Hong Kong: Phase 3 of the New Inspection Regime

From August 2021, the Companies Registry (“CR”) in Hong Kong has taken steps gradually and launched the New Inspection Regime to protect officer’s personal information from the public inspection.

With reference to phase 3 of the Regime which came into effect from 27 December 2023, it allows a current or former (1) director, (2) reserve director, (3) company secretary etc (the “Data Subject”) to apply for withholding their personal information (e.g. full ID/passport number, residential address) from public inspection and replace it with partial ID/passport number, and correspondence address.

As a side note, any filings with personal information made to the CR before 24 October 2022 (beginning of Phase 2) would still be publicly available since the withholding of personal information is not automatic. However, this is not a mandatory requirement. If no application for withholding of information is submitted, the personal information will continue to be publicly available.

Key changes and requirements

Phase 3 of the New Inspection Regime has commenced on 27 Dec 2023. This is not mandatory, but we highly recommend clients to take immediate action to better protect company officer’s personal information.

How can we help?

Computershare can assist Data Subjects with preparing the application for reviewing historical records at the Companies Registry and withholding of personal information for a fee. This new requirement reiterates the important need for better protection of personal information of companies’ officers.

Computershare’s leading entity management system GEMS can also help you store the personal information for your directors ID information in a secure online system, ready to access when you need it to meet your filing obligations.

Contact:

Please contact your dedicated Computershare Relationship Manager or send an email to globalentityservices@computershare.com for more information about how Computershare may assist you in responding to these new requirements.

This notice is provided by Computershare for general informational purposes only and is not intended and should not be construed as legal, regulatory, financial or tax advice. Computershare is not licensed or authorized to practice law in any jurisdictions and hence does not provide any legal advice and it does not hold itself out as doing so. Neither Computershare nor any of its affiliates or contributors accept any responsibility or liability for the quality, accuracy or completeness of any information contained in this notice. It is important that you seek independent professional advice relating to the subject matter of this notice before relying on it.