Major Changes to Notarisation of Hong Kong Companies: Directors Must Attend In Person, Flexibility Tightened
On 20 March 2026, the China Notary Association Limited issued Circular No. 1599, introducing significant changes to the notarisation of Hong Kong company documents, particularly regarding the use of “authorised persons” to sign company resolutions on behalf of directors or shareholders.
The circular took immediate effect with no transitional period.
Core Change
The use of “authorised persons” to sign written confirmations before a notary is now strictly limited.
Common practices such as “director unavailable, authorised person signs instead” or “video witnessing” are no longer generally permitted.
This aims to prevent fraudulent use of the notarisation system.
1. Key Highlights
Five Types of Institutions May Still Use an “Authorised Person”
Only the following five categories of institutions, through their employed staff, may continue to use an authorised person to sign before a notary:
Hong Kong statutory bodies
Licensed banks in Hong Kong
Licensed insurance companies in Hong Kong
Licensed securities firms in Hong Kong
Companies listed on the Hong Kong Stock Exchange
The authorised person must be an employee of the institution, and their job title must be clearly stated in the document.
All Other Companies Must Obtain Prior Approval
If your company does not fall into the above five categories but still wishes to use an authorised person to sign notarised documents (such as Company Director/Shareholder Resolution Proof or Power of Attorney), the process has fundamentally changed:
The notary must first write to China Legal Services (Hong Kong) Limited to apply for approval,
Providing full reasons, practical necessity, and verification steps taken.
Only after approval from China Legal Services and the Association can the notarisation proceed.
Without prior approval, authorised person signing is no longer possible.
2. Potential Impact on You
In-Person Signing Returns: For most ordinary Hong Kong companies (non-listed, non-licensed financial institutions), directors or shareholders must now appear in person before a notary to sign documents. Flexible arrangements like video witnessing or authorised person signing are largely withdrawn.
Longer Processing Times: If you need to apply for authorised person signing, the additional approval process will significantly extend the notarisation timeline.
Stricter Scrutiny: Notaries will apply much stricter checks on the authorised person’s identity, the authenticity of authorisation, and the background of the documents.
3. Our Recommendations
If possible, arrange for decision-makers (directors/shareholders) to travel to Hong Kong and sign in person before a notary.
If in-person attendance is genuinely difficult, please contact us well in advance so we can assist with the approval application and allow sufficient time for review.
We will continue to monitor further practical guidance from the Association and China Legal Services and keep you updated.
If you have any questions or if your ongoing notarisation may be affected, please feel free to reach out. We are happy to advise on the best approach for your situation.
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