Persons holding an "office of emolument" within a government bureau or department, as well as former members of the police force, are not eligible to be appointed to the IPCC.

The former Chief Executive Leung Chun-ying, for instance, drew criticism[9] for appointing Barry Chin Chi-yung, a member of the pro-Beijing political group Silent Majority for Hong Kong, to the council.

[10] In 2017, Chief Executive Carrie Lam sought to enhance the credibility of the IPCC by appointing Anthony Francis Neoh, a heavyweight in the legal sector, as its chairman.

[9] Clifford Stott, one of five members of an expert panel recruited for the IPCC in September during the 2019–20 Hong Kong protests, has reaffirmed that the powers, capacity, and independent investigative capability of the body was not commensurate with the "standards required of an international police watchdog operating in a society that values freedoms and rights".

[11][12] According to Stott, "structural limitations in the scope and powers of the IPCC inquiry [inhibit] its ability to establish a coherent and representative body of evidence".

[13] The Court of First Instance reported on November 20 that the IPCC and the Complaints Against Police Office (CAPO) cannot effectively conduct investigation into misconduct unless new powers were given.

[14] In September 2022, Helen Yu Lai Ching-ping, an IPCC member, blamed Hong Kong's child abuse cases on "widespread" sexual and violent content on TV.

It reviewed the videos during the police's kettling of protesters into the CITIC Tower on 12 June 2019, and rebutted the report's claim that Tim Mei Avenue was unobstructed for the crowd to leave.