FAQs

FIRST is the first job-creation scheme dedicated to the financial industry, commissioned by the Financial Services and the Treasury Bureau and administered by Financial Services Development Council ("FSDC") under the HKSAR Government’s HK$6 billion Anti-epidemic Fund, with the aim of creating 1,500 full-time jobs in the financial services sector.

FIRST allows eligible employers to apply for a subsidy to make eligible new hires  ("New Hire(s)") in the financial services sector. The subsidy is up to HK$10,000 or actual basic salary, whichever is lower, per month per New Hire for 12 months.

Applicant employers must spend all the subsidies under FIRST on paying salaries to New Hires and they cannot use the subsidies for other purposes, including non-cash benefits for employees or donations.

An entity or a firm regulated by prescribed statutory bodies are eligible for FIRST, including: 

• licensed banks, restricted licence banks, deposit-taking companies, and stored value facility ("SVF") licensees authorised by the Hong Kong Monetary Authority; or
• firms with non-temporary non-provisional licence and carrying out any of Type 1 to Type 10 regulated activities under the Securities and Futures Ordinance licensed by the Securities and Futures Commission; or
• insurers and insurance intermediaries (including insurance agencies and insurance broker companies; not including individuals) authorised by the Insurance Authority; or
• trustees approved by the Mandatory Provident Fund Schemes Authority; or
• Certified Public Accountants firms and corporate practices registered with the Hong Kong Institute of Certified Public Accountants.

A financial group may employ, pay salary and provide Mandatory Provident Fund ("MPF") contributions and/or Occupational Retirement Schemes Ordinance (“ORSO") benefits to its employees through a group entity not regulated by any of the five prescribed statutory bodies for managing human resource centrally (the “Payroll Company”). In case of the above, for the application of FIRST, the regulated entity or firm may use its number of employees hired by this group entity.

Entities or firms regulated by prescribed statutory bodies as set out in FAQ 3 are eligible to apply for FIRST.

FIRST is administered by FSDC, with support from the Government, to help create jobs in the financial services industry for the purposes of nurturing the talent pool. FIRST and ESS are independent schemes – having applied for the ESS would not affect the eligibility for FIRST.

In principle, a company may apply for more than one job-creation or job support schemes financed by public funds on the basis that the subsidy does not apply to the same position created. With that in mind, by applying for FIRST, the applicant employer undertakes not apply to more than one job-creation or job support scheme financed by public funds for the same New Hire during the same period. It may apply different schemes for different New Hires or for different periods.

An applicant employer may apply for subsidy for 1 to 25 New Hires. The number, if above 1, will be capped at 5% of the applicant employer’s existing number of employees and such will be rounded off to the nearest whole number, except for when the number of employees is below 30, of which the eligible headcount will be one.

To illustrate: an eligible employer with fewer than 30 employees may apply for up to 1 New Hire; an eligible employer with 30 may apply for up to 2 New Hires (30 x 5% = 1.5 = rounded off to 2); an eligible employer with 49 employees may apply for up to 2 New Hires (45 x 5% = 2.45 = rounded off to 2); and an eligible employer with 500 employees or more may apply for up to 25 New Hires.

In each application, the applicant employer does not necessarily apply for the maximum number of new hires it is entitled to. Instead, it should choose how many to apply for on the basis that such arrangement would most suit its human resource situation and needs.

An applicant employer which has more than one authorisation, licence, and/or registration, whether with one or more statutory bodies, is nonetheless considered a single applicant employer.

Each licensed subsidiary within a group is considered a separate applicant employer and can submit an independent application on the basis that it is an entity or a firm regulated by the prescribed statutory bodies listed in FAQ 3.

FIRST covers entities or firms carrying out activities regulated by the prescribed statutory bodies as set out in FAQ 3. In the case that a company does not fall under any of the categories, it should not be eligible for FIRST but may keep abreast of the announcements of other measures published by the HKSAR Government.

Applicant employers can apply for the subsidy irrespective of their profitability/earnings record, as long as they meet all the application criteria.

Regardless of any wage adjustments of the approved New Hire, the subsidy will be up to HK$10,000 or actual monthly basic salary, whichever is lower, per month per New Hire for 12 months.

If it comes to the attention of FSDC that an applicant employer is undergoing liquidation/ winding up/ deregistration/ striking-off, FSDC reserves all the rights to reject the application submitted and refuse the disbursement of the subsidies.

A New Hire must represent a net increase in the applicant employer’s number of employees during the subsidy period (applicant employer should select either 30 June 2020, 31 July 2020 or 31 August 2020 as the selected reference date to indicate the number of existing employees employed with the net increase number of employees regarded as “New Hire”).

Employees under FIRST are defined as those for whom the applicant employer has set up MPF or ORSO scheme accounts and to whose accounts the applicant employer is providing MPF contributions or ORSO benefits for him/her.

Approved employers are expected to monitor its monthly number of employees and the amount of their subsidies received will be affected if a “net increase” cannot be achieved.

To illustrate: if an approved employer had 100 employees as of 31 August 2020, it can apply for 5 New Hires. Suppose it has successfully applied for and made the 5 New Hires, but a few months later 2 employees leave, such that its total number of employees is 103. Thereafter the approved employer may receive subsidy for only 103 - 100 = 3 approved New Hires, even if all 5 New Hires are still under the employment of the approved employer.

The candidate applying for jobs created under FIRST must be aged 18 or above and permanent residents of Hong Kong, i.e., holding Hong Kong Permanent Identity Cards, at the time of commencement of the employment.

The following candidate will not be eligible if:

• he/she is the spouse, a child, a parent or a sibling of a proprietor, a director or a partner of the applicant employer; and/or
• he/she has been employed by the applicant employer or any of its group entities within the 12 months preceding the new employment (except for a candidate who is employed upon completion of an internship programme (e.g. HKMA Banking Talent Programme)).

To facilitate applicant employers in making New Hires whom most suit their human resource needs, FIRST does not specify any terms for the roles and positions. That stated, an applicant employer will have to state and undertake that –

• it will require each New Hire to work for at least 30 hours per week;
• it intends the position to last for at least 12 months; and
• it intends to employ the person for at least 12 months.

At the same time, roles and positions displacing an existing employee, or fully commission-based, subcontracted or self-employment positions will not be eligible for FIRST.

In case a New Hire’s employment ceases before 12 months, such that a part of the subsidy available for 12 months remains, the approved employer may reapply once within 3 months for the remaining part to provide for another New Hire. Such approved employer may not itself transfer or treat the subsidy as providing for any other New Hire or other purposes.

No penalty will be imposed on the approved employer if the approved New Hire leaves the company during the subsidy period. However, the approved employer will need to provide documentation to confirm the termination/departure of that New Hire and will be allowed to find a replacement for that position within 3 months.

The New Hires must be aged 18 or above and Hong Kong permanent residents, i.e., holding Hong Kong Permanent Identity Cards, at the time of commencement of the employment.

New Hires who meet the eligibility criteria in FAQs 16 & 17 will be eligible for FIRST application.

New Hires who meet the eligibility criteria in FAQs 16 & 17 will be eligible for FIRST application.

This employee should only be counted as one headcount of the applicant employer.

For the purpose of FIRST, a full-time employment is defined as an employment, with at least 30 hours of service per week as indicated or inferred in the employment contract. However, employers of which request the New Hire to take no-pay leaves which result in the aggregated working hours less than 30 in any weeks during the 12-month subsidy period will be regarded as a violation of the eligibility requirement. If a new hire is asked to take no-pay leave but the working hours of a week is more than 30 hours of service in a specific month, his/her salary is subject to the subsidy, but such subsidy amount might be affected and adjusted to the actual salary paid or HK$10,000, whichever is lower.

Applicant employers shall fill in and submit the required information on the FIRST application portal together with relevant supplementary documents.

FIRST is open for application from 9:00am (Hong Kong time) 30 September 2020. 

The FSDC sets a quota of 1,500 New Hires for applicant employers applying under FIRST. Completed applications lodged in the first 3 weeks of the application period (by 20 October 2020) will be processed in one batch. 

After the first 3 weeks of the application period, FSDC will continue to receive applications through the FIRST application portal if the 1,500 quota has not been exhausted. Any unused quota will be processed on a first-come, first-served basis.

Application period will close when the 1,500 quota exhausts, or 11:59pm (Hong Kong time) 31 March 2021, whichever is earlier.

That stated, applicant employers should choose when to apply as it most suits their human resource situation and needs. Applications may be made –

(i)   for intended New Hires before the hiring is done; or
(ii)  for New Hires made but employment yet to commence; or
(iii) for New Hires made and employment already commenced.

The application will not involve any interviews. The application is to be completed via the FIRST application portal. However, where the information submitted involves ambiguity, FSDC may contact the applicant employer for clarification. Towards the end of FIRST, approved employers are encouraged to fill in an evaluation form to reflect the impact of FIRST.

In making an application, the applicant employer should submit:

a) information about company, including:

• its business registration certificate number;
• its authorisation/ license/ registration certificate number; 
• a copy of the valid documents aforesaid; and
• its latest bank statement (within 3 months);

b) existing headcount number of the applicant employer, including:

• total number of employees shown in MPF Remittance Statement and/or ORSO records  for the month of applicant employer's selected reference date with the supporting documents;
• total number of contract staff with original contract period less than one year and part-time staff;
• total number of terminated employees in the month of applicant employer's selected reference date;
• total number of staff hired but yet to contribute MPF in the month of applicant employer's selected reference date; and
• any other adjustments to the existing headcount number of the applicant employer;

and

c) details of the positions for which the applicant employer intends to make or has made.

Applicant employer who pays salary and provides MPF contributions and/or ORSO benefits to its employees through another group entity not regulated by any of the prescribed statutory bodies (see FAQ 3) is required to submit the following additional information:

• number of employees hired by the group entity not regulated by any of the prescribed statutory bodies, which perform services for the applicant employer; and 
• supplementary documents showing the relationship with the Payroll Company (e.g. the latest group chart certified by the applicant employer, etc.).

After the application has been submitted, the applicant employer will normally be notified of the result within 4 to 6 weeks. 

If by the time of approval the New Hires have yet to be made or to commence employment, the applicant employer shall make the New Hires and have each New Hire commence employment within 3 months.

After the New Hire commences employment, applicant employers are required to submit information about the New Hires (including each of the New Hire¡¦s name, Hong Kong Permanent Identity Card number, employment commencement date, basic monthly salary, a copy of his/her Hong Kong Permanent Identity Card, a copy of his/her employment contract, and a declaration made by the New Hire). 

When the application is being possessed, the applicant employer may be contacted via email by FSDC for clarification/confirmation in case of information ambiguity.

Once the application result is available, the applicant employer will be notified of the result via SMS and email. Applicant employers might check their spam/junk mail folder to identify any email from FSDC.

Applicant employers can also log in to the FIRST application portal with their application reference and password to view the submitted information and latest application status. The FIRST application portal is best viewed with the latest version of web browsers.

As long as the 1,500 subsidised new hires under FIRST have not been exhausted after the first batch of beneficiaries, you may submit additional application(s) after the first batch closes on 20 October 2020 to apply for your remaining quota of New Hires. During the first 3 weeks of the application period, each applicant employer can only submit one application. Applications submitted after 20 October 2020 will be processed on a first-come, first-served basis.

There are some points to note when submitting an additional application for FIRST: 

• You are required to complete the applicant employer registration again and upload the latest valid supporting documents, such as bank statement in the last 3 months and valid business registration certificate;
• The selected reference date must be the same as that of your first application; and
• You can only apply for the remaining quota such that the aggregate number of New Hires you have applied for does not exceed the maximum number of New Hires allowed.

The approved New Hire will be revoked.

By making an application via the FIRST application portal, the applicant employer undertakes the following (including but not limited to):

• the applicant employer will monitor and reconcile its monthly actual number of employees with the relevant supporting records and report to FSDC in subsequent period when the new hire(s) in fact no longer represents a net increase in the applicant’s number of employees from the base number of the employees as of the selected reference date;
• the applicant employer will comply promptly with all reasonable requests for information from time to time raised by FSDC; 
• the applicant employer will use the entire subsidy amounts received from FIRST for the basic fixed salary payment (excluding commission, bonus or any kind of variable pay, and must not be subject to net-off with commission, bonus or any kind of variable pay or to any contractual clawback) to new hire(s) registered under FIRST for each full month of employment, up to 12 months;
• the applicant employer has not applied to and will not apply to more than one job-creation or job support scheme financed by public funds for the same new hire(s) for the same period; and
• the applicant employer acknowledges that in the case of any non-compliance with, violation and/or breach of the conditions of FIRST and/or of the Declaration and Undertakings by the applicant employer, FSDC reserves the right to notify the relevant regulatory bodies.

For the full version of Declaration and Undertakings, please refer to the Important Notes and Applicant Employer's Declaration and Undertakings in the FIRST application portal.

After the New Hire under FIRST commences employment, he/she is required to make a declaration through a declaration form downloadable in the FIRST application portal. He/she should declare that:

• to the best of his/her understanding, he/she has no other employment and that he/she has not been employed by the applicant employer or any affiliate of the that applicant employer within the past 12 months preceding the current employment with that applicant employer;
• he/she is not the spouse, a child, a parent or a sibling of a proprietor, a director or a partner of the applicant employer; and 
• he/she acknowledges and agrees with the provisions concerning personal data belonging to him/her from time to time provided to FSDC.

The subsidy for each New Hire will be HK$10,000 per month or the New Hire’s actual monthly basic salary, whichever is lower, for 12 months. Basic salary must be fixed, exclude commission, bonus or any kind of variable pay, and must not be subject to net-off with commission, bonus or any kind of variable pay or to any contractual clawback.

The subsidy will be for each full month of actual employment, up to 12 months.

Approved employers are required to submit reimbursement supporting documents within 15 calendar daysafter each quarter end from December 2020 to December 2022.

The subsidy disbursement process normally takes around 6 to 8 weeks after each quarter end once the approved New Hires commence employment.

The approved employer is required to make MPF/ORSO contributions for New Hires under FIRST in accordance with the existing MPF Ordinance/ORSO Ordinance.

To ensure the public funds are utilised in an appropriate manner whilst avoiding unnecessary or practically ineffective steps in the administrative process, approved employers will need to make simple periodic filings and/or confirmations, such as MPF Remittance Statement and/or ORSO records and proof of salary payment to the New Hire.

When applying for the government subsidies under FIRST, applicant employers should also make sure their undertakings can be relied upon and a breach thereof will have consequences.

The HKSAR Government plans to exempt approved employers from taxation of subsidy under FIRST. That said, wages earned by the New Hire are treated as income chargeable to salaries tax under the Inland Revenue Ordinance.

FIRST is designed with an objective to generate a net increase in employment in the financial services sector and the Government subsidy should be spent on achieving such particular purpose. Therefore, as it is defined, employers applying for the subsidy are required to maintain the number of staff at a level above that of the selected reference date. 

References are set out in FAQs 14 and 15.

Applicant employers must provide true, complete and accurate information when making the applications, otherwise, the relevant applications may be rendered invalid, rejected and/or disqualified. Appropriate monitoring and auditing mechanisms are in place under FIRST. During and after the vetting of applications, FSDC will verify the information submitted by the applicant employers. Any applicant employer who is found to have made a false statement, misinterpreted or concealed the facts, or furnished false or misleading documents or information to FSDC in an attempt to deceive FSDC is a criminal offence, and could be subject to criminal prosecution.

Applicants may seek assistance via the following channels:

Hotline: (852) 36129951 (9am to 6pm, Monday to Friday, except public holidays)

Email: first@fsdc.org.hk

Employees and the public can report any illegal or suspicious activities via channels in FAQ 41.

In case of any non-compliance with/ violation of the conditions of FIRST or breach of the undertakings and declaration by the applicant employer, FSDC reserves the right to notify the relevant regulatory bodies.