Protecting Your Privacy: Key Updates for Entrepreneurs in Hong Kong

If you’re an entrepreneur establishing a business in Hong Kong, understanding the new privacy rules for HK Companies under the New Inspection Regime under the Companies Ordinance (Cap. 622) is essential. Fully implemented in December 2023, this regime significantly enhances privacy protections for company directors, secretaries, and other key personnel by limiting public access to sensitive personal data.

What is the New Inspection Regime?

Under the previous system, a private limited company registered in Hong Kong made personal information—including residential addresses and full identification numbers—publicly accessible. The new regime enhances privacy by displaying only correspondence addresses and partial identification numbers, thereby safeguarding sensitive data.

Key Changes to Privacy Regulations

1. Usual Residential Addresses (URAs)
   Directors, company secretaries, and other relevant individuals now only need to disclose correspondence addresses, keeping their home addresses private. The registered office serves as the default correspondence address, but you can report a different address to the relevant authorities with the help of a company secretary.
2. Partial Identification Numbers (IDNs)
   Full ID numbers (such as HKID or passport numbers) were once visible in public records. Under the new rules, only partial IDNs are displayed, helping to reduce the risk of identity theft and fraud.
3. Application for Withheld Information
   Access to URAs and full IDNs is restricted and can only be obtained by specified persons*, including:

• The data subject
• Authorized individuals by the data subject
• Company members
• Liquidators
• Trustees in bankruptcy
• Public officers or bodies
• Scheduled persons
• Solicitors or foreign lawyers
• Certified public accountants
• Financial institutions or designated non-financial businesses and professionals

*As indicated in Section 12 of the Companies Ordinance (Residential Addresses and Identification Numbers) Regulation (Cap.622N).

Phased Implementation (Now Completed)

The regime was rolled out in three phases:

• Phase 1 (Since 23 August 2021): Companies were allowed to replace directors’ residential addresses with correspondence addresses and use partial IDNs on their own registers for public inspection.
• Phase 2 (Since 24 October 2022): The Companies Registry replaced protected data (e.g., full addresses and IDNs) on public records with correspondence addresses and partial IDNs. Documents filed after this date no longer include full IDNs or URAs.
• Phase 3 (Since 27 December 2023): Directors and key personnel whose personal data is already public can apply to have it withheld from inspection.

Why This Matters for Entrepreneurs

As a business owner in Hong Kong, you no longer need to worry about exposing your personal residential address or full identification number in public records. The New Inspection Regime allows you to operate with greater privacy while maintaining transparency for your business.

How to Comply with the New Rules

• Update Company Records: Exclude URAs and IDNs in your Company Registers. Replace them with correspondence addresses and partial IDNs where required.
• Replace Public Data: If your personal information was made public before the regime took effect, apply to the Companies Registry to have it replaced with protected alternatives.

Secure Your Business, Protect Your Privacy

The new privacy rules for HK companies under New Inspection Regime offers much-needed privacy protection for entrepreneurs and company directors in Hong Kong. Ensure your personal data is safeguarded while staying compliant with the Companies Ordinance, so you can focus on growing your business with peace of mind.

For more details on updating your records or applying for data protection, visit the Companies Registry or contact us.