Companies Registry Launches Inspection Phase
Phase 3 of the New Inspection Regime commenced, withholding sensitive personal data and requiring TCSPs to apply as specified persons.
On December 27, 2023, Phase 3 of the New Inspection Regime under the Companies Ordinance (Cap. 622) officially commenced, accompanied by Companies Registry External Circular No. 8/2023. This statutory milestone introduced fundamental procedural adjustments for Trust and Company Service Providers (TCSPs) conducting Customer Due Diligence (CDD) and corporate secretarial filings across Hong Kong.
Under Phase 3, data subjects—such as company directors and company secretaries—may apply to the Registrar to withhold their usual residential addresses and full identification numbers contained in registered documents from public inspection. In response, the public register replaces these details with correspondence addresses and partial identification numbers. To perform statutory CDD obligations under Schedule 2 of the AMLO, TCSPs must formally apply to the Companies Registry as “Specified Persons” to access withheld and protected data.
Concurrently, the Companies Registry fully implemented the Unique Business Identifier (UBI) across all entity types and launched its revamped e-Services Portal on the same day. Corporate secretarial teams must adapt internal workflows to ensure their staff hold verified e-Services user accounts to retrieve complete, unabridged company extracts. Relying on basic public searches is no longer sufficient for institutional-grade beneficial ownership verification.