Fintech in Hong Kong: Where There’s a Will, There’s a Way, or Hong Kong’s Measures To Become the Fintech Capital of Asia

by Dorsey & Whitney LLP

Dorsey & Whitney LLP

Hong Kong is putting substantial focus on financial technology, or fintech, to compete with Singapore and Tokyo as the fintech capital of Asia. In April 2015, the Hong Kong Government (the “Government”) established the Steering Group on Financial Technologies (the “Steering Group”) tasked with advising the Government on how to develop and promote Hong Kong as a fintech center. The Government budgeted over HK$17 billion (equivalent to approximately US$2 billion1) to begin building the key infrastructure to support a fintech center in Hong Kong.2 The Hong Kong Monetary Authority (the “HKMA”)3 has recently announced a series of policy initiatives to embrace technology development in Hong Kong, including setting up a "fintech innovation hub" in Hong Kong and introducing a relaxed regulatory regime for fintech in the banking sector in Hong Kong known as the "fintech supervisory sandbox" (the “FSS”).

Hong Kong’s potential

Fintech is a catch-all term used to refer to emerging digital technologies that make financial services more efficient. Fintech covers a large scope of financial services in such categories as lending, payment, money transfer, personal finance, consumer banking, equity financing, retail investment and institutional investment, and includes electronic / mobile payments, micro / peer-to-peer lending, robo-advisors / robotics, distribution of financial products, data analytics, cyber security, virtual currencies and technologies behind virtual currencies such as blockchain, crowdfunding, biometric authentication, augmented reality and other services / technologies.

Hong Kong has some strong advantages for development as Asia’s fintech center, including:

  • proximity to Mainland China;
  • presence of major banks and financial institutions;
  • comparatively cheap tech talent;
  • great internet connections;
  • special "start-up visa" for founders and key staff of start-ups allowing them to live and work in Hong Kong;
  • English as an official language and the common law legal system;
  • straight-forward accounting, tax, anti-money laundering and know-your-client regimes;
  • no regulation over virtual currencies; and
  • the Government’s support of fintech.

Hong Kong’s high cost of living and shortage of talented and skilled IT professionals and venture investors are its most noticeable downsides.

Government measures

The Government started to look closely at turning Hong Kong into a fintech center in 2015, when it set up the Steering Group. The Steering Group is tasked with advising the Government on how to develop and promote Hong Kong as a fintech center. It comprises 10 non-official members drawn from various industries and research and development (“R&D”) institutions, as well as relevant government officials and representatives from the regulatory authorities.4

The Steering Group has recently issued a report which proposed a number of recommendations to further Hong Kong’s development as a fintech center. These were mentioned in the Financial Secretary’s 2016-2017 budget speech and included the following5:

  • establishing a dedicated team under the Invest Hong Kong6 to organize international events and assist start-ups, investors and R&D institutions to establish their presence in Hong Kong;
  • promoting smart production and research led by the Hong Kong Science and Technology Parks Corporation;
  • setting aside a dedicated space of 3,000 square meters in Cyberport’s7 Smart-Space for fintech activities and rolling out a designated incubation program for 150 Fintech start-ups over the next five years;
  • arranging for 300 university students, through Cyberport, to join fintech training camps in overseas universities to gain more in-depth understanding of career prospects in the sector;
  • establishing dedicated platforms at the HKMA, the Securities and Futures Commission8 and the Office of the Commissioner of Insurance to enhance communication between regulators and the fintech community;
  • setting up, by the HKMA in partnership with the other stakeholders, a three-pronged cyber security program that comprises a cyber intelligence-sharing platform, the conduct of risk assessment and professional certification; and
  • encouraging the industry and relevant organizations to explore the application of blockchain technology in the financial services industry, with a view to developing its potential to reduce suspicious transactions and bring down transaction costs.

The Government budgeted over HK$17 billion (equivalent to approximately US$2 billion) to begin building the key infrastructure necessary to support a fintech center in Hong Kong, among other measures to facilitate the development of fintech in Hong Kong.9 The Government has also set up the Innovation and Technology Venture Fund and the Cyberport Macro Fund announced in the 2016 Policy Address.10

The Government specified that development of Hong Kong as a fintech center includes the need for the industry and relevant organizations to explore the application of blockchain technology. Blockchain technology is a technology behind the transactions of virtual currencies, most notably bitcoin. For more information on virtual currencies and bitcoin, in particular, please refer to our bitcoin-related eUpdate series which can be found here.

According to the Steering Group, Hong Kong has the potential to become a key blockchain hub through leveraging its high concentration of industry domain experts and institutions in finance, logistics and other professional services.11

HKMA’s policy initiatives

The HKMA has recently introduced a series of policy initiatives to promote technology development in Hong Kong, as it sharpens its edge to compete with Singapore and Tokyo as Asia’s fintech center. In September 2016, the HKMA announced that it launched the FSS and will set up a "fintech innovation hub", two initiatives aimed at embracing technology development to make financial transactions safer, faster and more convenient for consumers.12

The FSS is the HKMA's new regulatory regime aimed at facilitating the pilot trials of fintech and other technology initiatives of authorized institutions (i.e., banks) before they are launched on a fuller scale.13 This initiative was driven by the fact that the implementation of the fintech and other innovative technologies in Hong Kong by the banking industry requires greater flexibility to enable banks to test and refine these technologies before their formal launch. Under the FSS, the banks will be allowed to conduct a pilot trial of these technologies involving actual banking services and a limited number of participating customers without the need to achieve full compliance with the HKMA's usual supervisory requirements during the trial period. The banks, however, still need to ensure that the following requirements are observed:

  • clear scope: there must be clear definitions of the scope and phases of the trial (including the size and types of customers involved, technologies and types of banking services covered, etc.), the timing and the termination arrangements;
  • customer protection: customer protection measures must be in place to protect the interests of customers during the trial (including a proper process of selecting customers, a mechanism for timely and fair compensation of customers’ financial losses and appropriate arrangements for customers to withdraw from the trial);
  • risk management: reasonable compensating controls must be implemented to mitigate the risks arising from less than full compliance with supervisory requirements; and
  • readiness and monitoring: the systems and processes involved must be ready for the trial (i.e., they must be put through reasonable testing and other rollout preparation before the trial) and trial must be subject to close monitoring.

As the FSS is a new supervisory arrangement, the HKMA will refine the arrangement over time in the light of implementation experience and industry development. Banks intending to access the FSS are advised to get in touch with the HKMA soon. The HKMA is committed to stand ready to discuss with the banks individually the appropriate supervisory flexibility that can be made available to them within the FSS.

The HKMA also announced that it will soon, in collaboration with the Hong Kong Applied Science and Technology Research Institute (“ASTRI”), launch the “HKMA-ASTRI Fintech Innovation Hub” (the "Hub"), a new facility to support research and adoption of fintech by the industry.14

The Hub is intended to be a neutral ground for the fintech industry, a place where various stakeholders can collaborate to innovate. Industry players, such as banks, payment service providers such as SVF licensees, fintech start-ups, the HKMA, etc. can get together at this facility to brainstorm innovative ideas, try out and evaluate new fintech solutions, conduct proof-of-concept trials, and gain an early understanding of the general applicability of creative solutions for banking and payment services.

“Together with the launch of the FSS for banks, this initiative shows the HKMA's commitment to facilitate the healthy development of the fintech ecosystem in Hong Kong”, said Howard Lee, Senior Executive Director of the HKMA.15

The Hub, located at ASTRI’s office within the Hong Kong Science Park, will be supported by the technical teams and the hardware and software IT infrastructure of ASTRI. Specifically, around 200 virtual workstations connected in a segregated network segment, which can be expanded further if there is a need, will be assigned to support technology trials at the Hub. Together with the different kinds of hybrid cloud computing configurations available at ASTRI, the Hub is equipped to emulate, compare and analyze different financial services and products supported by various fintech solutions at any one time. Also, virtual private networks can be set up to connect the Hub with up to 30 external innovation facilities or developer laboratories in Hong Kong and overseas.

It is envisaged that the Hub can be used for:

  • testing solutions which require participation of multi-parties (e.g., use of the blockchain technology in supporting cross-banks financial services);
  • demonstrating fintech solutions which require substantial computing resources;
  • holding dialogues between the industry and the HKMA on emerging technologies;
  • testing solutions that may be adopted by the HKMA (e.g., the use of creative “regtech” solutions in improving the regulatory work); and
  • organizing training sessions for the industry.

The HKMA is currently finalizing details of the set-up and the mode of operation of the Hub with ASTRI, including how resources should be prioritized. The detailed arrangements are expected to be announced within the next few weeks.

1 In this eUpdate, we used the exchange rate as of October 13, 2016 which was US$1 to HK$7.76.
2 The Budget Speech for 2016-2017 available at:; “HK $17b boost for Hong Kong’s innovation and technology sector aimed at fintech startups” by Alice Woodhouse, South China Morning Post, February 24, 2016.
3 The HKMA is the government authority in Hong Kong responsible for maintaining monetary and banking stability. It was established in April 1993 by merging the Office of the Exchange Fund with the Office of the Commissioner of Banking and is de facto Hong Kong’s central bank.
4 Press release “Steering Group on Fintech releases report” dated February 26, 2016.
5 See footnotes 2 and 4 and the report of the Steering Group available at
6 The Invest Hong Kong is the department of the Government responsible for foreign direct investment which was established in July 2000 to strengthen Hong Kong’s status as the leading international business location in Asia.
7 Cyberport is a global innovation and technology hub with over 700 community members managed by Hong Kong Cyberport Management Company Limited, which is wholly owned by the Government.
8 The Securities and Futures Commission is an independent statutory body set up to regulate Hong Kong’s securities and futures markets.
9 See footnote 2.
10 The 2016 Policy Address available at:; Opening remarks by the Hong Kong Secretary for Innovation and Technology Nicholas W. Yang at the “Blockchain Strategies for Business” conference held on July 28, 2016, available at:
11 See footnote 4.
12 “HKMA embraces FinTech as it burnishes Hong Kong’s brand to compete as Asia’s financial hub” by Enoch Yiu, South China Morning Post, September 6, 2016.
13 Announcement by the HKMA regarding Fintech Supervisory Sandbox dated September 6, 2016, available at:  
14 Announcement by the HKMA regarding HKMA-ASTRI Fintech Innovation Hub dated September 6, 2016.
15 See footnote 14.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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