The Companies Registry (“CR”) in Hong Kong has announced the launch of the first phase of the new inspection regime. The regime is designed to protect the personal data from misuse while also ensuring transparency and allowing the public to inspect the Register.
Under the new inspection regime, correspondence addresses instead of the usual residential addresses (“URAs”) of directors and partial identification numbers (“IDNs”) instead of full IDNs of directors, company secretaries and other relevant persons would be made available on the register for public inspection. The URAs and full IDNs (“Protected Information”) would only be accessible by “specified persons” upon application. Similarly, companies may withhold from public inspection the Protected Information on the registers they have kept.
Timeline of the new inspection regime
The new inspection regime will run in three phases:
|
Phases |
Implementation date |
Particulars |
|
1 |
August 23, 2021 |
Companies may replace directors’ URAs with their correspondence addresses, and directors’ and company secretaries’ full IDNs with their partial IDNs on their registers for public inspection. |
|
2 |
October 24, 2022 |
Protected information on the index of directors on the register will be replaced with correspondence addresses and partial IDNs for public inspection. Protected information contained in documents filed for registration after the commencement of this phase will not be provided for public inspection. Specified people may apply to the CR for accessing protected information. |
|
3 |
December 27, 2023 |
Data subjects may apply to the CR for protecting their protected information from public inspection contained in documents already registered with the CR before the commencement of phase two, and replace such information with correspondence addresses and partial IDNs. Specified people may apply to the CR for accessing protected information. |
Specified people
Specified people include data subjects and those they authorise; the company's members; public officers, public bodies and people or organisations who need to use protected information for executing statutory functions; lawyers practising in law firms and practising accountants; banks; and financial institutions and designated non-financial businesses and professions regulated under the Anti-Money Laundering & Counter-Terrorist Financing Ordinance.
What we can help
Update your company’s own registers by:
- replacing URAs of directors with correspondence addresses;
- replacing full IDNs of directors with partial IDNs of directors; and
- providing registered office address as the correspondence addresses of directors.
For more information, please contact Ms. Vincy Cheung at vincycheung@lccpa.com.hk
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