Hong Kong: Commencement of Phase 3 of new Inspection Regime

neub9
By neub9
2 Min Read

In brief

Phase 3 of the new Inspection Regime for personal information on the companies register is set to be effective from 27 December 2023. This will allow directors and other relevant individuals to apply to withhold their protected information from public inspection.

To familiarize yourself with the background of the Inspection Regime, please refer to our previous alerts.


On 23 August 2021, the new Inspection Regime under the Companies Ordinance (Cap. 622) went into effect. It applies to both Hong Kong-incorporated companies and registered non-Hong Kong companies and has been implemented in three phases.

Under the previous rules, the usual residential address (URA) and full identification number (IDN) of a company’s director, alternate director, company secretary, authorized representative, or other relevant persons could be accessed by the public. The new Inspection Regime replaces this information with their correspondence address (CA) and partial IDNs.

Phase 1 and Phase 2 of the Inspection Regime allowed companies to limit public inspection of their registers and replace Protected Information with their CA and partial IDNs. From 27 December 2023, applies for Data Subjects to withhold their Protected Information from public inspection will be accepted by the Registry.

Phase 3 is focused on protecting the personal data privacy of Data Subjects, allowing them to apply to the Registry to withhold their Protected Information from public inspection. Our Firm can assist with making this application.

For further information, please get in touch with our lawyers under the “Contact Information” or your usual Baker McKenzie contact. We are here to advise on the next steps to be taken under this new regime.

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