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Chapter 04 · FAQ

BHU Certification:
30+ Questions Landlords Ask Most

Published 2026.04.29 · Last updated 2026.07.13

These questions come from landlord consultations we have conducted over the past 8 years, grouped by what landlords actually need to know at each stage: eligibility, registration and certification process, costs, renovation works, cross-border handling, and post-certification management and tenant relations. If your question is not listed here, ask us directly on WhatsApp.

Summary: This FAQ covers 30+ common BHU certification questions spanning eligibility, registration process, costs (all-inclusive service HKD 120,000–300,000), renovation works, and cross-border handling.

Ordinance Scope & Eligibility

Is my subdivided flat (劏房) a BHU?

Not necessarily. "Subdivided flat" (colloquially known in Cantonese as 劏房) is the everyday term for any residential unit partitioned for separate rental. "Basic Housing Unit" (BHU, 簡樸房) is the formal legal category under the Basic Housing Units Ordinance — a unit only earns this status after passing an on-site inspection by a specified professional and receiving Housing Bureau recognition. If your unit is simply subdivided and rented out but has not been certified, it remains legally a "subdivided unit" (劏房), not a BHU. See Subdivided Flat (劏房) vs BHU (簡樸房): What Changed After 2026.

Does my unit definitely need BHU certification?

If your unit has been subdivided into 2 or more independent units for rental purposes, and the property is a private residential building or the residential portion of a mixed-use building, certification is generally required. If the entire unit is rented as a single tenancy, or the property is a commercial or industrial building, certification is not required.

Do public housing (PRH) or Home Ownership Scheme (HOS) landlords need to comply?

PRH and HOS properties are governed by separate regulations and fall outside the scope of this Ordinance. However, subletting of PRH and HOS units is itself prohibited — that is a separate compliance issue.

If the unit is vacant and not rented out, is certification required?

No. The Ordinance only applies to subdivided flats used for rental purposes. However, if you plan to rent the unit in future, it is advisable to obtain certification at the appropriate time.

Are commercial/industrial buildings, bedspace lodging houses, or transitional housing covered by this Ordinance?

No. The Ordinance expressly exempts bedspace lodging houses (Cap. 447), transitional housing, Light Public Housing, hotels and guesthouses, elderly homes, residential care homes for persons with disabilities, and child care centres, among other categories listed in Schedule 4 Part 2. Commercial and industrial buildings are not "domestic buildings" and fall outside the Ordinance entirely.

How do I know if my unit legally qualifies as a "subdivided flat"?

Section 4 of the Ordinance sets two core conditions: (1) the flat has been subdivided or re-subdivided in a way not shown on the referenced building plans; and (2) after subdivision, there are 2 or more compartments, at least 2 of which are designed as separate residential tenancy subjects. Meeting only one condition may not constitute a subdivided flat — have an Authorized Person confirm on-site.

Do rooftop structures or illegal structures need certification?

No, and they cannot apply. The Ordinance expressly excludes compartments formed on a rooftop, platform, garden, or yard through works that breach the Buildings Ordinance (Cap. 123) — these are not subdivided flats and fall outside this Ordinance's scope. However, such structures may still face demolition action from the Buildings Department, which is a separate compliance issue.

Registration & Certification Process

How long does the entire process take?

Standard cases take 14–18 weeks (Owl Square case data, 2018–2026). Complex cases (structural issues, incomplete old building plans, extensive renovation required) may extend to 24 weeks or more.

What's the difference between grace-period registration and BHU certification?

They are different legal procedures. Grace-period registration is only temporary legal protection (HKD 0, must apply before 28 February 2027), allowing an existing subdivided flat to keep being lawfully let during the grace period. BHU certification is the substantive, formal certification requiring completed renovation and sign-off by an Authorized Person. See Grace Period vs Immediate Compliance.

If I missed the 28 February 2027 grace-period registration deadline, can I still register?

The standard registration period is 12 months (1 March 2026 to 28 February 2027), free of charge. If the registration period is subsequently extended, Schedule 2 provides that applications made on or after 1 March 2027 incur a fee of HKD 745 per flat — no longer free. In practice, this should not be treated as a reason to delay: the actual arrangements after missing the original deadline will depend on what the Housing Bureau announces at the time. Registering early remains the safest course of action.

How long is BHU certification valid?

60 months (i.e. 5 years) from the date of certification. Owners should start preparing renewal documentation and arrange an Authorized Person review well before expiry; the specific renewal application window will follow Housing Bureau arrangements.

Can I renovate the unit freely after certification?

Structural alterations or changes that affect compliance items (fire compartmentation, ventilation, independent utility metering) are not permitted. General furniture replacements and repainting do not affect certification.

Can multiple units be certified together?

Yes. Multiple units under the same landlord in the same building can be submitted together, which reduces some documentation costs.

What if my unit fails the first assessment?

It doesn't mean certification is out of reach — it's usually a correctable gap (e.g. insufficient ventilation, wrong fire-door rating). The Authorized Person will list the items that need to be addressed, and the unit can be reassessed once the corresponding renovation is complete. Common rejection reasons are covered in 5 Reasons BHU Applications Fail.

What is an Authorized Person (AP)? Do I need to hire both an architect and a structural engineer?

No. The Ordinance's "specified professional" category covers three types: a registered architect, a registered professional engineer (in the building, building services, civil, fire, or structural disciplines), or a registered professional surveyor (building surveying division) — any one of these can independently carry out the certification work. For units with complex structural issues, the AP may recommend engaging a structural engineer for an additional review, but that is a case-by-case need, not a statutory requirement. See The Role of the Authorized Person in BHU Certification.

Costs & Fees

How much does the whole process cost?

It depends heavily on the unit's condition. For a unit with 4 subdivided rooms, the total cost of an all-inclusive service (assessment + renovation + certification + management) is typically HKD 120,000–300,000 (2026 market rate). A specific quote will be provided after an on-site assessment — see the full breakdown in BHU Certification Costs Explained.

Is instalment payment available?

Yes. We offer staged payments: 30% upon signing / 40% upon completion of renovation / 30% upon receipt of certification.

Are there any government subsidies?

There is currently no dedicated government subsidy scheme. However, the cost of compliance renovation is a capital expenditure and can be factored into the cost basis when the property is sold.

Is the HKD 3,000 assessment fee mandatory?

Yes. An inspection by an Authorized Person (AP) is a professional service that requires payment (2026 market rate). However, upon signing the full service agreement, this fee is fully credited against the total — so there is no additional cost.

How much does renewal cost? Is it the same as the initial certification fee?

No, renewal is cheaper than initial certification. Under Schedule 2, the renewal application fee is HKD 2,400 per BHU. As for the initial certification fee, HKD 3,000 is the standard rate that applies only to landlords who did not register within the grace period — landlords who registered on time can pay as little as $0 or $1,500, depending on the combination of registration and application timing (see the full fee structure). Renovation costs at renewal time depend on whether the unit still meets the standard — a well-maintained unit typically won't need further renovation.

Renovation Works

Do existing tenants need to move out during renovation works?

It depends on the scale of works. Localised works such as fire-door installation or mechanical ventilation can usually be done in stages while tenants remain in residence; renovations requiring an added bathroom or structural changes may require tenants to temporarily vacate for a few days to two weeks (Owl Square case data, 2018–2026). See detailed costs and process in Hong Kong Subdivided Flat Renovation Cost.

My building's Owners' Corporation (OC) deed of mutual covenant prohibits alterations — what can I do?

Deed restrictions on alterations and the BHU Ordinance are two separate regimes: OC objection does not exempt an owner's statutory certification obligation, but it also doesn't mean the deed can be ignored. Owners generally have three paths: negotiate a waiver with the OC, apply to amend the deed, or choose a renovation approach that falls outside the deed's restricted scope. See BHU Certification & Owners' Corporation / Deed of Mutual Covenant.

My property is mortgaged — does renovation work require bank consent?

It depends on the nature of the works. Small works such as replacing fire doors or installing independent utility meters generally do not trigger the "no alterations without consent" covenant in a mortgage deed; structural changes may require consent. The certification application itself (registration, certification) is unaffected by mortgage status, and an owner's statutory obligations are not reduced because the property is mortgaged. See BHU Certification for Mortgaged Properties.

Cross-Border Landlords

I'm based in Mainland China / overseas long-term. Can I handle this remotely?

Yes. We provide a full cross-border proxy service. You only need to sign a power of attorney (which can be notarised locally), and we handle all remaining documentation on your behalf.

Where should the power of attorney be notarised?

Mainland landlords: at a local notary office. Overseas landlords: at a local solicitor or at the Hong Kong Consulate General in your country. We provide a template and translation service.

Does the original BHU certificate need to be mailed to me?

We recommend that we hold the original in safekeeping (in a solicitor's secure vault). You will receive a high-resolution scan. The original can be dispatched to you at any time upon request.

Do the same deadlines apply to cross-border landlords?

Yes. The Ordinance applies equally to all landlords regardless of where they are based — the grace-period registration deadline (28 February 2027) and certification requirements apply the same way. Our cross-border proxy service exists specifically to bridge the gap between "being based overseas" and "deadlines that sit in Hong Kong."

Post-Certification Management & Tenant Relations

Can I manage the rental myself after certification?

Absolutely. Post-certification management is an optional add-on service. You may self-manage, but you will need to ensure the unit remains compliant throughout the 60-month certification period (e.g. fire equipment inspections at least once every 12 months).

What happens if a tenant defaults on rent?

If you have engaged us to manage the property, we handle all rent recovery. Our arrears rate over 8 years of operations has been below 2%, which is primarily achieved through rigorous tenant vetting.

Do I still pay management fees when the unit is vacant?

During vacancy, only a "compliance maintenance fee" applies, which is significantly lower than the regular monthly management fee. The full management fee only begins once the unit is tenanted.

I'm a master tenant who sublets — is my compliance responsibility different from the property owner's?

Both can be held criminally liable under the Ordinance. Section 8(2) names three categories of liable persons: the person who lets the subdivided flat directly (typically the master tenant), the person who lets the entire principal flat under a superior tenancy (the owner), and any other person entitled to receive the rent from time to time. In other words, a master tenant cannot claim exemption on the grounds of "I'm not the owner" — the registration and certification application must be made by the owner of the principal flat, but the master tenant remains equally exposed to penalties.

Can I sell the unit after certification? Does the compliance obligation transfer to the new owner?

Yes, you can sell. Certification attaches to the subdivided flat itself, not to the individual owner, so it remains valid after a change of ownership (until it expires). However, the responsibility for renewal and for maintaining compliance transfers to the new owner along with the property. It is advisable to clearly state the certification status and handover documents in the sale and purchase agreement.

What does the "no new tenancies after 1 September 2029" rule mean?

From 1 September 2029, a subdivided flat without valid BHU certification may not be let under a new residential tenancy. Existing tenancies are unaffected and may run to their natural expiry, but once a tenancy expires it cannot be renewed or replaced with a new one — with the same or a different tenant — until certification is obtained. This takes effect six months before the full enforcement date of 1 March 2030, so landlords should factor it into their tenancy renewal planning.

Further Reading
Technical Standard

BHU Minimum Floor Area & Ceiling Height: Exact Calculation Method with Examples

Internal floor area must be at least 8 sq m (bathroom included) and ceiling height at least 2.3m (measured at lowest point). Includes calculation methods and solutions for non-compliant units.

Cost Analysis

BHU Certification Fee Breakdown: HKIS Benchmarks, BD Charges & Real Market Costs

A complete breakdown of BHU compliance costs, including HKIS market benchmarks and hidden costs landlords often overlook.

Landlord Guide

Grace Period vs Immediate Compliance: Which Should You Choose?

BHU landlords face two compliance approaches. This guide analyses the real costs, risks and conditions of each option to help you decide.

Still Have Questions?

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