New Inspection Regime for Hong Kong Companies from 24 October

A new inspection regime is being implemented under the Hong Kong Companies Ordinance, which provides additional protection for the personal information of directors and other relevant persons appearing on the Companies Registry.

The inspection regime is divided into three phases, with Phase 2 to commence on 24 October 2022. We discuss how the inspection area will operate and the relevant requirements for Hong Kong companies.

On 23 August 2021, the new inspection regime under the Companies Ordinance (Cap. 622) comes into effect.

Under the new inspection regime, (a) the correspondence addresses of directors instead of their usual residential addresses, and (b) the partial identification numbers of directors, company secretaries, and other relevant persons (such as liquidators) instead of their full identification numbers, will be published in the Companies Register for public inspection.

At the same time, the company may keep the URA and full IDNs (other than Part I) on the register in which the information is kept for public inspection. (The first part of the IDN is determined by established rules, usually the first half of the serial number if the IDN is an even number or the part that starts with the first character in the sequence and ends with the character in the middle of the sequence if the IDN is an odd number).

Under the new censorship, URAs and full IDNs are considered “protected information“. Previously, the URA and full IDN of any director, company secretary, or another relevant person of a company were available for public inspection. By replacing the URA and full IDN with a correspondence address and partial IDN, the protection of personal information will be enhanced. At the same time, this will ensure the transparency of the Companies Register by allowing public access for the purposes set out in the Companies Ordinance (Cap. 622).

The new inspection system will be implemented in three phases as a result of the major revisions being made to the Integrated Companies Registry Information System (ICRIS). The commencement dates for each phase are. 23 August 2021 (Phase 1)24 October 2022 (Phase 2); and 27 December 2023 (Phase 3).



Phase 2: from 24 October 2022

In Phase 2 of the new inspection regime, protected information in the index of directors on the Companies Register will be replaced with correspondence addresses and partial IDNs for public inspection. Documents containing protected information that is lodged for registration – after the start of this phase, i.e. 24 October 2022 – will not be available for public inspection but will be available for inspection by “specified persons” on application.

The following specified persons may apply for access to protected information in the Companies Registry

– Data Subjects

– A person who has been authorized in writing by the data subject to access the information

– A member of the company

– A liquidator

– A trustee in bankruptcy

– A public officer or public body

– A person specified in the Schedule to the Regulations

– A solicitor or expatriate practicing law in a law firm

– Certified public accountants (practicing).

– Financial institutions or designated non-financial businesses and industries



Companies are required to prepare registers of directors and company secretaries and to make available for public inspection their correspondence addresses and part of their identity card numbers – no later than the date of the first annual return or the date of first entry and/or update of particulars after the commencement of Phase 2, whichever is earlier.

More specifically, a Hong Kong company should perform the following tasks.

– Confirm the correspondence address of the natural person directors (including reserve directors). It is important to note that the registered office address or the residential address of the director can be used as the director’s correspondence address.

– Enter the correspondence addresses of natural person directors and partial identification numbers into the register of directors kept by the local company by the first annual return date on or after the commencement date of Phase 2.

– Deliver the prescribed registration form to the Registrar of Companies if

1. the correspondence address of the natural person director, which is not the address of the registered office of the company, is entered in the register of directors immediately before the effective date;

2. an address other than the address of the registered office of the local company or the address of the registered non-Hong Kong company’s principal place of business in Hong Kong will be used as the correspondence address of the natural person director.


How should a Hong Kong company be prepared?


In short, after all, three phases of the new inspection regime in Hong Kong have been fully implemented.

– Only the directors’ correspondence addresses and some of the identification numbers of directors, company secretaries, and other related persons will be shown on the Companies Registry’s register.

– Only specified persons may apply for access to the market value and full identification numbers of directors, company secretaries and other relevant persons, subject to a few exceptions.

– A company may not allow public access to the URA and full identification numbers on the register where information is kept (except for Part I).

– Data subjects may apply to the Companies Registry to withhold public access to protected information in their documents registered with the Registry.

The new censorship regime in Hong Kong will provide additional protection for the personal information of company directors and other relevant individuals appearing on the Companies Registry. To meet the requirements of this new regime, if data subjects and Hong Kong-registered companies wish to withhold their protected information from public inspection, they should contact their service providers to update their personal information accordingly and apply accordingly.

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