Hong Kong - Hong Kong Companies New Inspection Regime


The Companies Register (“the Register”) maintained by the Companies Registry (“the Registry”) contains personal information available for public inspection.  Such personal information includes identification details and residential address of the companies’ directors, their company secretaries and some other individuals.

Pursuant to the relevant provisions of the Company Ordinance concerning the New Inspection Regime, correspondence address instead of residential address of directors and partial identification details instead of full identification details of directors, company secretaries and other persons would be made available on the Register for public inspection.  The residential address of the directors and their full identification details would only be accessible by “specific persons” upon application. 


The New Inspection Regime Will Be Implemented In 3 Phases

Phase 1

From 23 August 2021, companies may replace residential address of directors with their correspondence addresses, and replace full identification details of directors and company secretaries with their partial identification details on their own registers for public inspection;

Phase 2

From 24 October 2022, Protected Information on the Index of Directors on the Register will be replaced with correspondence addresses and partial identification details for public inspection.  Protected Information contained in documents filed for registration after commencement of this phase will not be provided for public inspection.  “Specific persons” could apply to the Registry for access to Protected Information of directors and other persons; and

Phase 3

From 27 December 2023, data subjects could apply to the Registry for protecting from public inspection their Protected Information contained in documents registered with the Registry (“Withheld Information”), and replace such information with their correspondence addresses and partial identification details.  “Specified persons” could apply to the Registry for access to Withheld Information of directors and other persons.

Who Are Specified Persons?

Please find below who can be considered as Specified Persons:

  • a data subject;
  • a person who is authorised in writing by a data subject to obtain 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 Regulation;
  • a solicitor or foreign lawyer;
  • a certified public accountant (practising);
  • a financial institution or Designated Non-Financial Business and Profession


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