MPF Depends on the Working Relationship
A Hong Kong startup generally must enroll eligible full-time and part-time employees aged 18 to 64 within the first 60 days of continuous employment, unless a statutory exemption applies. An overseas founder may also need MPF if they are an executive director involved in daily operations and receive remuneration.
Foreign status does not create an automatic exemption. The most relevant expatriate exemptions concern people entering Hong Kong for employment for no more than 13 months, or people who remain members of an overseas retirement scheme.
For overseas founders, the safest approach is to classify each person by role first: employee, executive director, non-executive director, self-employed person or genuinely overseas worker. Then apply the MPF coverage and exemption rules to that status.
Who needs MPF in a Hong Kong startup?
Under the Mandatory Provident Fund Schemes Ordinance (Cap. 485) , the core rule covers employees and self-employed persons aged 18 to 64, subject to exemptions. For a regular employee, the employer must enrol the person within the first 60 calendar days of continuous employment.
Part-time status does not remove coverage. MPFA states that a part-time employee who has been employed continuously for 60 days or more is generally covered regardless of the number of days or hours worked each week.
| Startup role | Typical MPF position | Founder check |
|---|---|---|
Full-time employee, age 18–64 | Usually covered | Enrol within 60 days unless exempt. |
Part-time employee, age 18–64 | Usually covered | Hours per week do not cancel the 60-day rule. |
Executive director receiving remuneration | Can be covered | MPFA says daily operational involvement plus remuneration can require enrolment. |
Non-executive director not involved in daily operations | Generally not required | Document the actual governance-only role. |
Sole proprietor or partner | SEP rules may apply | Self-employed persons have their own enrolment and contribution rules. |
Casual worker in construction or catering | Special rules | The 60-day rule does not apply; Industry Scheme rules can apply even for one day. |
A founder who simply owns shares is not automatically an employee or self-employed person for MPF purposes. The actual relationship matters. For limited-company founders, director duties, daily operational involvement and remuneration are particularly important facts.
When can an overseas founder or employee be exempt?
The most useful exemption for overseas teams is narrower than many founders expect. MPFA lists as exempt a person who enters Hong Kong under section 11 of the Immigration Ordinance (Cap. 115) for employment and either has permission to remain for no more than 13 months or is a member of a retirement scheme outside Hong Kong.
Short employment visa
A permitted stay of 13 months or less can qualify. If an extension takes the total stay beyond 13 months, the exemption can cease after month 13.
Overseas retirement scheme
An employment-visa holder who is already a member of a retirement scheme outside Hong Kong may be exempt. MPFA says that overseas scheme does not need MPFA approval.
Genuinely overseas employment
A worker employed outside Hong Kong and working outside Hong Kong may fall outside MPF coverage if the connection with Hong Kong is insufficient.
Non-executive director
A director who is not involved in daily operations is generally not required to join merely because they hold a board position.
How much do the employer and employee contribute?
For monthly-paid regular employees, employers and employees generally each contribute 5% of relevant income, subject to statutory minimum and maximum income levels. The employer’s contribution comes from the employer’s own funds; the employee portion is deducted from the employee’s relevant income when required.
| Monthly relevant income | Employer mandatory contribution | Employee mandatory contribution |
|---|---|---|
| Below HK$7,100 | 5% of relevant income | Not required |
| HK$7,100 to HK$30,000 | 5% of relevant income | 5% of relevant income |
| Above HK$30,000 | HK$1,500 | HK$1,500 |
Relevant income is broader than base salary. MPFA includes wages, salary, leave pay, fees, commissions, bonuses, gratuities, perquisites and allowances, so variable pay should be reviewed when payroll calculates MPF.
The MPF timeline founders should put into payroll
MPF compliance is mainly a deadline-management problem. The 60-day enrolment rule, the first contribution timing, the monthly contribution day and the pay-record deadline should all be built into the onboarding and payroll calendar.
Start counting on day one
The 60-day period is counted in calendar days, including holidays. Probation does not pause the clock.
Complete enrolment within 60 days
Except for exempt persons, eligible full-time and part-time employees aged 18 to 64 should be enrolled within the first 60 days.
Calculate employer contributions from day one
Regular employees receive a contribution holiday for their own contributions, but employers still calculate their mandatory contribution from the first day of employment.
Pay by the contribution day
For monthly-paid regular employees, the contribution day is generally the 10th day of the following month. The first payment is generally due after the month in which the 60th day falls.
Issue the pay-record
Provide the employee with the required monthly pay-record within seven working days after making the mandatory contributions.
In 2026, all MPF schemes have been onboarded to the eMPF Platform . Employers and scheme members are required to register with eMPF and manage MPF administration through the platform.
A practical MPF checklist for overseas founders
Use this checklist when you hire your first Hong Kong employee, pay a founder-director, extend an expatriate’s visa or move someone between Hong Kong and an overseas location.
Also remember the post-2025 severance and long-service-payment change. Since 1 May 2025, employers can no longer use benefits derived from employer mandatory MPF contributions to offset the post-transition portion of severance payment or long service payment.
Common MPF mistakes overseas founders make
Build MPF into the same workflow as payroll
For a small overseas-led startup, MPF is easiest to manage when employee onboarding, payroll inputs, contribution calculations and monthly records live in one repeatable process. That reduces the risk of discovering a missed enrolment or contribution only after an employee asks for records.
Captime Bookkeeping & Payroll
Captime can support Hong Kong companies with payroll and MPF administration, including the operational steps around employee setup, contribution calculations and regular payroll records.
See bookkeeping & payroll pricingFrequently asked questions
1. Do overseas founders automatically need MPF for themselves?
No. Overseas status or share ownership alone does not determine MPF coverage. An executive director who is involved in the company’s daily operations and receives remuneration will generally need to be enrolled, unless a statutory exemption applies. A genuinely non-executive director who is not involved in daily operations is generally not required to join.
2. Does a non-resident director of a Hong Kong company need MPF?
It depends on the director’s actual role, remuneration, connection to Hong Kong and whether any MPF exemption applies. An executive director involved in daily operations and receiving remuneration will generally need to be enrolled, while a genuinely non-executive director who is not involved in daily operations is generally outside MPF coverage.
3. Are director’s fees subject to MPF?
Director’s fees can be relevant where an executive director is involved in daily company operations and receives remuneration. Do not assume that calling a payment a director’s fee removes MPF obligations; assess the director’s actual role and employment relationship.
4. Do part-time employees need MPF?
Usually yes. Full-time and part-time regular employees aged 18 to 64 who are employed continuously for 60 days or more are generally covered unless an exemption applies. The number of hours worked each week does not remove the MPF obligation. Different rules apply to casual employees in the construction and catering industries.
5. Does the 60-day rule mean I can wait until probation ends?
No. Probation is included when counting the first 60 calendar days of employment. If the employee is otherwise eligible, the employer should complete enrolment within the statutory 60-day period rather than waiting for probation to finish.
6. Are foreign employees always exempt from MPF?
No. The exemption is specific. A person entering Hong Kong for employment may be exempt if the permitted stay is no more than 13 months or if the person is a member of an overseas retirement scheme. Foreign nationality by itself is not an exemption.
7. How does the 13-month exemption work?
If a work visa permits a stay of 13 months or less, the employee may be exempt. If an extension causes the total permitted stay to exceed 13 months and no other exemption applies, the exemption ends after the first 13 months and the employer must then enrol the employee within 60 days.
8. Does an overseas retirement scheme have to be approved by MPFA?
MPFA says no approval or recognition by MPFA is required for the overseas retirement scheme for this expatriate exemption. Employers should still retain adequate evidence that the employee is genuinely a member of the overseas scheme.
9. Is a dependant-visa holder automatically exempt from MPF?
No. MPFA specifically notes that employees entering Hong Kong on a dependant visa are not covered by the employment-visa exemption merely because they are non-local. If the normal coverage conditions are met, MPF can apply.
10. What about a founder or employee working entirely outside Hong Kong?
A Hong Kong company’s incorporation alone does not settle the issue. MPFA looks at whether the person is employed in or from Hong Kong and whether there is a sufficient connection with Hong Kong. Overseas local hires can fall outside the system, while temporary overseas assignments can remain covered.
11. What is the MPF contribution rate in 2026?
For monthly-paid regular employees, the current rule is generally 5% from the employer and 5% from the employee, subject to the minimum and maximum relevant income levels. As at August 2026, those monthly levels remain HK$7,100 and HK$30,000.
12. What happens if monthly relevant income is below HK$7,100?
The employee is not required to make a mandatory contribution for that month, but the employer must still contribute 5% of the employee’s relevant income. This is a common startup payroll mistake.
13. What happens if monthly relevant income is above HK$30,000?
For a monthly-paid regular employee, both the employer and employee mandatory contributions are currently capped at HK$1,500 each for that month.
14. Are bonuses and commissions included in MPF relevant income?
They can be. MPFA’s definition of relevant income includes items such as wages, salary, leave pay, fees, commissions, bonuses, gratuities, perquisites and allowances. Payroll should therefore assess variable compensation rather than calculate MPF from base salary only.
15. When is the first MPF contribution due for a new employee?
The employer must enrol an eligible regular employee within the first 60 days. Employer contributions are calculated from the first day of employment, and the first remittance is generally due on the contribution day following the calendar month in which the 60th day falls.
16. Do employees get an MPF contribution holiday?
Yes. New regular employees generally receive a contribution holiday for their own mandatory contributions covering the first 30 days of employment and, for wage periods of one month or less, the incomplete wage period immediately following those 30 days. Different timing applies where the wage period is longer than one month. The employer receives no contribution holiday and must calculate its mandatory contributions from the employee’s first day.
17. Is the eMPF Platform mandatory in 2026?
Yes. All MPF schemes were onboarded to the eMPF Platform by 30 April 2026, and MPF scheme administration is now handled through the Platform. Employers, scheme members and self-employed persons must use the eMPF system for MPF administration, although certain instructions can still be submitted to the eMPF Platform through paper channels rather than online.
18. What records should a Hong Kong startup keep for MPF?
Keep accurate payroll, relevant-income, contribution and remittance data. MPFA requires remittance-statement information to be retained for at least seven years, while certain employee and income records have separate minimum retention periods.
19. What are the penalties for late or missing MPF contributions?
Late mandatory contributions can attract a 5% surcharge. MPFA can also impose financial penalties, recover arrears through civil action and prosecute serious cases. Failure to enrol eligible employees can carry a maximum fine of HK$350,000 and three years’ imprisonment.
20. Can Captime help manage MPF for a Hong Kong startup?
Yes. Captime’s Bookkeeping & Payroll services can include payroll administration and MPF e-submission, depending on the selected plan. Captime can help founder teams maintain a repeatable process for payroll, MPF contributions, records and monthly deadlines.
Sources
Official Hong Kong government sources:
- Mandatory Provident Fund Schemes Ordinance (Cap. 485) Hong Kong e-Legislation.
- Immigration Ordinance (Cap. 115) Hong Kong e-Legislation; relevant to the employment-visa exemption described by MPFA.
- Mandatory Provident Fund Schemes (General) Regulation (Cap. 485A) Hong Kong e-Legislation.
- Abolition of MPF Offsetting Arrangement Labour Department guidance effective from 1 May 2025.
Keep payroll and MPF on schedule
Set up a repeatable Hong Kong payroll process that covers employee onboarding, MPF calculations, contribution records and monthly deadlines.
