The New Capital Investment Entrant Scheme (New CIES) requires every applicant to submit a series of Agreed-Upon Procedures (AUP) Reports prepared by a Certified Public Accountant (Practising) in Hong Kong. AUP reports are the controlling gatekeepers of your New CIES application. Without accurate AUPs, Immigration will not proceed — regardless of your wealth.

For investors, AUP reports are not just a formality. They determine whether your application moves forward, gets delayed, or is rejected. Each report must strictly follow HKSRS 4400 (Revised) and align precisely with the Scheme Rules issued by the New CIES Office.

FastLane’s CPA team handles the full AUP lifecycle from net asset verification to annual portfolio compliance ensuring accuracy, speed, and correct submission.

• Net Asset Verification – proving your HK$30 million net assets over the prescribed six-month period
  
• Investment Requirement Verification – confirming your HK$30 million committed investment and compliance with asset caps
  
• Annual Portfolio Maintenance – ensuring continuous compliance for the full seven-year holding period

With a structured approach, experienced CPA teams, and meticulous HKSRS 4400 (Revised) procedures, we help investors safeguard their applications, avoid mistakes, and move confidently toward residency or unconditional stay in Hong Kong.

What Is an AUP Report Under the New CIES?

An Agreed-Upon Procedures (AUP) Report is an independent factual verification prepared by a Hong Kong Certified Public Accountant (Practising) under HKSRS 4400 (Revised). Unlike an audit or assurance engagement, an AUP does not provide opinions, conclusions, or judgments. Instead, it provides objective findings based solely on procedures agreed between the applicant and the New CIES Office.

Under an AUP engagement, the CPA reports only factual findings; Immigration makes the conclusions.

In the context of the New Capital Investment Entrant Scheme, AUP reports are the backbone of the entire application. Every major milestone — from proving your wealth to verifying your HK$30 million investment — requires a CPA-issued AUP report as formal evidence.

For investors, this means:

• The CPA must verify documents, account balances, transaction trails, valuation proofs, and ownership records exactly as required by the Scheme Rules.
  
• The CPA cannot estimate, infer, or interpret — all findings must be supported by concrete evidence.
  
• Any missing information, discrepancy, or non-compliance will result in delays or rejection by the New CIES Office.
  

In short, the AUP report is the compliance engine that determines whether your New CIES application moves to the next stage. Without properly prepared AUPs, no application can progress — regardless of asset size or investment experience.

Why AUP Reports Are Critical for New CIES Compliance

AUP reports are the non-negotiable backbone of the New CIES. Immigration will not advance an application without AUP-verified evidence confirming your wealth, your HK$30M investment, and your continued compliance during the 7-year period.

Because most investors hold multi-jurisdictional assets, residential properties, private companies, and complex portfolios, Immigration requires an independent HK CPA (Practising) to verify every document through strict HKSRS 4400 (Revised) procedures.

These reports are critical because they ensure:

Accuracy – Verifies that all balances, valuations, and ownership evidence are correct, consistent, and supported by official documentation.

Compliance – Confirms that every asset, transaction, valuation date, and document meets the exact Scheme Rules, investment caps, and procedural requirements.

Traceability – Establishes a complete audit trail for your HK$30M net assets and all CIES fund flows, strengthening transparency for both the investor and Hong Kong’s financial system.

Risk Control – Reduces the risk of breaches such as misclassified assets, ineligible investments, valuation issues, or incorrect account structures that commonly lead to application rejection.

Overview of All 9 AUP Reports Required Under the New CIES

The New Capital Investment Entrant Scheme requires nine distinct AUP reports, each serving a different purpose across the application lifecycle. Together, they form the full compliance framework that Immigration and the New CIES Office rely on.

These nine AUP reports correspond to the three official checkpoints of the New CIES application lifecycle.

Net Asset Assessment AUPs (Pre-Approval Stage)

These verify HK$30M net assets and six-month continuity before submission.

1. Net Asset Summary Verification

Confirms the applicant holds HK$30 million net assets, including cash, securities, real estate, private equity, and other assets.

2. Six-Month Continuous Ownership Verification

Verifies that the assets forming the HK$30M were continuously held across the required six-month period with no breaks.

3. Supporting Document & Valuation Authentication

Authenticates all ownership proofs, valuation reports, statements, loan records, audited accounts, and corporate documents.

Investment Requirement AUPs (Approval-in-Principle → Formal Approval)

These verify the HK$30M committed investment.

4. Committed Investment Verification

Confirms the applicant invested ≥ HK$30M into Permissible Investment Assets within the required timeframe.

5. Permissible Asset Classification Verification

Checks that invested assets comply with strict CIES rules, including caps on:

• Certificates of Deposit (HK$3M)
  
• LPFs / private OFCs (HK$10M)
  
• Real estate (HK$15M total / HK$10M single residential unit)
  

6. Investment Funds Source & Flow Review

Traces all funds used for the investment, ensuring they flowed through the designated intermediary account, with 100% of disposal proceeds reinvested.

Portfolio Maintenance AUPs (Post-Approval → Annual Renewals)

These ensure compliance across the full holding period (usually 7+ years).

7. Annual Portfolio Compliance Verification

Confirms the portfolio meets the HK$30M requirement every year and remains in eligible asset classes.

8. Annual Disposal & Reinvestment Verification

Verifies all disposals, reinvestments, and asset movements comply with ring-fencing rules (i.e., full proceeds reinvested).

9. Annual Supporting Document & Evidence Review

Authenticates updated annual statements, valuations, corporate documents, and real estate ownership proofs.

What CPAs Actually Do in These AUP Engagements (Simplified for Investors)

AUP reports under the New CIES are not audits and not opinions.
Instead, the CPA performs very specific, pre-agreed checking procedures and reports the factual findings exactly as they are.

Below is a clear, investor-friendly breakdown of what your CPA actually does at each stage:

Net Asset AUP – What the CPA Does

Goal: Confirm you invested HK$30M correctly into Permissible Investment Assets within the required timeframe.

What CPAs check

• Contract(s) with your financial intermediary
• Designated account statements
• Real estate proof (Land Registry, payment records, mortgage details)
• Transaction slips showing price, quantity, dates
• Whether each investment meets CIES Scheme Rules
• Whether 100% of sale proceeds were reinvested
• Whether foreign exchange translation is done correctly
• That FX translation uses actual bank-issued rates or official transaction slips
• That market value is not used — book cost is the required basis for CIES compliance

Outcome

A factual confirmation that:

• Your committed investment meets minimum HK$30M
• Asset types fall within acceptable categories
• The money trail is clean and compliant

Investment AUP – What the CPA Does

Goal: Confirm you invested HK$30M correctly into Permissible Investment Assets within the required timeframe.

What CPAs check

• Contract(s) with your financial intermediary
• Designated account statements
• Real estate proof (Land Registry, payment records, mortgage details)
• Transaction slips showing price, quantity, dates
• Whether each investment meets CIES Scheme Rules
• Whether 100% of sale proceeds were reinvested
• Whether foreign exchange translation is done correctly

Outcome

A factual confirmation that:

• Your committed investment meets minimum HK$30M
• Asset types fall within acceptable categories
• The money trail is clean and compliant

This report is used to obtain Formal Approval.

Portfolio Maintenance AUP – What the CPA Does

Goal: Verify your investment continues to remain eligible every year until residency or unconditional stay.

What CPAs check

• Annual designated account statements
• Book cost vs market value of portfolio
• Dividends/interest movements (allowed withdrawals)
• Whether disposal proceeds were 100% reinvested
• Updated real estate documents (rental, mortgage, valuations)
• Whether the HK$30M Net is still satisfied at all times
  

Outcome

A factual yearly compliance report confirming:

• Ongoing eligibility
• Proper reinvestment
• No breaches of ring-fencing rules

This report is required for every renewal, every extension, and final verification before applying for unconditional stay or permanent residency.

Documents Investors Must Prepare

To complete each stage of the New CIES smoothly, investors should prepare a focused set of documents. No long tables — just a streamlined checklist aligned with the 9 required AUP reports

For Net Asset Verification (HK$30M Net Assets)

Banking & Liquid Assets

• 6 months of bank statements
• 6 months of brokerage/custody statements
• Breakdown of asset types (cash, securities, bonds, funds, etc.)

Real Estate

• Valuation report (with valuer credentials)
• Ownership documents (Land Registry or foreign equivalents)
• Mortgage records (if any)
• Comparable transaction data screenshots

Insurance Policies

• Policy statement with investment-linked value
• Valuation or cash value records for the past 6 months
  

Private Companies / Unlisted Equity

• Latest audited financial statements
• Stub period financial statements (if required)
• Management accounts (if applicable)
• Shareholding proof
• Cap table
• Supporting schedules for valuation

Jointly Held Assets

• Legal documents proving family relationship
• Ownership percentage confirmation or legal undertaking

For Investment Requirement Verification (HK$30M Committed Investment)

Permissible Financial Assets

• Contract notes for all purchases
• Bank/brokerage statements showing holdings
• Transfer-in documents (for transferred equities)
• Currency conversion proof (actual FX rate, if available)

CIES Investment Portfolio (HK$3M)

• Subscription confirmation
• Account statement showing fund holding
• Deposit records
  

Real Estate Investments

(Up to HK$15 million of the committed investment may be allocated to real estate. Within this, up to HK$10 million may be allocated to a single residential property. Residential properties purchased before 17 September 2025 must follow the transitional requirement of ≥ HK$30M. Properties purchased on or after 17 September 2025 must comply with the updated HK$10M single residential property cap and single-property restriction.)

• Sale & Purchase Agreement
• Completion statement
• Land Registry documents
• Mortgage details to calculate net equity
• Valuation report
• Proof of transaction date (critical for 16 Oct 2024 / 17 Sept 2025 rules)

Financial Intermediary Compliance

• Evidence that the designated broker/bank is CIES-approved
• Designated account statements
• No-margin-trading confirmation (implicit via account type)

For Annual Portfolio Maintenance (Years 1–7)

Asset Holdings

• Annual statements from bank/broker/custodian
• Updated valuation for any non-public assets held through a Holding Company
• Real estate ownership confirmation
• Mortgage updates (if applicable)

Transaction Records

• Contract notes for disposals & reinvestments
• FX conversion evidence
• Records of reinvestment of FULL sale proceeds

Compliance Items

• Updated breakdown of:
  
  • CDs (≤HK$3M)
  • LPFs/OFCs (≤HK$10M)
  • Real estate (≤HK$15M, residential ≤HK$10M)

Holding Company Documentation (if applicable)

• Confirmation that the Holding Company meets all Scheme Rule conditions during the entire investment period
• Management proof from Eligible Single Family Office (if applicable)

Common Mistakes That Cause New CIES AUP Rejections (And How to Avoid Them)

The New Capital Investment Entrant Scheme is a documentation-driven programme.
Most applications are not rejected because the investor lacks HK$30 million — they fail because the AUP evidence is incomplete, inconsistent, or non-compliant with HKSRS 4400 and Scheme Rules.

Below is a structured breakdown of the most common mistakes investors make, why the New CIES Office rejects them, and how to avoid delays that can cost months.

Missing or Inadequate 6-Month Net Asset Evidence

The Net Asset Assessment is the first bottleneck.
Applicants often submit:

• Account statements that do not cover the full six months
• Screenshots instead of bank-issued documents
• Consolidated statements without asset breakdown
• Statements missing page numbers, dates, or identity details

Because the CPA must verify continuous ownership at HK$30M for six full months, any gap — even a missing week — forces resubmission.

How to avoid:
Ensure all banks and brokers provide official monthly statements with full breakdowns and matching dates.

Non-Compliant Valuation Reports for Real Estate

Real estate valuations are one of the biggest rejection points.
The New CIES Office requires:

• Valuation date aligned with assessment date
• Clear asset description, photos, and condition
• Comparable transactions with geography matching
• Valuer qualifications and methodology

Generic or informal valuation letters are not accepted.

How to avoid:
Use valuers recognised by Hong Kong CPAs and ensure the report follows professional valuation standards.

Investing Through Non-Eligible Financial Intermediaries

The Scheme mandates the use of designated accounts operated by eligible intermediaries.

Common mistakes:

• Using global trading apps not approved in Hong Kong
• Holding assets in accounts that permit margin trading
• Mixing CIES assets with personal or business investments

These errors invalidate the entire investment portion.

How to avoid:
Open a dedicated CIES-designated account before executing any investment transactions.

Incorrect Calculations of Investment Caps

The New CIES imposes strict limits that many investors unintentionally breach:

• Certificates of Deposit – HK$3M cap
• LPFs / private OFCs – HK$10M cap
• Total real estate – HK$15M cap
• Residential real estate – HK$10M cap, must be one single property, with different rules applying to properties purchased before and after 17 September 2025
• Breaching a cap means the CPA cannot issue the AUP report.

How to avoid:
Track each category against the cap before making the investment.

Non-Compliant Real Estate Purchases

Residential properties purchased on the wrong dates or with the wrong structure will not qualify. Examples:

• Buying residential property before 16 October 2024
• Buying residential property below HK$30M during the transitional period (before 17 September 2025)
• Buying multiple residential units (not allowed)
• Purchasing mixed-use property without clear zoning proof

How to avoid:
Verify zoning, value, and transaction date before signing any purchase agreement.

Failure to Reinvest 100% of Sale Proceeds

Under CIES Rules:

All sale proceeds — without deductions — must be fully reinvested into Permissible Investment Assets.

Common errors include:

• Deducting fees or charges before reinvestment
• Holding surplus cash outside designated accounts
• Reinvesting only the net amount after FX conversions

How to avoid:
Ensure every dollar from disposal is reinvested in full, and keep FX conversion proof.

Incomplete Foreign Currency Documentation

Many applicants hold USD, EUR, or CNY assets.
But they often fail to provide:

• Actual bank FX rates
• Dates of conversion
• Official statements showing HKD equivalents

Without this, CPAs cannot confirm the HKD value of your assets.

How to avoid:
Export FX transaction slips or daily TT rate confirmations from the bank.

Holding Company Non-Compliance

Applicants using a Holding Company structure must meet every Scheme Rule condition.

Frequent mistakes:

• The Holding Company not meeting the 6-month continuous compliance requirement
• Missing proof of governance, ownership structure, or financial statements
• Failing to demonstrate the Eligible Single Family Office relationship (if applicable)

How to avoid:
Ensure corporate documents are complete, updated, and aligned with the 6-month requirement.

Date Inconsistencies Across Documents

Even small date mismatches can cause rejection:

• Statement date ≠ valuation date
• Contract note date ≠ CPA calculation date
• CPA report issued more than 14 days before submission
• Real estate completion date not matching Land Registry records

The New CIES Office checks dates line by line.

How to avoid:
Choose one consistent timeline and align every supporting document to it.

Incorrectly Certified True Copies

Many investors misunderstand the requirement:

Applicants must personally sign the first and last page of each set.

• Not notarised.
• Not signed by an assistant.
• Not stamped by a firm.
• Signed by the investor.

Missing signatures = incomplete submission.

How to avoid:
Sign correctly and ensure every supporting document set is complete.

Why Professional AUP Support Matters

The AUP reports required under the New CIES are not simple confirmations — they are technical, rule-based procedures that must strictly follow HKSRS 4400 (Revised). A single mismatch, missing document, or date inconsistency can invalidate an application or delay your approval timeline.

Professional AUP support ensures your submission is clean, accurate, and defensible.

Why Investors Shouldn’t DIY the AUP Process

1. The New CIES Office rejects incomplete or inconsistent evidence
Most rejections come from mismatched dates, valuation gaps, or incorrect currency translation. A professional team ensures every proof aligns perfectly with the Scheme Rules.

2. AUP is factual verification — not interpretation
CPAs cannot “estimate” or “assume” values. They can only verify what you provide.
If the evidence is incomplete, the CPA must state a limitation — and that can derail your application.

3. Multiple checkpoints = multiple risks
You need AUP reports at:

• Net Asset Assessment
• Investment Requirement Assessment
• Annual Portfolio Maintenance (every year)

Each stage has different evidence rules, caps, and compliance requirements. A misstep at any point resets your timeline.

4. Real estate, private funds, and joint ownership require specialised handling
Cross-border ownership, valuation rules, and investment caps create complexity.
Without professional guidance, the risk of breaching a rule is high.

5. Avoiding delays protects your residency timeline
A rejected AUP means:

• your 180-day investment period may lapse
• your approval timeline resets
• you may need fresh valuation reports, new statements, and re-certification

Professional support eliminates this uncertainty.

What Investors Gain With Professional AUP Preparation

• Clean, rule-compliant documentation
• Zero ambiguity between purchase dates, valuation periods, and statements
• Correct handling of caps (CDs, LPFs, real estate, etc.)
• Accurate consolidation of global assets
• Efficient communication with financial intermediaries
• Faster verification by the New CIES Office

In short: professionally prepared AUP = no errors, no rework, no delays.

How FastLane Supports Investors Under the New CIES

FastLane provides a complete AUP service ecosystem designed specifically for the New Capital Investment Entrant Scheme, giving investors the confidence that every compliance requirement is handled with precision and speed.

Our team prepares all mandatory Agreed-Upon Procedures (AUP) reports required at three critical checkpoints — Net Asset Assessment, Investment Requirement Verification, and Annual Portfolio Maintenance. Each report is performed strictly under HKSRS 4400 (Revised), ensuring that every figure, document, and calculation aligns with the exact standards set by the New CIES Office.

FastLane works as your dedicated compliance partner throughout the entire application lifecycle. We verify your asset position, review investment transactions, prepare the required schedules for caps and surplus equity, and ensure all documentation is complete, consistent, and submission-ready. This eliminates the risk of delays, rejections, or repeated submissions — allowing investors to move through each stage with confidence.Whether you are just beginning your application or preparing for your annual maintenance cycle, FastLane delivers an end-to-end, professionally managed AUP process that keeps your residency journey smooth, compliant, and fully aligned with Hong Kong’s regulatory requirements. Speak to FastLane’s audit team today for fully compliant AUP reporting.