Short answer: if your tutorial centre teaches 20 or more people on any one day, or 8 or more people at any one time, it counts as a "school" under Hong Kong law. You must register it with the Education Bureau and receive a provisional registration certificate before classes start.
| Item | Requirement | Department |
|---|---|---|
| Registration | School registration (a tutorial centre is a "private school offering non-formal curriculum", 非正規課程私立學校) | Education Bureau (EDB) |
| Location | Confirm the premises may be used as a school: Form P (planning) and Form L (lease). School premises are generally not allowed more than 24 metres above ground | Planning Department, Lands Department |
| Fire safety | Fire certificate; specified fire service installations; automatic sprinklers if the area exceeds 230 m² | Fire Services Department (FSD) |
| Building safety | Safety certificate or notification; exits, door swing and corridor widths must comply | Buildings Department (BD) / Independent Checking Unit |
| Health | Hygiene requirements and the maximum number of students per classroom | Department of Health |
| Time | Departments usually issue their requirements within 20–22 working days; re-inspection 14–22 working days after the works are done; EDB considers provisional registration about 10 working days after receiving all documents |
Which tutorial centres must register?
Under the Education Ordinance (Cap. 279), a "school" is any institution that provides education or any other course to 20 or more people on any one day, or to 8 or more people at any one time. This includes tutorial, language, computer and commercial courses. Tutorial centres fall under "private schools offering non-formal curriculum" and must register with the EDB.
Operating an unregistered school is an offence, with a maximum penalty of a HK$250,000 fine and two years' imprisonment. The Permanent Secretary for Education may also order the premises to be closed.
Tutorial centres are exempted from some rules, such as parts of the fee and staffing procedures, under the Education (Exemption) (Private Schools Offering Non-formal Curriculum) Order, as long as they meet its conditions. The exemption does not cover premises, fire safety or building safety.
Four checks before you sign a lease
- Planning use: submit Form P to the Secretariat of the Town Planning Board to ask whether the premises may be used as a school. With complete information, the Secretariat can reply within 10 days. If planning permission is needed, the application goes to the Town Planning Board within two months of receipt.
- Lease and deed of mutual covenant: obtain the land records from the Land Registry and submit them with Form L to the District Lands Office, which checks whether the use breaches the government lease. A lease modification or temporary waiver may be needed. The building's deed of mutual covenant (公契) may also restrict the use, so check it before signing.
- Floor level and staircases: under EDB guidelines, no part of the school premises should generally be more than 24 metres above ground, though this may be relaxed if specified requirements are met. In buildings not designed as schools, floors more than 30 metres above ground are generally not accepted; each case is considered individually. Upper floors of buildings with only one staircase are generally not accepted.
- The building itself: cocklofts, partitions, shared corridors or fire doors that are unauthorised building works, or have been altered, will hold up approval. Premises previously registered as a school are re-assessed against current standards. You can check the building for statutory orders with our Building Orders Search (in Chinese).
The registration process
- Planning Department: submit Form P.
- Lands Department: submit Form L with the land records.
- Fire Services Department: submit Form A1 with 3 copies of the layout plans to apply for a fire certificate. This can be done online through GovHK or iAM Smart.
- Buildings Department (or the Housing Bureau's Independent Checking Unit): submit Form A2 with 4 copies of the plans to apply for a safety certificate and notification. From January 2026 you may appoint an Authorized Person or Registered Structural Engineer to self-certify some requirements and speed this up, though not every requirement qualifies.
- Education Bureau: submit the registration application (Form 1), the supervisor registration (Form 6) and supporting documents.
- Complete the works: carry out the FSD and BD requirements, ask for a re-inspection in writing, and send the certificates to the EDB, together with 5 copies of the approved plans. The Department of Health then sets hygiene requirements and classroom capacities.
- Meet the EDB requirements: school name, courses, fees and registration of the school managers.
- Start classes: only after receiving the provisional registration certificate. It is generally valid for one year. If all requirements are not met within that time, the school becomes unregistered when it expires.
Key design requirements
- Floor area: at least 0.9 m² per student, plus a 1.5-metre-wide teacher's zone along one wall. For example, a 4.5 m × 5 m classroom can take 25 students and 1 teacher.
- Exits: rooms for more than 30 people need doors that open outwards. Where two exits are needed, the angle between them from any point in the room must be at least 30 degrees. Every classroom exit needs an illuminated "EXIT 出口" sign.
- Fire service installations: portable fire extinguishers, manual fire alarm, emergency lighting, exit and directional signs, and automatic fire detection; automatic sprinklers if the area exceeds 230 m². The work must be done by a registered fire service installation contractor of the right class, who issues an FS 251 certificate when finished.
- Fire separation: the school must be separated from neighbouring premises by fire-resisting construction. Glass doors and walls must meet fire-resistance requirements, which can be expensive. Curtains must be fire-retardant.
- Toilets: for boys, one WC, two urinals and one wash basin per 30 (or one WC per 20 if there are no urinals); for girls, one WC per 20 and one wash basin per 25.
- Corridors: the EDB's FAQ (June 2026) states that where the school's total number of persons is 4 to 500 and a corridor forms part of an exit route, the corridor should be at least 1,050 mm wide; wider for more people.
Common minor works in the fit-out
Besides ordinary interior works, a tutorial centre fit-out often includes works controlled under the Buildings Ordinance as minor works (小型工程). The item pages below are in Chinese:
- Wall signboards: item 3.17 (5 m² or less), 2.19
- Projecting signboards: 3.16, 2.18
- Air-conditioner supports on external walls: 3.27, 2.49
- External drain pipes for new toilets: 3.23, 2.30
- Fire dampers in ventilation systems: 2.42
Removing structural walls, larger floor openings or changes to escape routes may go beyond minor works and need plans submitted to the BD by an Authorized Person. See our minor works service.
Rules after opening
- Fees must be collected in equal monthly instalments, the first no earlier than one month before the course starts. Receipts must show the school name, student name, course, venue, date and amount, with the school chop and the supervisor's signature.
- Before enrolment, give students a leaflet showing fees, course length, class times, venue, principal and teacher details, and the refund policy.
- Display the fees in a prominent place, and display each classroom's maximum number of students.
- Teachers must be registered or permitted teachers and meet the minimum qualifications in the exemption order. The supervisor must report each teacher to the EDB within one month of starting. The supervisor must appoint a teacher as principal and notify the EDB within one month.
- Classes may only be held at the address on the registration certificate.
You can also use the Trade and Industry Department's Business Licence Information Service to look up government licences, permits and approvals relevant to your business.
Common questions
I only teach a few students privately. Do I need to register?
If you teach fewer than 20 people a day and fewer than 8 at any one time, it is not a school under the Education Ordinance and does not need registration. Once you reach 20 people on any one day, or 8 people at any one time, it is a school and you must register with the EDB.
Can I open a tutorial centre in a residential flat?
First check the government lease, the planning use and the deed of mutual covenant for restrictions. Changing a flat to a school is a change of use and must also meet fire and building safety requirements and be approved by the departments.
How long does registration take?
According to the EDB, departments usually issue their requirements within 20–22 working days of receiving the application. After the works are done, the BD and FSD take 14–22 working days to re-inspect and issue certificates, and the EDB considers provisional registration about 10 working days after receiving all documents. Allow several months including the fit-out.
The shop used to be a tutorial centre. Can I just take it over?
A new school must apply for registration itself. Even if the premises were registered before, the BD and the Independent Checking Unit re-assess them against current building safety standards, so registration is not guaranteed.