Key points
If you live in an HOS court or a Tenants Purchase Scheme estate and your hinges have oxidised, the seals have hardened and the window edge leaks in every rainstorm, the first question about a new set of aluminium windows is usually not the price but "who do I apply to?" Some people say the Housing Department, some say the Buildings Department, and some say it is your own flat so it is your own call. None of the three is quite right. This article starts with the system, then walks through the submission steps and what owners can do to protect themselves.
HOS and TPS Window Replacement: It Is the ICU, Not the Buildings Department
Building safety in Hong Kong is governed by the Buildings Ordinance, and minor works in ordinary private buildings are supervised by the Buildings Department. Properties under the Housing Authority — public rental estates, HOS courts and Tenants Purchase Scheme estates — are different. For these buildings, the functions of the Buildings Ordinance are carried out by the Independent Checking Unit (ICU) under the Office of the Permanent Secretary for Housing. In other words, the minor works submission for replacing windows in an HOS flat is lodged with the ICU.
This is often confused, because HOS owners hold private title and naturally assume they deal with the Buildings Department like any private building. In practice, as long as the flat is in an estate developed by the Housing Authority, the submission goes to the ICU whether you are a public housing tenant or an HOS owner. The same applies to the Mandatory Window Inspection Scheme (MWIS): inspection forms and submissions for HOS and TPS flats are also processed through the ICU. The official description of the minor works system is on the Buildings Department's Minor Works Control System page.
Recent public hearings have drawn attention to how the ICU supervises works, and many HOS owners are now asking what a submission actually protects. In short, the submission system requires the works to be carried out by a registered contractor with a record of commencement and completion, so the owner holds a set of documents that can be traced later. The system itself does not send anyone to supervise on site, which is why verifying the contractor and inspecting the finished work yourself still matters.
How Does HOS Window Replacement Differ from Public Housing?
Although both are submitted to the ICU, the procedure for an HOS owner and a public housing tenant is not the same. The difference is mainly at the "approval" step:
| Item | HOS / TPS owner | Public housing tenant |
|---|---|---|
| Title | Privately owned | Rented from the Housing Department |
| Approval before replacement | Depends on the court's Deed of Mutual Covenant and management office; some courts require uniform window styles and colours | Must apply to the Housing Department estate office first |
| Minor works submission | Contractor submits MW03 / MW04 to the ICU | Contractor submits MW03 / MW04 to the ICU |
| Cost | Paid by the owner; elderly owners may apply for a subsidy | Subject to Housing Department arrangements |
For the public housing application procedure, see the Public Housing Window Replacement Guide. What HOS owners need to watch is the Deed of Mutual Covenant: many HOS courts require a uniform external appearance, with frame colours and styles matching the original specification, so check with the management office or owners' corporation before replacing anything, rather than being told to take it down afterwards.
HOS Window Replacement Submission: 5 Steps from Quotation to Completion
Full aluminium window replacement is an alteration that involves the wall structure and is classified as Class II minor works. The whole process runs as follows:
The Minor Works Submission for Aluminium Windows article explains the three classes in detail, so that is not repeated here.
Owner Checklist: What to Do Beyond the Submission
The ICU submission system is built on documents; it does not send anyone to supervise the site. The following steps, done by the owner, are worth more than any system:
A Typical Situation: An HOS Owner in Tseung Kwan O Replaces Their Windows
An owner who has lived in a Tseung Kwan O HOS court for over 20 years has six windows across the kitchen and living room. The hinges had oxidised and the seals had shrunk, and the sills pooled with water in every black rainstorm. He first asked the management office and learned that the court's Deed of Mutual Covenant requires silver frames and the original pane layout, so that became the specification for quotations. After measuring, the contractor recommended 50-series aluminium windows with Amgen 304 stainless steel hinges, and the quotation itemised scaffolding and the ICU submission fee. The MW03 was submitted 8 days before work started, the works took two days, and the MW04 was submitted a week after completion. The owner kept copies of the full set of documents and filed them with the completion photos. The whole project complied with Class II minor works submission.
Frequently Asked Questions
Can I replace HOS windows without a submission?
No. Full aluminium window replacement is Class II minor works and must be submitted to the ICU by a registered minor works contractor. Works with no submission record may have to be regularised, or even redone, at a future mandatory window inspection or sale.
Do I need a submission for replacing only hinges or handles, or for re-applying sealant?
No. Replacing hinges, handles and seals and re-applying glass sealant are maintenance, do not involve the wall structure and fall outside minor works submission. Only removing the old frame and installing a brand-new window requires it.
Can elderly HOS owners apply for a subsidy?
Owner-occupiers aged 60 or above who pass the income and asset tests can apply for the Urban Renewal Authority's Building Maintenance Grant for Elderly Owners, up to $80,000, which can be used for window replacement. Amgen Windows can help prepare the application documents.
When do I need a window inspection after replacement?
Once new aluminium windows are installed, if the court falls within the Mandatory Window Inspection Scheme you will still need an inspection the next time a notice arrives. Because the windows are new, an inspection without repairs is usually all that is required, but the report still has to be submitted through the ICU.
In Short: Ask the Management Office First, Then Use a Licensed Contractor
Three things decide an HOS window replacement: check the Deed of Mutual Covenant and management office requirements first, confirm the contractor is a registered minor works contractor, and follow the ICU's MW03 / MW04 submission procedure in full. Amgen Windows, licence number MWC 316/2021, carries out window replacement in HOS courts and Tenants Purchase Scheme estates and handles the entire ICU submission. To discuss a replacement plan for your own flat, WhatsApp 6586 3435 to book an on-site assessment.
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