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COMPANY SECRETARIAL: New Inspection Regime

According to the first meeting of “Subcommittee on Seven Pieces of Subsidiary Legislation Relating to the Implementation of the New Inspection Regime of the Companies Register under the Companies Ordinance” on 5 July 2021, the new inspection regime will be implemented in 3 phases and is to be completed by end of 2023.
Under the new guidelines, there will additional safeguards relating to the personal data of directors and other relevant individuals who appear on the Companies Registry. While members of the public will still be able to access certain personal information about company directors, company secretaries or liquidators in the event of a business being wound up (on application). "Specified persons" (including practicing accountants) may access usual residential address and full Identification Documents which are categorized as protected information.

New Personal Data Protection Provisions

  • only the correspondence addresses of directors and company secretaries, as well as the partial Identification Number of directors, company secretaries and other relevant individuals will be shown in the Companies Register;
  • the usual residential address and full Identification Number of the individuals will only be made accessible to specified persons upon application. The court may disclose such information if it considers it appropriate. The Register may also reveal the usual residential address if it cannot effectively communicate with the director using the correspondence address provided;
  • individuals whose protected information is contained in documents filed before the new inspection regime commencement may apply to the Companies Registry to withhold such material from inspection;
  • a company may also withhold protected information contained in its own register from public scrutiny.

Implementation Timeline

Phase 1

- Companies Ordinance provisions will allow companies to withhold the usual residential address of directors and full Identification Number of directors and company secretaries from public inspection of their private register. This will commence (August 23) with specific subsidiary legislation due to be introduced.

Phase 2

- Starting in October 2022, Companies Ordinance will be expanded to allow protected information in the Companies Registry to be withheld from public inspection (applicable to document filed for registration after Phase 2 commences)

Phase 3

- Starting in December 2023, all remaining Companies Ordinance Provisions will come into effect. People may apply to the register if they wish to suppress protected information already filed in the registry for public inspection.

**All subject to the subsidiary legislation being introduced.

Please feel free to contact Gilbert Pun at +(852) 2521-2328 or send an email to This email address is being protected from spambots. You need JavaScript enabled to view it. for more details.