Does a Hong Kong company with no business or no revenue still need an audit?

Zero revenue does not remove the audit requirement. The Companies Ordinance requires an auditor for every financial year (s.394), and the only audit exemption is for a company that is dormant under s.5.

Why "no business" is not enough A company is dormant for audit purposes only if its members pass a special resolution declaring dormancy and the resolution is delivered to the Registrar. In addition, a company stops being dormant when it enters an "accounting transaction", meaning a transaction that must be recorded in its accounting records (paying a fee that the law requires the company to pay does not count). Ordinary running costs such as accounting fees, rent or bank charges are recorded transactions.

Practical effect

• A trading company with a quiet year: audited as normal, usually a simpler and quicker audit.
• An inactive company that never made the dormancy filing: still audited.
• A company that has genuinely done nothing and files for dormancy first: exempt from audit while dormant, but members and directors carry personal liability if it later transacts (see the answers on making a company dormant and on what ends dormancy).

Tax side IRD's circular asks for audited statements with the profits tax return in all cases with gross income, except dormant companies. A company with no gross income is therefore treated differently at the tax return stage, but this does not change the Companies Ordinance duty.