Hong Kong

Is there a specific enacted legislation regulating AI in your jurisdiction?

No

Is there a proposed legislation regulating AI in your jurisdiction?

No

Are there any guidelines/ codes of conduct/ recommendations / reports / policies in connection with AI in your jurisdiction?

• Ethical Artificial Intelligence Framework - A framework issued by Digital Policy Office which is originally developed to assist government departments in planning, designing, and implementing AI and big data analytics in their IT projects and services. It includes guiding principles, leading practices, and an AI Assessment with templates for managing benefits, impact, and risks. This framework, with some adjustments, is also applicable to other organisations for their AI and big data projects.

• Policy Statement on Responsible Application of Artificial Intelligence in the Financial Market - A statement issued by the Financial Services and the Treasury Bureau setting out the Government’s policy stance and approach towards the responsible application of AI in the
  financial market.

• Hong Kong Generative Artificial Intelligence Technical and Application Guideline - A guideline formulated by the Hong Kong Generative AI Research and Development Center on commission, providing relevant codes and practices on the use of Gen AI technologies. The guideline contains industry-specific recommendations for different sectors to consider.

• Financial Services in the Era of Generative AI: Facilitating Responsible Adoption - A report prepared by the Hong Kong Institute for Money and Financial Research which explores how Gen AI has developed and its significance for both financial service providers and regulators, including survey and interview data.

Any additional relevant news regarding AI / or anticipated future changes (e.g. white papers, policy statements about AI regulation)?

In response to a public consultation on AI-related copyright issues in 2024, an amendment bill to the Copyright Ordinance, aimed at enhancing protection for AI technology development, is set to be introduced to Legco in the first half of 2025.

Public Consultation on Copyright and Artificial Intelligence (2024) (consultation paper)

Hong Kong lawmakers raise concerns over AI safeguards for copyrighted works

Is AI specifically addressed in IP laws? Are there any guidelines / soft laws relating to AI? 

No (but see proposed amendments that are in the pipeline in the previous question).

Is AI specifically addressed in data protection laws? Are there any guidelines / soft laws relating to AI?

No, but the privacy regulator has released a number of guidelines in relation to AI.

• Guidance on the Ethical Development and Use of Artificial Intelligence - A guidance issued by PCPD to facilitate the healthy development and use of AI in HK and assist organisations in complying with the data protection provisions in their development and use of AI. 

• Artificial Intelligence: Model Personal Data Protection Framework - A model framework issued by PCPD to provide a set of recommendations on the best practices for any organisations procuring, implementing and using any type of AI systems that involve the use of personal data, which may include predictive AI and generative AI.
  
  
• Checklist on Guidelines for the Use of Generative AI by Employees - A guide published by the PCPD to help organisations develop internal policies or guidelines for employees using Gen AI tools at work for the purpose of compliance with the Personal Data (Privacy) Ordinance.
  

Who are the competent AI supervisory authorities in your jurisdiction? 

There isn't currently a dedicated supervisory authority specifically for AI in Hong Kong.

Are there any publicly known enforcement actions in relation to AI?

No, but the privacy regulator routinely conducts compliance checks with companies in Hong Kong on the development and use of AI (see below).

The Privacy Commissioner’s Office has Completed Compliance Checks on 60 Organisations Regarding How the Use of Artificial Intelligence Affects Personal Data Privacy.

The PCPD conducted a fresh round of compliance checks into 60 organisations in February 2025 regarding their use of AI systems to collect and/or use personal data.

Are there any other sector specific laws or guideline / soft laws (e.g. finance, healthcare etc.) where AI is specifically addressed?

• Consumer Protection in respect of Use of Big Data Analytics and Artificial Intelligence by Authorized Institutions - A letter issued by HKMA to all authorised institutions regarding a set of guiding principles on consumer protection aspects in respect of the use of big data analytics and artificial intelligence. 

• High-level Principles on Artificial Intelligence - A letter issued by HKMA introducing a set of high-level principles of which banks are expected to take  into account when designing and adopting their AI and big data analytics applications. 
  
   
• Generative Artificial Intelligence in the Financial Services Space - A paper issued by HKMA which provides a comprehensive overview of the role Generative AI can play in the financial sector, as well as the potential use cases and challenges that institutions should consider when integrating these technologies into their operations. 
  
   
• Use of Artificial Intelligence for Monitoring of Suspicious Activities - A letter issued by HKMA to support and accelerate the use of artificial intelligence in suspicious activity monitoring by all authorised institutions.
  
   
• Consumer Protection in respect of Use of Generative Artificial Intelligence - A letter issued by HKMA to all authorised institutions regarding a set of guiding principles in respect of use of generative artificial intelligence in customer-facing applications from consumer protection perspective.

• Circular to licensed corporations - Use of generative AI language models - A circular issued by SFC to provide guidance to licensed corporations on compliance with their regulatory obligations in the context of their adoption and use of generative artificial intelligence language models.
  
  
• Chatting about Chatbots and AI - A publication by the Insurance Authority commenting on the utility of AI-powered chatbots in the context of streamlining the process of handling insurance claims and the applicable regulatory guidelines.
  
  
• Guidance on Offering Robo-Advisor Service - A circular issued by the Mandatory Provident Fund Schemes Authority in response to the partnership between MPF approved trustees and principal intermediaries for the offering of robo-advisor services.
  
  
• Insights for Design, Implementation and Optimisation of Transaction Monitoring Systems - Guidance published by the HKMA recognising that authorized institutions can use AI to check the quality of data and improve the accuracy of transaction monitoring systems for the purposes of anti-money laundering and countering financing of terrorism.
  
  
• Manpower Management in the Age of Artificial Intelligence - Insights published by the HKMA in relation to manpower management in the age of AI, including urging the banking industry to proactively plan ahead for manpower development to adapt to the forthcoming changes brought by AI, as well as assess the impact of technological advancement and changing customer needs on the requirements of different job roles.

*Information is accurate up to 30 June 2025