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  • The Insider’s Tips – Understanding the Local Recruitment Exercise Requirement for GEP & ASMTP Applications

The Insider’s Tips – Understanding the Local Recruitment Exercise Requirement for GEP & ASMTP Applications


In recent years, Hong Kong’s immigration landscape has undergone a significant transformation, particularly in the realm of employment visa applications. With increasing scrutiny from both internal government bodies and external stakeholders, the Hong Kong Immigration Department has tightened its protocols to ensure that local talent is prioritised wherever possible. This shift reflects broader socio-economic changes, including rising local unemployment concerns, evolving labour market dynamics, and a growing emphasis on transparency and fairness in hiring practices.



One of the most critical components of this evolving framework is the Local Recruitment Exercise (LRE)—a process designed to verify that a job position genuinely requires an expatriate hire and cannot be filled by a local candidate. For employers seeking to hire under the General Employment Policy (GEP) or the Admission Scheme for Mainland Talents and Professionals (ASMTP), understanding and properly executing the LRE is no longer optional—it’s essential.


What Is the Local Recruitment Exercise (LRE)?

The LRE is a formal process that demonstrates an employer’s effort to recruit locally before seeking overseas talent. The Immigration Department has long maintained that positions intended for expatriates must not be readily fillable by local candidates. While this principle has remained consistent, the standards for acceptable proof have evolved significantly.



While the definition of an acceptable LRE is not included in the Immigration Department’s guidelines, the key components normally include the following as per our experience with the Department:

  • Job Advertisement: The employer is expected to post a job ad targeting local candidates, ideally through reputable platforms such as JobsDB, CTgoodjobs, or the Labour Department’s Interactive Employment Service.
  • Application Collection: Employers must gather and retain all applications received during the recruitment period.
  • Candidate Interviews: Shortlisted applicants should be interviewed, and interview records must be documented.
  • Outcome Documentation: If no suitable local candidate is found, the employer must compile a report detailing the recruitment process, including reasons for rejection and evidence of genuine effort.
This documentation serves as supporting evidence in the visa application process, helping to justify the need for an overseas hire.


Historical Evolution of the LRE Requirement

Pre-2016: A Loosely Enforced Practice

Prior to 2016, the LRE was consistently required for ASMTP but not for GEP applications.  Most GEP Immigration Officers would expect only written justifications highlighting the specialised nature of the role.  Employers were often advised by Immigration Consultants to avoid conducting an LRE unless absolutely necessary, as it could inadvertently signal that the role was not sufficiently specialised.


Audit Commission Report No. 66 (2016)

The turning point came with the release of Audit Commission Report No. 66, which recommended stricter enforcement of local recruitment efforts.  In response, the Immigration Department adopted the ASMTP’s more rigorous standards and extended them to the GEP scheme.  Since then, unless an application qualifies for exemption, LRE documentation has become a de facto requirement.


Interestingly, the LRE has never been explicitly listed as a formal requirement in the Immigration Department’s official guidebooks. However, its importance has grown through practice and policy interpretation, making it a critical part of most employment visa applications.



Facilitation Measures Introduced in 2021


To address inconsistencies and improve transparency, the Immigration Department introduced Facilitation Measures in 2021. These measures clarified when an LRE could be skipped and established standardised expectations across applications.


Exemption Criteria

Employers may be exempt from conducting an LRE if the application meets one of the following criteria:


1. Intra-Company Transfer

The applicant has worked in a managerial or professional capacity for the same company from overseas or an overseas company within the same corporate group for at least one year.

Important caveat: Contractors or agents are usually not eligible because they are not directly employed by the group. Under very limited circumstances, this can be overcome with compelling justification and supporting documentation.

2. Listed on the Talent List

The professional and their profession are in high demand according to Hong Kong’s Talent List.

Note: The Talent List is updated regularly, and eligibility depends on strict criteria including education, certifications, and relevant experience.


3. Graduate of a Top 100 University

The applicant has graduated from one of the world’s top 100 universities—according to rankings such as:

• Times Higher Education World University Rankings

• QS World University Rankings

• Shanghai Jiao Tong University Academic Ranking of World Universities

• U.S. News & World Report Best Global Universities Rankings

Note: Applicants who hold a bachelor's degree from one of the world's top 100 universities are generally eligible to apply for the more straightforward Top Talent Pass Scheme (categories B or C).


4. Holder of a Job-Relevant Master’s or Doctorate Degree

The applicant has a master’s or doctoral degree directly relevant to the job role.

Note: The relevance of the degree must be clearly demonstrated in the application.




Strategic Considerations for Employers

Given the complexity and evolving nature of the LRE requirement, employers should approach the process strategically. Here are some best practices:

Before Posting the Job:

  • Ensure the job description clearly outlines specialised skills or qualifications.
  • Make sure the name of the employing entity is clearly visible.
  • Use reputable job boards that are recognised by the Immigration Department.
  • Set a reasonable application deadline (typically 4 weeks).


During the Recruitment Process:

  • Keep detailed records of all applications received.
  • Document interview notes and reasons for rejection.
  • Maintain transparency and fairness throughout the process.


When Preparing the Visa Application:

  • Include a summary of the LRE, highlighting the number of applicants and interview outcomes.
  • Attach copies of the job ad, CVs received, interview records, and rejection reasons.
  • Clearly explain why the selected candidate is uniquely qualified



Common Pitfalls to Avoid

Despite best intentions, many employers fall into traps that can jeopardise their visa applications:

•           Vague job ads that fail to specify specialised skills, titles or the name of the employer.

•           Insufficient documentation of the recruitment process.

•           Overreliance on exemptions without verifying eligibility.

•           Failure to update recruitment practices in line with current Immigration Department expectations.

Avoiding these pitfalls requires diligence, planning, and sometimes, professional guidance.



Conclusion: Navigating the LRE with Confidence

The Local Recruitment Exercise has become a cornerstone of Hong Kong’s employment visa framework.  While it may seem burdensome, it serves a vital function – ensuring that local talent is given fair consideration and that overseas hires are genuinely necessary.


For employers, understanding the nuances of the LRE and staying up to date with Immigration Department expectations is essential.  Whether you're applying under the GEP or ASMTP, a well-documented and thoughtfully executed LRE can make the difference between approval and rejection.


As Hong Kong continues to refine its immigration policies in response to shifting economic and social dynamics, the importance of compliance and transparency will only grow.  By embracing the LRE as part of a responsible hiring strategy, employers can not only meet regulatory requirements but also contribute to a more equitable and competitive labour market.



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