You may be aware of a New Inspection Regime for person information on the Company Register issued by the Hong Kong Companies Registry that will be implemented in three phases from 2021 to 2023. Phase 1 commenced on August 23rd, 2021, which mainly allows companies to replace usual residential addresses (URA) of directors with their correspondence addresses and to replace full identification numbers (IDN) of directors and company secretaries with their partial IDNs. The remaining two phases with key information are as follows:
- Phase 2: From October 24th, 2022, the Protected Information which are the URA and the IDN, on the Index of Directors will be replaced with the correspondence addresses and the partial IDNs for public inspection. Protected Information contained in documents filed for registration after commencement of this phase will not be provided for public inspection. "Specified persons" could apply to the Registry for access to the protected information of directors and other persons, and
- Phase 3: From December 27th, 2023, data subjects could apply to the Registry for protecting from public inspection their Protected Information contained in documents registered with the Registry and replace such information with their correspondence addresses and partial IDNs. "Specified persons" could apply to the Registry for access to Withheld Information of directors and other persons.
Specified persons include data subjects or persons authorized in writing by a data subject, member of the company, liquidator, trustee in bankruptcy, public officer or public body, scheduled person (Cap.622N), solicitor or foreign lawyer, certified public accountant (practicing), a financial institution or designated non-financial business and professional.
Given that Phase 2 is to be implemented soon. If the directors decide not to use the company’s registered or principal office in Hong Kong as their correspondence address, those correspondence addresses must be reported to the Registry within 15 days after October 24th, 2022.
Should you need further information, please kindly contact our experts.