Under Phase 1 of the new inspection regime, companies may replace usual residential addresses of directors (including reserve directors) with their correspondence addresses, and replace full identification numbers (i.e. number of an identity card or a passport) of directors (including reserve directors) and company secretaries with their partial identification numbers on their own registers for public inspection.
The Companies Ordinance (Commencement) Notice 2021 stipulates 23 August 2021 as the commencement date of Phase 1.
Upon the commencement of Phase 1, in accordance with section 643(1)(a)(ii), (2)(b) or (3)(b) (in so far as it relates to a correspondence address) and section 643(5) of the Companies Ordinance (Cap. 622) (“CO”), a company’s register of directors is required to contain a correspondence address of its director (including reserve director) who is a natural person and such address must not be a post office box number.
Section 115A of Schedule 11 to the CO provides for the transitional arrangements in relation to compliance with the requirement under section 643(1)(a)(ii), (2)(b) or (3)(b). It is provided that the register of directors need not contain a director’s correspondence address before the company’s first annual return date on or after the commencement date of Phase 2, unless –
- the particulars of the director are first entered in the register of directors on or after the commencement date of Phase 2; or
- any change is made to the particulars of the director contained in the register of directors on or after the commencement date of Phase 2.
In case of (b) above, the register of directors must contain the director’s correspondence address beginning on the date on which the change is made.
Yes.
If the number of an identity card or a passport (“IDN”) comprises a sequence of an even number of alphanumeric characters (excluding spaces, punctuation marks and symbols), the first half of the sequence must be made available for public inspection.
If the IDN comprises a sequence of an odd number of alphanumeric characters (excluding spaces, punctuation marks and symbols), the part that begins with the first character in the sequence and ends with the character that falls on the middle of the sequence must be made available for public inspection.
Some examples of the first part of the IDNs are provided below.
Hong Kong Identity Card Number- the date on which the company enters the director’s correspondence address in the register of directors;
- the first annual return date of the company on or after the commencement date of Phase 2.
