Hong Kong

Hong Kong has no comprehensive AI legislation and is not close to one, but its regulators are active. The Digital Policy Office publishes an Ethical AI Framework and a Generative AI Technical and Application Guideline, the privacy commissioner has a model framework for AI and personal data, and the Monetary Authority and Securities and Futures Commission actively supervise AI use in financial services, where the real compliance pressure sits.

Key points

• No comprehensive AI statute or published plan for one.
• The PCPD's Model Personal Data Protection Framework for AI (2024) is the reference standard for AI touching personal data.
• The Digital Policy Office's generative AI guideline gives practical direction to developers, providers, and users.
• HKMA and SFC supervision makes financial services the most regulated AI context in the territory.

Laws and instruments

Timeline

• 2021 onward
  HKMA and SFC issue AI and generative AI supervisory expectations for financial services.
• 2024
  PCPD model framework for AI and personal data.
• April 2025
  Digital Policy Office generative AI technical and application guideline.

Who it applies to

No AI-specific statutory duties. Binding exposure runs through the privacy ordinance and, for financial firms, supervisory expectations that function as requirements in practice.

Penalties

PDPO enforcement for data-protection breaches; supervisory action for regulated financial institutions.

Common questions