HKSAR Passport's compliance of ICAO Doc 9303

Claxton made this Access to Information request to Immigration Department

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Dear Immigration Department,

I am writing to request access to information under the Code on Access to Information regarding the compliance of the Hong Kong Special Administrative Region (HKSAR) Electronic Passport with the International Civil Aviation Organization (ICAO) Document 9303, Part 4, specifically concerning the placement of the holder's signature.

Background
ICAO Doc 9303, Part 4, Section 3.2.1 specifies that Field 18 (the holder's signature or usual mark) is a mandatory data element that "shall normally be placed in Zone IV of the MRP data page." The specification permits two alternative locations: Zone VI on the reverse side of the data page, or the page adjacent to the data page. Section 3.2.4 further states that Zone IV "shall be present either on the data page or on an adjacent page.". Section 4.1.1 also prescribes Holder's signature or usual mark as "Mandatory".

The current HKSAR Electronic Passport does not include the holder's signature on the data page, the reverse of the data page, or the page adjacent to the data page. Instead, a space for the holder's manual signature is provided on the last page of the passport book, alongside the emergency contact information section. This placement does not appear to correspond to any of the three locations permitted under Doc 9303, Part 4.

By contrast, passports issued by the Mainland (People's Republic of China) and the Macao Special Administrative Region include the holder's signature on the data page, in apparent conformity with the ICAO specification.

Information Requested
I respectfully request access to the following information:

1. Compliance status: Does the Immigration Department consider the current HKSAR Electronic Passport to be fully compliant with ICAO Doc 9303, Part 4, with respect to the inclusion and placement of the holder's signature (Field 18, Zone IV)? If so, please identify the specific provision(s) of Doc 9303 that the Department relies upon to support this position.

2. Design rationale: What was the rationale or circumstances behind the decision to not place the holder's on the data page, the reverse of the data page, or the page adjacent to the data page? Please provide any records, minutes of meetings, internal memoranda, policy papers, or correspondence relating to this design decision, including any consideration of ICAO Doc 9303 requirements during the design process for any version of the HKSAR Electronic Passport.

3. ICAO notifications: Has the Immigration Department, the Government of the HKSAR, or the Government of the People's Republic of China (on behalf of the HKSAR) ever received any notification, communication, audit finding, or inquiry from ICAO (including from the ICAO Implementation and Capacity Building Working Group, the Technical Advisory Group on Machine Readable Travel Documents, or any other ICAO body) regarding the HKSAR passport's compliance with the signature placement requirements of Doc 9303, Part 4? If so, please provide copies of such communications and the Department's responses.

4. Traveller impact: Does the Immigration Department hold any records, reports, complaints, or statistics regarding cases in which HKSAR passport holders have encountered difficulties at foreign border control points, airline check-in, or other travel-related processes due to the absence of a signature on or adjacent to the data page of the HKSAR passport? If so, please provide such records or, at minimum, aggregate statistics on the number and nature of such cases.

Yours faithfully,
Claxton

Dear Claxton,

I refer to the application for access to information under the captioned
reference received by us on 22 March 2026.
Please be informed that the application is under processing. According to
paragraph 1.16 of the Code on Access to Information, our department will
inform you of the latest progress of the case separately on or before 11
April 2026.

Best regards,

(Mr C H Ho)
for Director of Immigration
Records and Data Management Section
Tel : 2829 3554
Fax : 3101 0512
Email : [1][Immigration Department request email]

From: "Claxton" <[FOI #1568 email]>
To: "FOI requests at Immigration Department" <[Immigration Department request email]>
Date: 22/03/2026 16:58
Subject: Freedom of Information request - HKSAR Passport's
compliance of ICAO Doc 9303
Sent by: [FOI #1568 email]

══════════════════════════════════════════════════════════════════════════

Dear Immigration Department,

I am writing to request access to information under the Code on Access to
Information regarding the compliance of the Hong Kong Special
Administrative Region (HKSAR) Electronic Passport with the International
Civil Aviation Organization (ICAO) Document 9303, Part 4, specifically
concerning the placement of the holder's signature.

Background
ICAO Doc 9303, Part 4, Section 3.2.1 specifies that Field 18 (the holder's
signature or usual mark) is a mandatory data element that "shall normally
be placed in Zone IV of the MRP data page." The specification permits two
alternative locations: Zone VI on the reverse side of the data page, or
the page adjacent to the data page. Section 3.2.4 further states that Zone
IV "shall be present either on the data page or on an adjacent page.".
Section 4.1.1 also prescribes Holder's signature or usual mark as
"Mandatory".

The current HKSAR Electronic Passport does not include the holder's
signature on the data page, the reverse of the data page, or the page
adjacent to the data page. Instead, a space for the holder's manual
signature is provided on the last page of the passport book, alongside the
emergency contact information section. This placement does not appear to
correspond to any of the three locations permitted under Doc 9303, Part 4.

By contrast, passports issued by the Mainland (People's Republic of China)
and the Macao Special Administrative Region include the holder's signature
on the data page, in apparent conformity with the ICAO specification.

Information Requested
I respectfully request access to the following information:

1. Compliance status: Does the Immigration Department consider the current
HKSAR Electronic Passport to be fully compliant with ICAO Doc 9303, Part
4, with respect to the inclusion and placement of the holder's signature
(Field 18, Zone IV)? If so, please identify the specific provision(s) of
Doc 9303 that the Department relies upon to support this position.

2. Design rationale: What was the rationale or circumstances behind the
decision to not place the holder's on the data page, the reverse of the
data page, or the page adjacent to the data page? Please provide any
records, minutes of meetings, internal memoranda, policy papers, or
correspondence relating to this design decision, including any
consideration of ICAO Doc 9303 requirements during the design process for
any version of the HKSAR Electronic Passport.

3. ICAO notifications: Has the Immigration Department, the Government of
the HKSAR, or the Government of the People's Republic of China (on behalf
of the HKSAR) ever received any notification, communication, audit
finding, or inquiry from ICAO (including from the ICAO Implementation and
Capacity Building Working Group, the Technical Advisory Group on Machine
Readable Travel Documents, or any other ICAO body) regarding the HKSAR
passport's compliance with the signature placement requirements of Doc
9303, Part 4? If so, please provide copies of such communications and the
Department's responses.

4. Traveller impact: Does the Immigration Department hold any records,
reports, complaints, or statistics regarding cases in which HKSAR passport
holders have encountered difficulties at foreign border control points,
airline check-in, or other travel-related processes due to the absence of
a signature on or adjacent to the data page of the HKSAR passport? If so,
please provide such records or, at minimum, aggregate statistics on the
number and nature of such cases.

Yours faithfully,
Claxton

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Dear Claxton,

I refer to the application for access to information under the captioned
reference received by us on 22 March 2026.
Please be informed that the application is under processing. According to
paragraph 1.18 of the Code on Access to Information, our department will
inform you of the latest progress of the case separately on or before 11
May 2026.

Best regards,

(Miss K M Lau)
for Director of Immigration
Records and Data Management Section

From: RM/IMMD/HKSARG
To: "Claxton" <[索取資料要求電郵#1568]>
Date: 2026/03/27 下午 05:08
Subject: Re: Freedom of Information request - HKSAR Passport's
compliance of ICAO Doc 9303 - Ref: RDCD-0000063-26

Dear Claxton,

Best regards,

(Mr C H Ho)
for Director of Immigration
Records and Data Management Section
Tel : 2829 3554
Fax : 3101 0512
Email : [1][入境事務處供索取資料的電郵]

From: "Claxton" <[索取資料要求電郵#1568]>
To: "FOI requests at Immigration Department" <[入境事務處供索取資料的電郵]>
Date: 22/03/2026 16:58
Subject: Freedom of Information request - HKSAR Passport's
compliance of ICAO Doc 9303
Sent by: [索取資料要求電郵#1568]