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uid: T-210 title: Statutory registers β€” find out where they are kept and hold a copy status: todo area: compliance created: 2026-09-14 owner: girafeev1 assignee: unassigned related: T-209

T-210 β€” The company's statutory registers are not in the Drive

Why (owner, 2026-09-14)

Raised by the Drive audit of 2026-08-24 and parked deliberately by the owner: "remember it, and we'll work on it in a later time." This task exists so it is not forgotten.

The finding

A scan of the whole ERL shared drive found no Register of Members, Register of Directors, Register of Company Secretaries, and no Significant Controllers Register. The only files matching "Register" are accounting ledgers the app itself produces (ERL_Register_Invoice_*, ERL_Register_WOPC_*, ERL_Register_Receipt_* and so on) β€” those are bookkeeping output, not statutory registers.

Under the Companies Ordinance a Hong Kong company must keep these, and the Significant Controllers Register must be kept at the registered office or another designated place, with a designated representative appointed.

What this most likely means

Very often the corporate services provider holds the registers and the client never receives a copy. That is perfectly normal and not a breach in itself β€” but the company should know where they are, who the designated representative is, and hold a scan.

What to do when this is picked up

  1. Ask the company secretary / corporate services provider where the registers are kept and who the designated representative for the SCR is.
  2. Get a scan of each.
  3. File them under the Companies Registry branch of 90. Governmental & Compliance β€” the Drive audit proposes 91-D. Statutory Registers for exactly this.

Not started. No code involved.