Artificial Intelligence ยท Hong Kong
AI regulation in Hong Kong: laws & policy (2026)
Hong Kong shaded by its artificial intelligence status
AI in Hong Kong: sectoral rules.
FrameworkNo dedicated AI statute; governance rests on existing laws (Personal Data (Privacy) Ordinance, financial services legislation, copyright, AML/CFT) supplemented by regulator- and Digital Policy Office (DPO)-issued AI guidance and sector-specific circulars
Hong Kong has no comprehensive AI law. Instead, the Government has confirmed it will continue to regulate AI through existing regimes plus targeted sectoral rules and non-binding guidance โ anchored by the Personal Data (Privacy) Ordinance (PDPO), the PCPD's Model Personal Data Protection Framework for AI (2024), the DPO's Hong Kong Generative AI Technical and Application Guideline (April 2025, updated December 2025), and financial-sector measures led by the HKMA, SFC, IA and MPFA. In March 2026 the Secretary for Justice convened a Steering Committee to lead an inter-departmental review of existing legislation to support wider AI application, but no bespoke AI bill has been introduced to the Legislative Council.
Key points
The Government's position, reiterated in LegCo answers in March 2026, is to regulate AI primarily through existing frameworks (PDPO, SFO, copyright, AML/CFT, consumer protection and common law) plus sectoral guidance, rather than a single AI code. An inter-departmental review of the legal framework was launched in March 2026 to identify gaps and consider whether bespoke legislation is needed.
On 11 June 2024, the Office of the Privacy Commissioner for Personal Data issued the 'Artificial Intelligence: Model Personal Data Protection Framework', setting recommended best practices for organisations procuring, implementing and using AI (including generative AI) in compliance with the PDPO. It builds on the PCPD's 2021 'Guidance on the Ethical Development and Use of AI'.
The DPO released the Hong Kong Generative AI Technical and Application Guideline on 15 April 2025 (updated December 2025), providing operational guidance for developers, service providers and users, and proposing a four-tier risk classification (unacceptable, high, limited, low) reminiscent of the EU AI Act โ but as guidance, not binding law.
The Financial Services and the Treasury Bureau issued the 'Policy Statement on Responsible Application of Artificial Intelligence in the Financial Market' on 28 October 2024, adopting a 'dual-track approach' โ promoting AI adoption in finance while requiring institutions to manage cybersecurity, IP and privacy risks with human oversight and a risk-based governance framework.
On 5 March 2026 the HKMA, SFC, Insurance Authority and MPFA jointly launched GenA.I. Sandbox++, expanding the HKMA/Cyberport GenAI Sandbox across banking, securities, asset management, insurance, MPF and stored-value facilities; 36 use cases from 30 institutions were selected in the first cohort announced on 27 August 2026. Regulators have also issued joint circulars on GenAI-related cyber-resilience.
Following a 2024 public consultation on AI-related copyright issues, the Government indicated an amendment bill to the Copyright Ordinance to enhance protection for AI development was to be introduced to LegCo. This is the most concrete piece of AI-driven statutory change in Hong Kong to date, targeted rather than horizontal.
Timeline - major decisions & events
The HKMA, SFC, Insurance Authority and MPFA jointly expanded the generative-AI sandbox to banking, securities, insurance, asset management and MPF, offering supervisory guidance and GPU compute for risk-controlled AI piloting. It signals a coordinated, cross-sector 'innovate-and-supervise' posture for finance.
HKMA โThe HKMA admitted a second cohort focused on 'AI vs AI' defences and deepfake-related fraud, building supervisory experience before issuing firmer expectations. It shows AI governance in banking is being developed iteratively through experimentation.
HKSAR Government / HKMA โThe DPO published a voluntary best-practice guideline for the ethical, safe and responsible development, deployment and use of generative AI, targeting developers, platform providers and users. It is the government's central cross-sector reference for GenAI and was later updated in December 2025.
HKSAR Government / Digital Policy Office โThe Privacy Commissioner issued a checklist to help organisations craft internal policies governing employee use of GenAI in compliance with the Personal Data (Privacy) Ordinance. It extends Hong Kong's AI privacy guidance from organisational deployment down to day-to-day workplace use.
PCPD โRun with Cyberport, the first sandbox cohort let banks trial generative-AI use cases under HKMA observation, informing later supervisory guidance. It marked the start of Hong Kong's structured, hands-on approach to AI in banking.
HKMA โThe Securities and Futures Commission required licensed corporations using GenAI language models to manage model risk, ensure senior-management oversight, address cyber/data risks and vet third parties, treating investment advice as a high-risk use case demanding human oversight. It set binding regulatory expectations for AI in securities markets.
A&O Shearman (reporting SFC circular) โThe Financial Services and Treasury Bureau set out a 'dual-track' approach promoting AI adoption while mitigating cybersecurity, IP and data-privacy risks across the financial sector. It is the government's overarching policy frame for AI in finance.
HKSAR Government / FSTB โThe HKMA gave authorized institutions specific GenAI expectations for customer-facing applications, including opt-out/human-intervention rights and continuous output monitoring, extending its 2019 BDAI principles. It tailored bank AI governance to generative models.
HKMA โThe DPO published a framework with ethical principles, an AI governance model, a lifecycle guide and an impact-assessment template for AI projects (initially aimed at the public sector). It anchored the government's own ethical-AI baseline.
Digital Policy Office โThe Privacy Commissioner published the Asia-Pacific region's first comprehensive AI-specific data-protection framework, guiding organisations on procuring, deploying and governing AI (including generative AI) in line with the PDPO. It is Hong Kong's flagship AI privacy-governance reference.
PCPD โThe Privacy Commissioner set out three data-stewardship values and seven internationally recognised ethical AI principles to help organisations comply with the PDPO when developing or using AI. It established the foundational ethics-by-design approach Hong Kong still follows.
PCPD โThe HKMA's circular set out twelve principles for banks adopting AI, making boards and senior management accountable for governance, explainability, data quality and risk management. It was Hong Kong's earliest sector-specific AI regulatory guidance and underpins later banking AI rules.
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