Phase 2 of the New Inspection Regime will take effect from 24 October 2022

Pursuant to the relevant provisions of the Companies Ordinance concerning the New Inspection Regime which will be implemented in three phases, phase 1 has taken effect from 23 August 2021, companies may replace usual residential addresses (“URAs”) of directors with their correspondence addresses, and replace full identification numbers (“IDNs”) of directors and company secretaries with their partial IDNs on their own registers for public inspection.

Phase 2 of the New Inspection Regime will take effect from 24 October 2022. Protected information contained in documents filed for registration after commencement of this phase will not be provided for public inspection. “Specified persons” could apply to the Hong Kong Companies Registry (“CR”) for access to Protected Information of directors and other persons.

Key points of Phase 2 of the New Inspection Regime are as below:

1. A company is required to ensure that its register of directors will contain the correspondence address of its natural person director(s) (including reserve director) before its first annual return date on or after the commencement date of Phase 2 on 24 October 2022;

2. URAs and full IDNs (collectively as “Protected Information”) on the Index of Directors on the Companies Register are replaced with correspondence addresses* and partial IDNs for public inspection. Protected Information contained in documents filed for registration after commencement of this phase is not provided for public inspection. “Specified persons”* could apply to CR for access to Protected Information of directors and other persons;

3. The address of the company’s registered office (or the company’s principal place of business in Hong Kong if the company is a registered non-Hong Kong company) will be regarded as the correspondence address of a natural person director (including reserve director) unless a separate statutory form (i.e. form ND2B, or form NN7 for registered non-Hong Kong company) to report the director’s correspondence address is filed with CR within 15 days (or within one month for registered non-Hong Kong company) after the commencement date of Phase 2 on 24 October 2022.

4. CR has revised 26 specified forms pertaining to the reporting of Protected Information for use starting from 24 October 2022.

CityLinkers provide the following service:

Provide correspondence address arrangements for natural person directors on the companies register.