AI regulation in Hong Kong: laws & policy (2026)

Legal framework

No 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

Key points: artificial intelligence in Hong Kong

1. 01No horizontal AI statute; existing-law approach

   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.

   info.gov.hk info.gov.hk

2. 02PCPD Model Personal Data Protection Framework for AI

   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'.

   pcpd.org.hk pcpd.org.hk

3. 03Digital Policy Office Generative AI Guideline (four-tier risk model)

   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 — but as guidance, not binding law.

   info.gov.hk digitalpolicy.gov.hk

4. 04Financial-sector Policy Statement (dual-track approach)

   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' — promoting AI adoption in finance while requiring institutions to manage cybersecurity, IP and privacy risks with human oversight and a risk-based governance framework.

   info.gov.hk digitalpolicy.gov.hk

5. 05GenA.I. Sandbox++ and joint financial-regulator circulars

   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.

   hkma.gov.hk apps.sfc.hk hkma.gov.hk

6. 06Copyright Ordinance amendment for AI

   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.

   info.gov.hk twobirds.com

Timeline of decisions

1. 5 Mar 2026Guidance · official
   Regulators launch GenA.I. Sandbox++ across financial sectors

   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

2. 15 Oct 2025Guidance · official
   HKMA announces second cohort of GenA.I. Sandbox

   The 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

3. 15 Apr 2025Guidance · official
   Digital Policy Office releases GenAI Technical and Application Guideline

   The 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

4. 31 Mar 2025Guidance · official
   PCPD publishes Checklist on Use of Generative AI by Employees

   The 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

5. 19 Dec 2024Guidance · official
   HKMA announces inaugural cohort of GenA.I. Sandbox

   Run 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

6. 12 Nov 2024Guidance
   SFC circular on use of generative AI language models

   The 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)

7. 28 Oct 2024Guidance · official
   FSTB Policy Statement on Responsible Application of AI in the Financial Market

   The 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

8. 19 Aug 2024Guidance · official
   HKMA circular on consumer protection in use of generative AI

   The 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

9. 1 Jul 2024Guidance · official
   Digital Policy Office issues Ethical Artificial Intelligence Framework

   The 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

10. 11 Jun 2024Guidance · official
    PCPD issues 'AI: Model Personal Data Protection Framework'

    The 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

11. 18 Aug 2021Guidance · official
    PCPD publishes Guidance on Ethical Development and Use of AI

    The 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

12. 1 Nov 2019Guidance · official
    HKMA issues High-level Principles on Artificial Intelligence

    The 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.

    HKMA

Sources

1. 1.info.gov.hk/gia/general/202603/18/P2026031800419.htm
2. 2.info.gov.hk/gia/general/202604/22/P2026042200319.htm
3. 3.pcpd.org.hk/english/news_events/media_statements/press_20240611.html
4. 4.pcpd.org.hk/english/artificial_intelligence/index.html
5. 5.info.gov.hk/gia/general/202504/15/P2025041500227.htm
6. 6.digitalpolicy.gov.hk/en/our_work/data_governance/policies_standards/ethical_ai_framework/d
7. 7.info.gov.hk/gia/general/202410/28/P2024102800154.htm
8. 8.digitalpolicy.gov.hk/en/our_work/data_governance/policies_standards/policy/
9. 9.hkma.gov.hk/eng/news-and-media/press-releases/2026/03/20260305-3/
10. 10.apps.sfc.hk/edistributionWeb/gateway/EN/circular/intermediaries/supervision/doc?r
11. 11.hkma.gov.hk/eng/news-and-media/press-releases/2026/08/20260827-3/
12. 12.twobirds.com/en/capabilities/artificial-intelligence/ai-legal-services/ai-regulato