What if a director is not in Hong Kong? Is video signing required, or must it be signed in person?

Latest Rules and Practical Solutions (Starting 2026 3)

📘 Gongshitong · Global Notarization & Authentication

Many directors of Hong Kong companies are based in mainland China or overseas. Their primary concern is: when obtaining notarization from a Chinese Notary Public for use in the mainland, must they appear in person to sign? Is video signing still an option?

📅 From 2026/3/20 onwards ⚖️ Stricter regulations ✈️ In-person interviews required

Starting from 2026/3/20, the rules have tightened significantly.For the vast majority of ordinary Hong Kong companies, documents reflecting corporate will—such as board resolutions, shareholder resolutions, and powers of attorney—must be signed in person by directors before a Commissioner for Oaths in Hong Kong. Remote video witnessing and "authorized third-party signing" models are no longer accepted.

Here are the latest rules and viable solutions clearly explained.

I. Key Updates to the Latest Rules

China Legal Services (Hong Kong) Co., Ltd. and the Association of Entrusted Notaries have jointly revised audit requirements to strengthen authenticity verification and prevent forged authorizations and false documents.

✅ Situations Requiring In-Person Interview (Regular Company)

• Certificate of Board/Shareholder Resolution

• Power of Attorney (for establishing a company, making changes, opening bank accounts, litigation, asset disposal, etc., in mainland China)

• Other resolutions and authorization documents reflecting the company's decision-making authority

Clear requirements:The director must personally appear in Hong Kong to sign before a Commissioner for Oaths.
❌ Remote video witnessing is not allowed
❌ Cannot be signed and confirmed by an "Authorized Person" who is not a director.

Exceptions (authorized signature by proxy may be retained)

Available only to the following five types of institutions:

• Hong Kong Statutory Bodies

• Licensed Bank in Hong Kong

• Licensed Insurance Companies in Hong Kong

• Licensed Securities Firm in Hong Kong

• Listed Companies on the Hong Kong Stock Exchange

Ordinary commercial companies (including most Hong Kong holding companies with mainland China backgrounds) generally do not qualify for exceptions.

📄 Unaffected files:
Pure documentary evidence (e.g., Certificate of Incorporation, Business Registration, Annual Return NAR1, registers of directors/shareholders) that does not require resolution endorsement can typically be processed through the standard procedure without requiring in-person director signature.

II. Practical Solutions for Directors Not in Hong Kong

Option 1Director in-person signing in Hong Kong (industry standard and most secure)

• Schedule an appointment with a Chinese commission notary in advance (recommended 5–10 business days ahead; book even earlier during peak seasons).

• Directors must bring the original identification documents (ID card/passport), Hong Kong/Macau Travel Permit (if applicable), and company seal (round or rectangular).

• Sign and stamp the documents in the presence of a notary to complete identity verification.

• After the notary issues the notarized document, it is forwarded to China France Service for stamping and further processing.

Pros:Highest compliance level; highest probability of acceptance by mainland AICs, banks, and courts.
Note:If multiple directors must sign the resolution, their physical presence may be required, depending on the resolution content and the notary's requirements.

Option 2The sole director must confirm in person in Hong Kong (applicable to the simplified version).

• For simplified "Resolution of the Sole Director/Shareholder" documents used in select pilot provinces/cities, directors may first execute a written resolution independently. Subsequently, a director (or the sole director) must personally travel to Hong Kong to sign a confirmation letter before a notary public, verifying the authenticity and validity of the resolution.

• Whether this method is acceptable must be confirmed in advance with the specific notary and the document-receiving unit in mainland China.

Option 3Prioritize primary qualification documents

• If the applicant only requires corporate qualification documents (CI, BR, NAR1, etc.) without resolutions or authorizations, you may proceed with notarization of documentary evidence directly; no board member attendance is required.

• Many setup or modification scenarios can first confirm whether to accept this streamlined path.

❌ Not recommended:
• Remote video signing (largely infeasible for standard companies under new regulations)
• Arbitrary authorization for non-directors to sign (high risk of rejection)
• Using outdated or unupdated authorization arrangements

III. Essential Preparations and Recommendations Before You Begin

📌

Confirm file type— Confirm with mainland document users (Market Regulation Administration, banks, or courts) whether resolution documents are required or if proof of legal entity status alone suffices.

📅

Appointment & ItineraryAppointment volume has increased after the new regulations. We recommend contacting a notary early to secure your appointment slot and allowing extra buffer time for entry and travel.

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Prepare materials— Original director ID, company seal, latest corporate documents (CI, BR, NAR1, etc.), and drafted resolutions or authorization texts (available for pre-review).

👥

Multiple Directors— If all or some directors need to sign, coordinate schedules in advance. Some notaries allow partial signing sessions, subject to confirmation.

⏱️

Time & CostThe in-person interview is typically quick, but the full process—including scheduling and document transfer—requires adequate lead time. Expedited service is available upon inquiry.

IV. Special Reminder

• New rules take effect immediately with no transition period.

  Continuing to use the old remote or proxy signing methods may result in your documents being rejected during CN-FR server review or when used within mainland China.

• Notarization procedures may vary slightly by notary. We recommend contacting a certified Chinese commissioner directly, explaining your company's situation and intended use to receive a tailored solution.

• Directors no longer being in Hong Kong is no longer a barrier, but expectations and schedules must be adjusted under the new rules. Plan ahead to achieve full compliance in one go—this is far more efficient than fixing issues afterward.

If your company has specific notarization needs (establishment, modification, account opening, or litigation), provide the document type and director details to a professional agency for guidance on the optimal path.

📌 This article is based on adjustments made by China Legal Services (Hong Kong) Co., Ltd. and the Association of Chinese Entrusted Notaries starting in 3 of 2026.Specific implementation is subject to the notary's latest requirements and the regulations of the document-using entity in mainland China. Please verify the latest rules before proceeding.