New inspection regime of the Companies Register implemented in Hong Kong.

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A new inspection regime has been implemented under the Hong Kong Companies Ordinance to improve the protection of sensitive personal information of company directors and company secretaries. The new regime will be implemented in three phases.

Phase 1 of the new inspection regime came into effect on 23 August 2021, while phases 2 and 3 will be commenced on 24 October 2022 and 27 December 2023, respectively.

Phase 1

Under phase 1, companies can use correspondence addresses instead of the usual residential address (URAs) of directors and replace the full identification numbers (IDNs) of directors and company secretaries with partial IDNs on their registers for public inspection.

Partial IDNs will be displayed for public inspection in the following sequence:

  • If the IDN consists of an even number of alphanumeric characters, the first half of the sequence must not be withheld.
  • If the IDN consists of an odd number of alphanumeric characters, the part that begins with the first character and ends with the character in the middle must be displayed.

Phase 2

Protected Information on the Index of Directors on the Companies Register will be replaced with correspondence addresses and partial IDNs for public inspection beginning on 24 October 2022.

Documents containing Protected Information filed for registration after the implementation of this phase will not be available for public inspection.  To facilitate the implementation of Phase 2, the Registrar of Companies has revised 26 specified forms which pertain to the reporting of Protected Information for use starting from 24 October 2022.

Specified persons can apply for access to Protected Information of directors and other persons.

Specified persons include:

  • Data subject
  • The person who is authorised in writing by a data subject to obtain the information
  • Member of the company
  • Liquidator
  • Trustee in bankruptcy
  • Public officer or public body
  • A person specified in the Schedule to the Regulation
  • Solicitor or foreign lawyer who practices law in a law firm
  • Certified public accountant (practising)
  • Financial institutions or designated non-financial businesses and professions

Phase 3

From 27 December 2023, data subjects can apply for protection of their Protected Information in documents registered with the Registry from public inspection and replace such information with correspondence addresses and partial IDNs.

Final thoughts

Hong Kong’s new inspection regime aims to protect the private information of directors and other individuals in the company that is displayed in the Companies Registry’s registers. Instead of showing URAs and full IDNs, only correspondence addresses and partial IDNs will be displayed. If you need help updating personal information with the Registry, feel free to contact Acclime.

New inspection regime of the Companies Register implemented in Hong Kong
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