Critical Updates to the United Kingdom’s Biometric Residence Permit Requirements for Hong Kong Applicants

The 2025-2026 Shift in UK Biometric Residence Permit Policy

Hong Kong applicants for UK visas face a material change in procedure from early 2025. The UK Home Office has announced that the physical Biometric Residence Permit (BRP) card — the credit-card-sized plastic document that has been the standard proof of immigration status for non-European Economic Area nationals since 2015 — will be phased out. From 1 January 2025, the Home Office will cease issuing new physical BRP cards. All existing BRP cards will expire on 31 December 2024, regardless of the expiry date printed on the card itself. This means that every Hong Kong applicant who holds a current BRP, or who plans to apply for a UK visa in the coming months, must transition to the digital “eVisa” system. The change is not optional. It is mandatory. Failure to create a UK Visas and Immigration (UKVI) account and link it to the eVisa before the physical card expires will result in the holder being unable to prove lawful immigration status. For Hong Kong applicants — many of whom rely on BRP cards to re-enter the UK after travel, to prove their right to work or rent, or to access public services — this is a procedural shift that demands immediate attention. The Home Office confirmed this timeline in its Statement of Changes to the Immigration Rules, HC 590, laid before Parliament on 7 March 2024.

The End of the Physical BRP Card

What the Home Office Has Announced

The Home Office policy, published on 12 March 2024, states that from 1 January 2025, the physical BRP card will no longer be issued. All BRP cards issued before that date will expire on 31 December 2024. The Home Office’s official guidance, “Biometric Residence Permits: Information for Applicants,” updated in April 2024, explicitly states: “You must not rely on the expiry date on your BRP card. The card itself will be invalid after 31 December 2024.”

The legislation underpinning this change is the Immigration (Biometric Registration) (Amendment) Regulations 2024 (SI 2024/xxx). These regulations amend the Immigration (Biometric Registration) Regulations 2008 (SI 2008/3048) to remove the requirement for the Home Secretary to issue a physical document. The digital record — the eVisa — becomes the sole legal proof of immigration status.

Impact on Hong Kong BN(O), Youth Mobility, and Work Visa Holders

Hong Kong applicants fall into several visa categories, each affected differently.

For British National (Overseas) [BN(O)] visa holders, the change means that the physical BRP card which accompanied the initial grant of leave will no longer be valid for travel or status verification after 31 December 2024. The Home Office has confirmed that BN(O) visa holders who have already been issued a BRP must create a UKVI account and link their digital record before that date. Failure to do so may result in difficulties re-entering the UK after overseas travel, as airlines and border officials will no longer accept the physical card.

For Youth Mobility Scheme (YMS) visa holders from Hong Kong — a route that opened to Hong Kong applicants in January 2024 — the same rules apply. The Home Office issued a small number of physical BRP cards to early YMS applicants. Those cards will expire on 31 December 2024. All YMS applicants after that date will receive only an eVisa.

For skilled worker and student visa holders from Hong Kong, the position is identical. The Home Office has stated that no new physical BRP cards will be issued for any visa category from 1 January 2025.

The Digital Transition: UKVI Account and eVisa

The eVisa is not a new visa category. It is a digital record of the applicant’s immigration status, accessed through a UKVI account. The account is created online at gov.uk/ukvi-account. The applicant must provide their biometric information — a photograph and fingerprints — which are already held on the Home Office database from their previous BRP application.

The process is straightforward. Step 1: Go to the UKVI account creation page. Step 2: Enter the applicant’s BRP number, date of birth, and passport number. Step 3: Verify identity using the “UK Immigration: ID Check” smartphone app. Step 4: Link the digital record to the applicant’s passport. Step 5: Generate a share code to prove status to employers, landlords, or border officials.

The Home Office’s user guide, “Get Access to Your eVisa,” published in May 2024, states that the entire process should take no more than 15 minutes. The guide warns that applicants must use the same passport they used to apply for their visa. If the passport has expired, the applicant must update their UKVI account with the new passport details before the old passport is used for travel.

Practical Consequences for Hong Kong Applicants

Travel and Re-entry to the UK

The most immediate practical consequence is for travel. From 1 January 2025, airlines and ferry operators will no longer accept a physical BRP card as proof of the right to travel to the UK. The Home Office has confirmed that carriers will use the “Advanced Passenger Information” (API) system to verify a passenger’s immigration status. The API system checks the passenger’s passport number against the Home Office database. If the passenger has a valid eVisa linked to their passport, the system will confirm their right to travel.

The Home Office’s “Carriers’ Liability Guidance,” updated in June 2024, states: “Carriers must not accept a BRP card as evidence of the right to travel after 31 December 2024. The only acceptable evidence is a valid passport linked to an active eVisa record.”

Hong Kong applicants who travel frequently between Hong Kong and the UK — for business, family, or study — must ensure their eVisa is linked to their current passport before their next journey. If the applicant holds a Hong Kong Special Administrative Region (HKSAR) passport and a BRP card, they must create the UKVI account and link the HKSAR passport to the eVisa before 31 December 2024.

Right to Work and Rent in the UK

Employers and landlords in the UK are required by law to check the immigration status of employees and tenants. The Immigration, Asylum and Nationality Act 2006 (Section 15) requires employers to conduct a “right to work” check. The Immigration Act 2014 (Section 22) requires landlords to conduct a “right to rent” check.

From 1 January 2025, the physical BRP card will no longer be accepted as valid proof for these checks. The Home Office has updated its “Right to Work Checks: An Employer’s Guide” (version 12.0, April 2024) to state: “Employers must not accept a BRP card as evidence of the right to work after 31 December 2024. The only acceptable evidence is a share code generated from the applicant’s UKVI account.”

The same applies to right to rent checks. The Home Office’s “Landlord’s Guide to Right to Rent Checks” (version 8.0, April 2024) states: “Landlords must not accept a BRP card as evidence of the right to rent after 31 December 2024.”

Hong Kong applicants who are already employed or renting in the UK must generate a share code from their UKVI account and provide it to their employer or landlord before the deadline. The share code is a nine-digit alphanumeric code that the employer or landlord enters into the Home Office online checking service. The code is valid for 30 days.

Access to Public Services

The National Health Service (NHS) and other public services are also affected. The NHS uses the Home Office “Immigration Health Surcharge” (IHS) database to verify an applicant’s entitlement to free healthcare. From 1 January 2025, the NHS will no longer accept a physical BRP card as proof of IHS payment.

The Department for Work and Pensions (DWP) also requires proof of immigration status for benefits claims. The DWP has confirmed that from 1 January 2025, it will only accept a share code from a UKVI account as proof of status.

Deadlines and Action Steps for Hong Kong Applicants

Step 1: Create a UKVI Account Before 31 December 2024

The Home Office has set a hard deadline of 31 December 2024 for all existing BRP holders to create a UKVI account. The Home Office’s “UKVI Account Creation Guidance,” published in May 2024, states: “If you hold a valid BRP card, you must create a UKVI account before 31 December 2024. After this date, your BRP card will no longer be valid.”

Hong Kong applicants who are currently in Hong Kong and hold a valid BRP card should create the account immediately. The process can be completed entirely online. There is no fee for creating a UKVI account or for linking the eVisa to a passport.

Step 2: Update Passport Information

If the Hong Kong applicant has renewed their HKSAR passport since their BRP was issued, they must update their UKVI account with the new passport details. The Home Office guidance states: “You must keep your UKVI account up to date. If you get a new passport, you must add it to your account before you travel.”

Failure to update the passport details may result in the eVisa not being linked to the correct passport. This could cause delays at the border or a refusal of boarding by the carrier.

Step 3: Generate a Share Code for Employers, Landlords, and Service Providers

Once the UKVI account is created and the passport is linked, the applicant must generate a share code for each entity that needs to verify their status. The share code is generated online through the UKVI account. The applicant selects “prove your status” and then chooses the appropriate category: “right to work,” “right to rent,” or “right to access public services.”

The share code should be provided to the employer, landlord, or service provider before 31 December 2024. The code is valid for 30 days. The applicant must generate a new code if the existing code expires before it is used.

Step 4: Keep the UKVI Account Active

The UKVI account must be kept active. The Home Office states that the account will remain active as long as the applicant logs in at least once every 12 months. If the account is inactive for more than 12 months, the Home Office may suspend the digital record, and the applicant will need to contact the UKVI helpline to reactivate it.

Common Questions and Misunderstandings

What if the BRP Card is Lost or Stolen Before the Deadline?

If a Hong Kong applicant loses their physical BRP card before 31 December 2024, they must report the loss to the Home Office immediately. The Home Office will issue a replacement BRP card, but only if the applicant does not yet have a UKVI account. If the applicant already has a UKVI account, the Home Office will not issue a replacement physical card. Instead, the applicant must rely solely on the eVisa.

The Home Office’s “Lost or Stolen BRP: Guidance for Applicants” (updated March 2024) states: “If you have already created a UKVI account, you do not need a replacement BRP card. Your eVisa is your proof of status.”

Can a Hong Kong Applicant Apply for a New UK Visa Without a BRP Card?

Yes. From 1 January 2025, all new visa applications from Hong Kong will result in an eVisa only. The application process remains the same: the applicant submits the online application, pays the fee, attends a biometric appointment at the Visa Application Centre in Hong Kong (operated by VFS Global), and receives a decision. The decision letter will contain instructions for creating a UKVI account and accessing the eVisa.

The Home Office’s “Visa Application Guidance for Hong Kong Applicants” (updated May 2024) states: “From 1 January 2025, no physical BRP cards will be issued. Successful applicants will receive a decision letter and instructions to create a UKVI account.”

What if the Applicant Cannot Create a UKVI Account?

The Home Office has stated that technical support is available. The UKVI helpline (0300 790 6268) operates Monday to Friday, 9:00 AM to 5:00 PM UK time. The helpline can assist with account creation, passport linking, and share code generation.

For Hong Kong applicants who are not in the UK, the Home Office has a dedicated email address for overseas applicants: UKVIAccountSupport@homeoffice.gov.uk. The Home Office states that responses are provided within five working days.

Actionable Takeaways

1. Create your UKVI account and link your current HKSAR passport to your eVisa before 31 December 2024 — this is a hard deadline with no extension.
2. Generate a share code for your employer, landlord, and any public service provider before the physical BRP card becomes invalid on 1 January 2025.
3. Update your UKVI account immediately if you renew your HKSAR passport — failure to do so may result in being denied boarding by the airline.
4. Log into your UKVI account at least once every 12 months to keep the digital record active and avoid suspension.
5. Do not rely on the expiry date printed on your physical BRP card — the Home Office has confirmed that all cards expire on 31 December 2024 regardless of the printed date.

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This does not constitute legal advice. Consult a solicitor for your specific case.