Seven Critical Updates to the Hong Kong Immigration Department’s Biometric Requirements for 2025

The Hong Kong Immigration Department (ImmD) will implement a revised set of biometric data collection requirements effective 1 January 2025. This change affects every person submitting a visa, entry permit, or extension of stay application, regardless of nationality or residence status. The update is codified in an amendment to the Immigration (Biometric Data) Regulation (Cap. 115A), which expands the scope of mandatory biometrics—fingerprints and facial photographs—to include applicants for dependant visas, student visas, and certain investment schemes under the Capital Investment Entrant Scheme (CIES). Failure to comply with the new biometric submission protocol will result in the application being deemed invalid. For Hong Kong permanent residents applying for a Hong Kong Special Administrative Region (HKSAR) passport, the requirement now extends to in-person collection at designated ImmD offices, ending the previous postal submission option. This regulatory shift is driven by the government’s stated goal of enhancing border security and streamlining identity verification, as outlined in the 2024 Policy Address. Practitioners and applicants must understand these seven critical changes to avoid procedural rejection.

The Expanded Scope of Biometric Data Collection

New Applicant Categories Now Covered

The existing biometric requirement under Cap. 115A previously applied only to applicants for a HKSAR passport, a Certificate of Identity, or a Document of Identity for Visa Purposes. The 2025 amendment extends this to all visa and entry permit applications processed by the ImmD. This includes dependant visas, student visas, employment visas (including the Admission Scheme for Mainland Talents and Professionals), and the CIES. The Immigration Department’s official circular, issued in November 2024, confirms that applicants under the Quality Migrant Admission Scheme (QMAS) and the Technology Talent Admission Scheme (TechTAS) are also captured.

In-Person Attendance Requirement

For the first time, the ImmD mandates in-person biometric collection for all applicants aged 11 and above. The previous practice of submitting fingerprints via a courier or through a third-party service is revoked. The application form (e.g., ID 1003A for employment visas) now includes a mandatory field for the applicant to confirm their attendance at a designated ImmD office for biometric capture. The ImmD has published a schedule of 12 district offices equipped with the new biometric kiosks, operating from 8:30 a.m. to 5:30 p.m. on weekdays.

Exemptions and Special Circumstances

The legislation provides limited exemptions. Applicants under the age of 11 are exempt from fingerprinting but must still provide a facial photograph. Persons with a physical disability that prevents fingerprinting may apply for a waiver by submitting a medical certificate from a registered medical practitioner in Hong Kong. The ImmD has stated that the waiver must be submitted at least 14 working days before the biometric appointment. No exemption is available for facial photography.

Changes to the HKSAR Passport Application Process

End of Postal Submission Option

The ImmD confirms that, effective 1 January 2025, all HKSAR passport applications must be submitted in person at a designated ImmD office. The previous option to submit a passport application by post, along with a photograph and a photocopy of the applicant’s Hong Kong permanent identity card, is discontinued. This change applies to both first-time applicants and renewals. The ImmD’s 2024 Annual Report noted that over 60% of passport applications were previously submitted by post.

Biometric Capture at the Time of Application

Applicants must now have their fingerprints and facial photograph taken during the same visit as the application submission. The ImmD has deployed self-service kiosks at 10 major offices. The process takes approximately 10 minutes per applicant. The ImmD advises applicants to book an appointment online at least 7 days in advance, as walk-in slots are limited. The appointment booking system (available via the GovHK website) now integrates directly with the biometric capture schedule.

Validity Period of Biometric Data

The biometric data collected for a passport application will be stored for a period of 10 years, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486). The ImmD has confirmed that this data will not be used for any purpose other than identity verification for immigration applications. Applicants have the right to request access to their biometric data under Cap. 486, Section 18. The ImmD has published a Privacy Policy Statement on its website detailing data retention and deletion procedures.

Impact on Visa Extension and Change of Status Applications

Extensions of Stay Now Require Biometrics

Previously, an application for an extension of stay (e.g., for a holder of an employment visa) could be submitted by post or through the ImmD’s online portal without biometrics. The 2025 amendment changes this. All extension applications, including those for dependants, now require the applicant to attend an in-person biometric appointment. The ImmD’s internal circular, dated 15 October 2024, states that this requirement is retroactive for applications pending as of 1 January 2025.

Change of Status Applications

Applicants who are already in Hong Kong and wish to change their immigration status (e.g., from student to employment) must also comply. The ImmD will not process a change of status application until the biometric data is captured. The application fee remains unchanged at HKD 230 for a change of status, but the biometric capture is free of charge. The ImmD has clarified that the biometric data collected for a change of status application will be linked to the applicant’s new visa category, not their previous one.

Consequences of Non-Compliance

The legislation provides that an application is invalid if the biometric data is not submitted within 14 days of the application date. The ImmD will issue a written notice to the applicant, giving them 14 days to attend a biometric appointment. If the applicant fails to do so, the application is deemed withdrawn. The application fee is not refundable. The ImmD has stated that there is no right of appeal against a deemed withdrawal under this provision.

Practical Steps for Applicants and Legal Practitioners

Step 1: Verify the Application Category

Before submitting any application, confirm whether the applicant falls within the expanded scope. The ImmD’s online eligibility checker (available on the GovHK portal) now includes a biometric requirement indicator. Practitioners should update their internal checklists to include a mandatory biometric appointment booking step.

Step 2: Book the Biometric Appointment

Use the ImmD’s online booking system to schedule an appointment. The system requires the applicant’s Hong Kong identity card number or passport number. The appointment must be booked at least 7 days in advance. The ImmD has stated that walk-in appointments are available only at certain offices and may result in longer wait times.

Step 3: Prepare Required Documents

The applicant must bring the original application form, supporting documents, and their identity document (Hong Kong identity card or passport). The ImmD will not accept photocopies for biometric capture. The applicant must also bring a recent photograph (50 mm x 40 mm) that meets the ImmD’s specifications, although the biometric kiosk will also capture a digital photograph.

Step 4: Attend the Appointment

Arrive at least 15 minutes before the scheduled time. The biometric capture process involves fingerprinting of all ten fingers and a digital facial photograph. The ImmD advises applicants to avoid wearing heavy makeup or accessories that may obscure facial features. The entire process takes approximately 10 minutes.

Step 5: Monitor Application Status

After biometric capture, the applicant can track the application status online using the application reference number. The ImmD’s processing times remain unchanged: approximately 4 weeks for a visa application and 6 weeks for a passport application. The ImmD has stated that biometric capture does not affect processing times.

Actionable Takeaways

1. All visa, entry permit, and extension of stay applications submitted on or after 1 January 2025 require in-person biometric capture at a designated ImmD office.
2. The postal submission option for HKSAR passport applications is permanently discontinued; all passport applications must be submitted in person.
3. Applications pending as of 1 January 2025 are retroactively subject to the new biometric requirement; applicants will receive a written notice to attend an appointment within 14 days.
4. Failure to attend a biometric appointment within 14 days of the ImmD’s notice will result in the application being deemed withdrawn, with no refund of the application fee.
5. Practitioners should update all client intake forms to include a mandatory biometric appointment booking step and confirm the applicant’s eligibility for any limited exemptions under Cap. 115A.

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