The Hong Kong Companies Ordinance provides a new mode of access to information from the Companies Register, which is introduced in stages from 23 August 2021.
The new inspection regime will become fully operational after substantial modifications of the Integrated Companies Registry Information System. That is why a step-by-step introduction of the regime is linked with the System upgrading project, which is scheduled for completion at the end of 2023.
Starting with 23 August 2021, companies mayblock public access to their directors’ usual residential addresses (URA) and full identification numbers (IDN) kept in their internal corporate registers by replacing them with their correspondence addresses and partial identification numbers, respectively.
This refers to companies’ internal registers (the Register of directors and the Register of secretaries), as distinct from the Companies Register, which is maintained by the Companies Registry. At this phase, the renewal of these internal registers for the purposes of the new inspection regime is optional.
The first phase allows companies to exclude from public access only the directors’ residential addresses and their full identification numbers maintained in the company’s own registers.
From 24 October 2022, usual residential addresses and full identification numbers in the Register will be replaced with correspondence addresses and partial identification numbers. They will be open for public inspection. Therefore, usual residential addresses and full identification numbers submitted to the Companies Register for registration after the commencement of this phase will not be available to the public.
The exception is made for a closed list of persons specified in the Ordinance. For example, they include a member of the company, a liquidator, a trustee in bankruptcy. They will be able to obtain this information upon request.
From 27 December 2023, data subjects could apply to the Registry for protecting from public inspection their residential addresses and full identification numbers contained in documents registered with the Registry and replace such information with their correspondence addresses and partial identification numbers.