Compliance with the Filing Requirements under Phase 2 of the New Inspection Regime (24 Oct 2022)

As reported in our prior news updates on 4 August 2021 and 25 October 2021, under the new inspection regime, the usual residential addresses of directors and full identification numbers of directors, company secretaries and some other individuals such as authorized representatives and liquidators (collectively, the “Protected Information”) are no longer required to be disclosed as part of the filings to the Companies Registry (the “Registry”) and in the Register of Directors kept by the Company.

The new regime will be implemented in 3 phases. Phase 2 of the new regime will commence on 24 October 2022. Upon the commencement of Phase 2 of the new regime:

(1) A new set of company filing forms[1] will be used and companies will only be required to fill in a correspondence address of the directors, which could be the registered office address (for Hong Kong companies) or principal place of business (for non-Hong Kong companies), as well as a partial identification numbers of the directors and other individuals.

Company secretaries are reminded that the Registry will only accept the revised forms from 24 October 2022 onwards.

(2) “Specified persons[2] can apply to the Registry for access to the Protected Information.

(3) Any typographical or clerical error in documents already registered with the Registry can be rectified using a new administrative Form AD[3].

Form AD applies not only to the Protected Information as mentioned, but also other general rectifications that do not involve Protected Information. Companies should note that the Registry in processing their application for rectification, may further request for an explanatory letter to provide particulars of and the circumstances leading to the error(s).


[1] Link to the new Filing Forms: https://www.cr.gov.hk/en/legislation/nir/forms.htm

[2] as specified in the Companies (Residential Addresses and Identification Numbers) Regulation (Chapter 622N of the Laws of Hong Kong) when it comes into effect

[3] See Circular: https://www.cr.gov.hk/en/publications/docs/ec6-2022-e.pdf ; Link to Form AD: https://www.cr.gov.hk/en/legislation/nir/formad.htm

21 September 2022
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