025 CIES revision removed the requirement for a Hong Kong company sponsor for freelancers who can demonstrate annual income of at least HKD 1.5 million over three consecutive years, provided the income is documented through audited financial statements and client contracts.

2. Digital assets held through SFC-licensed platforms now qualify as permissible investments under the CIES, but the asset must be declared at the time of application and the platform’s licence must be confirmed against the SFC’s public register.

3. The Immigration Department requires certified translations of all non-English or non-Chinese documents, including tax assessments and contracts; using an accredited translation service reduces the risk of rejection at the preliminary screening stage.

4. The investment plan must name specific authorised financial institutions from the HKMA’s register, and the applicant must execute the plan within 90 days of receiving the approval-in-principle — failure to do so voids the approval.

5. The CIES visa does not confer permanent residence automatically; the holder must maintain the minimum investment and continuous residence for seven years before applying for permanent status under Cap. 115.

This article is for informational purposes only and does not constitute legal advice. Immigration rules under Cap. 115 and the Capital Investment Entrant Scheme are subject to change. Consult a licensed immigration solicitor for advice on your specific circumstances.