A client called us last month after spending HK$420,000 on a Southeast Asia market launch, expecting the BUD Fund to reimburse half of it. It didn't. The fund pays 25%, and only for costs approved before the first invoice was issued. That misunderstanding sits behind most failed applications we see.

The BUD Fund (Dedicated Fund on Branding, Upgrading and Domestic Sales) has run since June 2012. By September 2025, nearly 12,000 applications had been approved, worth around HK$7.5 billion across roughly 7,800 companies. The rules moved again in 2026.

The 1:3 rule and the ceilings that actually bind

For applications received from 14 March 2025, funding runs on a 1 (Government) : 3 (enterprise) matching ratio. The Government covers a maximum of 25% of total approved project cost. You pay at least 75% in cash, and contribution in kind isn't accepted.

• Easy BUD: up to HK$150,000 per application, raised from HK$100,000 on 15 June 2026
• General application: up to HK$800,000
• E-commerce Easy: up to HK$800,000 per application, with its own HK$1,000,000 cumulative cap
• Per enterprise: HK$7,000,000 cumulative across a maximum of 70 approved projects

Here's the constraint that catches people out: at any point, the total approved and ongoing funding across all your BUD projects can't exceed HK$800,000. "Ongoing" means the final report hasn't been accepted by the Programme Management Committee yet. So if you have a HK$400,000 project running and want to start an HK$800,000 one, you can't. You finish one first. Sequencing matters more than maximising any single application.

You may submit one general application, one E-commerce Easy application and one Easy BUD application every three months. General and E-commerce Easy applications are handled in batches, and the current batch closes on 31 December 2026 at 23:59 Hong Kong time.

What changed in 2026

• Eight new markets. From 15 June 2026 the fund covers Saudi Arabia, Bangladesh, Egypt, Hungary, Pakistan, Kazakhstan, Mongolia and Brazil, taking the number of covered economies to 47.
• Easy BUD got bigger. The per-application ceiling rose 50% to HK$150,000, with results normally within 30 working days.
• The EMF is gone. The SME Export Marketing Fund was consolidated into BUD, and the last activities eligible under it had to be completed by 30 June 2026. Exhibition and export marketing spend now runs through Easy BUD. EMF and BUD ceilings were always calculated separately, so old EMF grants don't reduce your HK$7 million.

E-commerce Easy is narrower: it covers the Chinese Mainland and the ten ASEAN states only, and it's aimed at platform setup, digital marketing and logistics integration. If your target market is Dubai or São Paulo, use a general application.

The eligibility test that fails most applicants

Being registered in Hong Kong isn't enough. You need substantive business operations here, and you have to prove it when you apply — the latest audited accounts plus either MPF records for your employees or sales invoices and receipts.

Two traps worth flagging:

• A shell company, or one that primarily operates outside Hong Kong, fails outright. So does a company whose sales are only to other entities in its own group.
• Related enterprises share one ceiling. If two Hong Kong companies have common shareholders holding 30% or more in each and carry on the same business nature, they're treated as a single enterprise for the HK$7 million cap.

If your statutory audit is outstanding, you have nothing to submit. That's the most common reason a genuinely qualified company gets turned away. Fix the audit, then apply.

Approval isn't the finish line — the project audit is

Payment is tied to a project audit. On completion you file a final report plus the project's income and expenditure accounts, audited by an independent Hong Kong practising CPA, within two months. Easy BUD has no initial payment at all: everything is reimbursed once those documents are accepted. General applications can draw an initial payment of 20% of approved government funding, with the balance settled on completion. The audit fee is claimable, capped at HK$10,000 per audit and subject to the same 1:3 ratio.

Treat the project as a set of books within your books. Expenditure counts only where the goods or services were received and delivered inside the project period. Costs committed before the start date or incurred after completion don't count. Every quotation, contract, invoice and payment record has to be in the applicant company's own name.

Don't pay a middleman for a "guaranteed" approval

HKPC, which implements the fund, has stated it hasn't appointed or designated any consultancy to provide fee-charging BUD services. Firms claiming otherwise are misrepresenting it. Enforcement is real: on 16 October 2026 the ICAC charged five people over subsidy fraud involving more than HK$1.6 million under the former Technology Voucher Programme, with roughly 470 applications linked to the case. False declarations in a BUD application expose the owner, shareholder or director personally.

HKPC runs a free one-hour consultation. Book at least three working days ahead on 2788 6088 or bud_sec@hkpc.org — and read the Guide to Application before that call, not after.

If you're planning a BUD project this year, the preparation starts with your books, not the application form. Lemon Accountancy handles Hong Kong statutory audits, project accounts and the audit reports the fund requires, and we'll tell you straight whether your company clears the substantive operations test before you spend anything on an application. Email info@lcpa.com.cn or call 00852-55749538.

This article reflects the BUD Fund rules published by the Trade and Industry Department and the Hong Kong Productivity Council as at October 2026. Figures and deadlines can change — confirm current requirements with the BUD Fund Implementer before applying.