Electronic Access to Withheld Information / Protected Information

Protected information means the usual residential addresses and full identification numbers of directors of companies, and full identification numbers of company secretaries and some other individuals (such as liquidators and provisional liquidators) contained in documents delivered to the Companies Registry for registration on or after 24 October 2022.

Withheld information means the usual residential address and full identification number which are contained in a document delivered to the Companies Registry for registration under the Companies Ordinance (Cap. 622) ("CO"), the Companies (Winding Up and Miscellaneous Provisions) Ordinance (Cap. 32) or the Companies Ordinance (Cap. 32) as in force from time to time before the commencement of the CO, and are withheld from public inspection by the Registrar of Companies upon an application made under section 49(1) of the CO.

The usual residential addresses and full identification numbers contained in documents filed for registration after commencement of Phase 2 of the new inspection regime on 24 October 2022 (i.e. the Protected Information) are NOT provided for public inspection. The revised specified forms for use after the commencement of Phase 2 contain a “PI-sheet” to each relevant form for reporting Protected Information of individuals and the PI-sheet will NOT be made available on the Register for public inspection.

Upon the commencement of Phase 3 of the new inspection regime on 27 December 2023, data subjects may apply to the Registrar of Companies to withhold from public inspection their usual residential addresses (if applicable) and full identification numbers contained in documents registered with the Companies Registry. If the application is approved, the image record of the relevant document will be updated so that the usual residential address and full identification number contained therein (i.e. the withheld information) will NOT be made available on the Register for public inspection.

The usual residential addresses and full identification numbers (IDNs) of natural person directors on the Index of Directors have been replaced with correspondence addresses and partial IDNs for public inspection upon the implementation of Phase 2 of the new inspection regime on 24 October 2022.

You can continue to conduct Director Index Search (Director-based) to obtain a list of companies of which a person is currently a director or reserve director. You can continue to search by:

• English name and / or Chinese name of a natural person director

• HK Identity Card number or Passport number of a natural person director

• exact match of any 2 or more input data of a natural person director

The only difference is that you only need to enter a partial HK Identity Card No or a partial passport number (i.e. first part of the number) instead of the full identification number when HK Identity Card number or Passport number is used as the search key.

No.  You only need to input the partial identification number (i.e. first part of the number) as search key.

In the display of results of Director-based Director Index Search, records of directors having the same full identification numbers but with different formats of names kept on the Register (e.g. one name with English name and another without) will be grouped together for display in a consolidated manner with the same group number so that searchers can identify records of the same director more easily despite the difference in patterns of the names of the director concerned.

In the rare circumstances where different directors have identical full name and partial identification numbers, extra digit(s) will be displayed for the partial identification numbers of the related groups where appropriate for easy differentiation of the directors.

The persons specified by sections (8)1 and 12(1) of the Companies (Residential Addresses and Identification Numbers) Regulation (Cap. 622N) (“the Regulation”) can apply to the Registrar for disclosure of WI/PI under sections 51(3) or 58(3) of the Companies Ordinance (Cap. 622), as the case may be.

The “specified persons” include –

(a) a data subject;
(b) a person who is authorized in writing by a data subject to obtain the information;
(c) a member of the data subject’s company;
(d) a liquidator;
(e) a trustee in bankruptcy;
(f) a public officer or public body;
(g) a person specified in the Schedule to the Regulation;
(h) a solicitor or foreign lawyer;
(i) a certified public accountant (practising);
(j) a financial institution or designated non-financial businesses and professions (DNFBP).

For more information on the meaning of specified persons, please refer to the Regulation.

The list of “specified persons” is guided by the need for access to usual residential addresses and full identification numbers of directors in the conduct of functions in relation to statutory procedures (e.g. handling liquidation and bankruptcy procedures), statutory obligations (e.g. implementing anti-money laundering and counter-terrorist financing measures including customer due diligence pursuant to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)) and law enforcement (e.g. criminal investigation and asset recovery), with a view to ensuring the robustness of the financial, commercial and corporate governance systems of Hong Kong, and proper conduct of law enforcement.

Any person who is authorised by a data subject is a “specified person” who will be given access to the WI / PI of the relevant individuals on the Companies Register. You should therefore ask the data subject to authorise you in writing for obtaining the WI / PI.

No. A law firm is not a specified person as provided in section 12(1) of the Companies (Residential Addresses and identification Numbers) Regulation and therefore cannot apply for disclosure of WI / PI.

However, a solicitor as defined by section 2(1) of the Legal Practitioners Ordinance (Cap. 159) who practises law in a Hong Kong firm and a foreign lawyer as defined by section 2(1) of the Legal Practitioners Ordinance who practises foreign law in a Hong Kong firm or a foreign firm are specified persons who can apply for disclosure of WI / PI.  A legal professional being a DNFBP (having the meaning as a solicitor or foreign lawyer as defined by section 2(1) of the Legal Practitioners Ordinance) can also apply for disclosure of WI / PI for the performance of DNFBP’s functions conferred or imposed on DNFBP under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

A specified person can apply for disclosure of WI / PI through the following means:

(a) One-time application (electronic or paper application)

Electronic application

Only the data subject, a person authorised in writing by a data subject and a member of the data subject’s company can make the one-time application electronically.

The application should be made at the e-Services Portal of the Companies Registry. Applicant should log in his/her User Account or log in as “Unregistered Online User”, and select the service item “ Access to Withheld Information / Protected Information > One-time Application for Disclosure of Withheld Information / Protected Information” under “Access to WI / PI” in the menu bar to make the application. Supporting documents are also required to be submitted with the application.

Paper application

All types of specified persons can make the one-time application in paper. Please refer to the answer to Q15 for details of such kind of application.

(b) Electronic application through a User Account

Only the following designated types of specified persons being a natural person can make electronic application through a User Account which has subscribed to the WI / PI Search Services :

• a liquidator
• a trustee in bankruptcy
• a public officer or public body
• a person specified in the Schedule to the Companies (Residential Addresses and Identification Numbers) Regulation
• a solicitor or foreign lawyer
• a certified public accountant (practising)
• a financial institution or designated non-financial businesses and professions (DNFBP)

If the designated specified person is not a natural person, the application for disclosure of WI / PI can be made by its authorised representative through the authorised representative’s User Account which has subscribed to the WI / PI Search Services.

The designated specified persons being a natural person or the authorised representatives should log in his/her User Account at the e-Services Portal of the Companies Registry. After the login, applicant should select the service item “Access to Withheld Information / Protected Information > Application for Disclosure of Withheld Information / Protected Information” under “Access to WI / PI” in the menu bar to make the application. Please refer to the answers to Q24 to Q42 for more information about the subscription to the WI / PI Search Services for a User Account.

After a one-time online application for disclosure of WI / PI has been submitted, an acknowledgement will be displayed on the screen. Applicant can select the Print function to print the acknowledgement for record. System will also send an email to the applicant at his/her email address provided in the application to acknowledge the application.

Depending on the type of specified person, a specified person should use one of the following specified forms for making a one-time application for disclosure of WI / PI:

Form PS1:	Application for Disclosure of Withheld Information／Protected Information (By data subject／person authorized in writing by a data subject／member of the data subject’s company)
Form PS2:	Application for Disclosure of Withheld Information／Protected Information (By liquidator／trustee in bankruptcy／public officer or public body／scheduled person)
Form PS3:	Application for Disclosure of Withheld Information／Protected Information (By solicitor or foreign lawyer／certified public accountant (practising)／financial institution or DNFBP)

The application form together with the supporting documents can be delivered by post to “Public Search Section, Companies Registry, 13th floor, Queensway Government Offices, 66 Queensway, Hong Kong”.  Applicant may also deliver the form in person to the e-Services Centre of the Companies Registry on 13th floor.

No.  Each paper application for disclosure of WI / PI is for one data subject in one company only.

In general, the supporting documents include:

(i) the identification documents of the applicant, and of the authorised representative of the applicant which is other than a natural person;

(ii) the evidence of the capacity of the applicant as one of the types of specified persons; and

(iii) in certain circumstances, the authorisation document.

Please refer to the information pamphlet “Additional Documents for the Application for Disclosure of Withheld Information / Protected Information” for details of the supporting documents.

Certified true copy of the supporting documents should be submitted together with an application for disclosure of WI / PI. For a one-time application for disclosure of WI / PI made electronically , certified true copy of the supporting documents in PDF format should be uploaded before the application is submitted.

Alternatively, applicant may choose to present the original supporting documents in person to the Companies Registry. Applicant may bring the original documents to the e-Services Centre of the Companies Registry on the 13th floor, Queensway Government Offices, 66 Queensway, Hong Kong for checking. Applicant of electronic application should also provide the officer at the e-Services Centre with the Order Number of the relevant electronic application.

If the supporting documents are submitted in photocopy, they should be certified as true copy by:

(a) a notary public practising in Hong Kong;
(b) a solicitor practising in Hong Kong;
(c) a certified public accountant (practising) within the meaning of section 2 of the Accounting and Financial Reporting Council Ordinance (Cap.588);
(d) an officer of the court in Hong Kong who is authorized by law to certify documents for any judicial or other legal purpose;
(e) a professional company secretary practising in Hong Kong;
(f) a consular officer of applicant’s home country, in case the applicant is a non-Hong Kong resident or an entity not registered in Hong Kong; or
(g) the authority or body which issues the document.

No.  The certification of identification documents cannot be self-serving.  Please arrange to have the copy of your identification document certified by another person specified in the answer to Q19 above.

A fee of $10 for obtaining the WI / PI of each data subject is required according to section 6(c)(iii) (for WI) or section 10(c)(iii) (for PI) of the Companies (Residential Addresses and Identification Numbers) Regulation (“the Regulation”) if the application is made by a solicitor or foreign lawyer, a certified public accountant (practising), or a financial institution or a designated non-financial business and profession.

The other types of specified persons are exempted from the fees by section 13 of the Regulation.

If the application is made by a specified person who is a natural person through his/her User Account, the payment can be made by deduction from its deposit account, credit card (VISA/Mastercard/JCB/UnionPay), digital wallet (Apple Pay/Google Pay), FPS (Faster Payment System) or PPS Shop&Buy Service.

If the application is made by an authorised representative through his/her User Account on behalf of a specified person other than a natural person, the fee will be deducted from the specified person’s deposit account.

If the application is made in paper form and submitted in person at the e-Services Centre of the Companies Registry on 13th floor, the fee should be paid by cheque or EPS (Electronic Payment Services), Octopus, FPS (Faster Payment System) or in cash upon submission of the application. If the fee is paid by cheque, the cheque should be crossed and issued in Hong Kong Dollars payable to “Companies Registry”.

If the application is made in paper form and delivered by post, the fee should be paid by cheque only.

For one-time application for disclosure of WI / PI (electronic or paper application), a report on the selected data subject containing the WI / PI (“WI / PI Report”) will be sent to the applicant at the email address provided by the applicant in the application.

For the application for disclosure of WI / PI through a User Account, applicant can log in his/her User Account and download the WI / PI Report using the function “Download Ordered Items”.

Designated types of specified persons or their authorised representative(s) can apply for subscription to the WI / PI Search Services under the e-Services Portal for their User Accounts so that they can apply for disclosure of the WI / PI electronically on 24-hour basis seven days a week through their User Accounts.

Designated types of specified person being a natural person can apply for disclosure of WI / PI electronically through his/her User Account which has subscribed to the WI / PI Search Services.

Designated types of specified person not being a natural person cannot apply for disclosure of WI / PI through its User Account. After subscription to the WI / PI Search Services for its User Account, it needs to apply for its authorised representative who must be an individual to subscribe to the WI / PI Search Services so that the authorised representative can apply on its behalf for the disclosure of the WI / PI through his/her User Account. The designated types of specified person not being a natural person can log into its User Account to manage the subscription to the WI / PI Search Services of its authorised representatives.

To manage the subscription of WI / PI Search Services of their authorised representatives, the designated types of specified person not being a natural person should log in its User Account and select “Authorised Representative (Access to WI / PI)” on the page of “User Account Maintenance”.

The designated types of specified persons who / which can apply for subscription to the WI / PI Search Services under the e-Services Portal are–

• a liquidator;
• a trustee in bankruptcy;
• a public officer or public body;
• a person specified in the Schedule to the Companies (Residential Addresses and Identification Numbers) Regulation;
• a solicitor or foreign lawyer;
• a certified public accountant (practising); and
• a financial institution or designated non-financial businesses and professions.

Yes.  However, you will need to follow some steps during your first login to the new e-Services Portal of the Companies Registry (“the Registry”).  The step-by-step demonstration on migration of existing Special Account to the Registry’s new e-Services Portal has been uploaded to the Registry’s website (www.cr.gov.hk) under the “Electronic Services > e-Services Portal > Demonstration” section”.

Application for subscription to the WI / PI Search Services must be made electronically.

If the specified person has already had a User Account, he/she/it can log into his/her/its User Account and select “Subscribe services” on the page of “User Account Maintenance” to make the application.

If the specified person does not have a User Account, he/she/it should click the button “Register Now” on the landing page of the e-Services Portal to register for a User Account and subscribe to the Services. Supporting documents in PDF format are required to be uploaded before submission of the application.

The designated type of specified person other than a natural person can apply electronically for its authorised representative to subscribe to the WI / PI Search Services through its User Account which has subscribed to the WI / PI Search Services.

The designated type of specified person should log in to its User Account and select “Access to WI / PI > Access to Withheld Information / Protected Information > Apply for Subscription to Access to Withheld Information / Protected Information Service for Authorised Representatives” from the menu bar to make the application. Certified true copy of the supporting documents in PDF format are required to be uploaded before submission of the application.

In respect of the application for subscription to the WI / PI Search Services for a User Account of a specified person, the supporting documents in general include:

(i) the identification documents of the applicant;
(ii) the evidence of the capacity of the applicant as one of the designated types of specified persons; and
(iii) if the applicant is not a natural person, the authorisation document issued by the applicant to authorise a natural person to make the application.

In respect of the application for the authorised representative of a specified person not being a natural person to subscribe to the WI / PI Search Services, the supporting documents in general include:

(i) the identification document of the authorised representative; and
(ii) the authorisation letter issued by the applicant to authorise the natural person authorised representative to apply for WI / PI on its behalf in future.

Please refer to the information pamphlet “Additional Documents for the Application for Disclosure of Withheld Information / Protected Information” for details of the supporting documents.

Certified true copy of the supporting documents in PDF format should be uploaded before the electionic application is submitted.

Alternatively, applicant may choose to present the original supporting documents in person to the Companies Registry. Applicant may bring the original documents to the e-Services Centre of the Companies Registry on the 13th floor, Queensway Government Offices, 66 Queensway, Hong Kong for checking. Applicant should also provide the officer at the e-Services Centre with the Order Number of the relevant application.

If the supporting documents are submitted in photocopy, they should be certified as true copy by:

(a) a notary public practising in Hong Kong;
(b) a solicitor practising in Hong Kong;
(c) a certified public accountant (practising) within the meaning of section 2 of the Accounting and Financial Reporting Council Ordinance (Cap. 588);
(d) an officer of the court in Hong Kong who is authorized by law to certify documents for any judicial or other legal purpose;
(e) a professional company secretary practising in Hong Kong;
(f) a consular officer of applicant’s home country, in case the applicant is a non-Hong Kong resident or an entity not registered in Hong Kong; or
(g) the authority or body which issues the document.

No.  The certification of identification documents cannot be self-serving.  Please arrange to have the copy of your identification document certified by another person specified in the answer to Q31 above.

A specified person not being a natural person can apply up to 15 such subscriptions through its User Account.

However, specified person other than a natural person may consider opening separate User Accounts for its branches / sub-offices if it needs to manage more than 15 authorised representatives.

No.  A specified person not being a natural person can only appoint a natural person as its authorised representative for obtaining WI / PI.

No.  A natural person can only act as an authorised representative of one specified person not being a natural person.

No fee is required for subscribing to the WI / PI Search Services for a User Account.

After the electronic application for subscription to the WI / PI Search Services for a User Account has been submitted, an acknowledgement containing the Order No. will be displayed on the screen. Applicant can select the Print function to print the acknowledgement. An email will also be sent to the applicant to acknowledge the submission of the application.

If the application for subscription to the WI / PI Search Services by a specified person for his/her/its User Account is approved, the Companies Registry will issue an email to the applicant at the email address of the applicant provided in the application informing him/her/it of the result. A separate email containing the activation link of the User Account will also be issued for the newly opened User Account.

For the application for subscription to the WI / PI Search Services for the authorised representative of a specified person other than a natural person, the Companies Registry will send an email to the applicant notifying the result of the application. The Companies Registry will also send the activation ID and token to the authorised representative at the email address provided. If the authorised representative has already had a User Account, he/she should log into his/her User Account and select “Subscribe services” on the page of “User Account Maintenance” to activate his/her subscription using the activation ID and token. If the authorised representatives does not have a User Account, he/she should click the button “Register Now” on the landing page of the e-Services Portal to register for a User Account. He/she will be required to enter the activation ID and token to activate his/her subscription as an authorised representative during the application process.

If the application requires further information or clarification from the applicant or the application is not approved, the Companies Registry will contact the applicant separately.

The specified person can access its monthly statements through its User Account. The monthly statements will set out the types of transactions made by its authorised representative(s) and the fees paid for obtaining WI / PI during the preceding month.

The specified person can log in its User Account to select “Authorised Representatives (Access to WI / PI)” on the page of “User Account Maintenance” to terminate the authorised representative’s subscription to the WI / PI Search Services.

The User Account holder must forthwith notify the Registrar of Companies (“the Registrar”) the cessation of being any one type of such specified persons and must cease to use the User Account to apply for disclosure of WI / PI in the capacity of the specified person which has been ceased. The corresponding WI/PI Search Services subscribed for the User Account(s) of the authorised representative(s) (“ARUAs”) in respect of such type of specified persons, if any, shall also cease to be used immediately. The User Account holder must also terminate the subscription to the WI / PI Search Services of the ARUAs (if any) as soon as possible.

Yes.  The holder of the User Account must forthwith notify the Registrar of the cessation and must cease to apply for disclosure of WI / PI through the User Account.  The holder should log into the User Account and select “Subscribe Service” on the page of “User Account Maintenance” to unsubscribe the WI / PI Search Services.   For the situation of the WI / PI Search Services being the only subscribed service type of the User Account, the holder should select “Close User Account” on the same page instead to close the account.  Before unsubscribing the services or closing the account, the holder should terminate the subscription to services of all relevant authorised representative(s).