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Hong Kong Regulatory Crosswalk

Verification required. This page was compiled on 25 October 2026. Rows HK1, HK2, HK3, HK8 and HK9 were checked that day against the HKMA's and the government's own documents and are tagged [Verified]. Every other claim is tagged [Reported], [Recalled], [Conflict] or [Unverified] as explained on the section home page. Check the primary text before relying on any of them. This is not legal advice.

One row per instrument in the Hong Kong AI Regulatory Hub, with the wiki controls that relate to it and its verification status. The last column holds the primary URL and the date it was retrieved, for the rows that have been checked. The HKMA guidance is also mapped principle by principle further down this page.

The same data is available as a CSV file for GRC tooling: crosswalk.csv.

Legal force sorts each row under one of seven labels, so that law is not mistaken for guidance or for a voluntary framework. The label is this wiki's reading of the sources and carries the same verification caveat as the rest of the row.

Label Meaning
Binding law Enacted law or regulation that applies generally in the jurisdiction, including provisions that start on a later date.
Binding in scope Binding only on a sector, a free zone, a state or province, or public bodies.
Guidance Published by a government or regulator, and not binding in itself.
Voluntary A standard, code or framework that an organization chooses to adopt.
Proposed A bill, draft or consultation, or a proposal that lapsed. It is not law.
Context A policy, authority, programme or summary row that sets no rule.
Unclear The sources used do not settle whether it binds.
ID Instrument Legal force Type / status Wiki controls Verification tag To verify Primary URL and retrieval date
HK1 HKMA Supervisory Guidance for Responsible Adoption of Artificial Intelligence (15 Oct 2026) Guidance Supervisory expectations for authorized institutions, applied proportionately; no deadline ("in a timely manner") AI-CTRL-012; AI-CTRL-045; AI-CTRL-011; AI-CTRL-037; AI-CTRL-025; AI-CTRL-014; AI-CTRL-041 Verified Circular reference number HKMA: Annex A, retrieved 25 Oct 2026
HK2 HKMA High-level Principles on Artificial Intelligence (1 Nov 2019) Context Superseded by HK1 on 15 Oct 2026 AI-CTRL-012 Verified Whether the HKMA register still lists it as current HKMA: Annex A (supersession statement), retrieved 25 Oct 2026
HK3 HKMA circular: Consumer Protection in respect of Use of Generative Artificial Intelligence (19 Aug 2024) Guidance Customer-facing generative AI; human-in-the-loop in the early stage AI-CTRL-045; AI-CTRL-041 Verified The circular's own text (only its description in HK1 footnote 3 was read) HKMA: Annex A, footnote 3, retrieved 25 Oct 2026 (as cited in HK1)
HK4 HKMA consumer protection circular on big data analytics and AI (5 Nov 2019) Guidance Consumer protection for AI-based products; disclosure and opt-out expectations continue under HK1 AI-CTRL-041 Reported Title, date and text
HK5 SFC circular to licensed corporations on generative AI language models (12 Nov 2024) Guidance Four core principles; investment advice and research treated as high-risk; notification to the SFC for high-risk use (reported) AI-CTRL-012; AI-CTRL-011; AI-CTRL-034; AI-CTRL-005; AI-CTRL-014 Reported The circular text and any update
HK6 PCPD Artificial Intelligence: Model Personal Data Protection Framework (11 Jun 2024) Guidance Not law; four areas for organisations that buy, deploy and operate AI handling personal data AI-CTRL-013; AI-CTRL-012; AI-CTRL-045 Reported The framework text
HK7 Personal Data (Privacy) Ordinance (Cap. 486) Binding law Binding law AI-CTRL-013; AI-CTRL-017 Recalled Provisions relevant to AI
HK8 GenA.I. Sandbox++ (HKMA, SFC, Insurance Authority, MPFA; 5 Mar 2026) Context Programme None Verified Cohort dates Hong Kong Government press release, retrieved 25 Oct 2026
HK9 HKMA discussion paper on agentic AI governance Proposed Announced 15 Oct 2026; not yet published AI-CTRL-006; AI-CTRL-025 Verified Publication and content HKMA press release, retrieved 25 Oct 2026 (announcement only)

HKMA guidance on responsible AI adoption: principle crosswalk

The HKMA issued its Supervisory Guidance for Responsible Adoption of Artificial Intelligence on 15 October 2026, as Annex A to a circular to authorized institutions. It supersedes the HKMA's High-level Principles on Artificial Intelligence of 1 November 2019 and groups nine principles under three pillars: Accountability (1 to 3), Resilience (4 to 6) and Trust (7 to 9). It was read on 25 October 2026, and the mapping below is this wiki's.

Point What the guidance says
Who it applies to Authorized institutions, applying the principles proportionately and using existing governance where appropriate
When No fixed date. Institutions should uplift their policies, procedures and controls in a timely manner
Read with The HKMA report on practical insights from the second cohort of the GenAI Sandbox, and other supervisory requirements

Coverage shows how far the wiki covers the expectation: Direct (a wiki control addresses it) or Partial (the last column says what is missing).

Principle Expectation Wiki controls Test cases and templates Coverage What the wiki does not cover
1 Board and senior management accountability: the board approves an AI strategy with the approach and risk appetite; roles across the three lines for approval and monitoring; regular review by senior management AI-CTRL-012, AI-CTRL-037 TC-L02-005, TC-L02-024, TC-L01-003; HK-T1 Partial The wiki has no control or test case on board understanding of AI or on quantitative risk appetite measures
2 Use-case owners and human oversight: a named owner for each use case; in-the-loop, on-the-loop or in-command oversight with risk-based triggers; reviewers able to challenge, override or stop; oversight tested AI-CTRL-045, AI-CTRL-023, AI-CTRL-011 TC-L01-003, TC-L01-012, TC-L03-040, TC-L03-041; HK-T1 Direct
3 Inventory: an up-to-date inventory of approved use cases including third-party and embedded AI, with standard attributes; unlisted AI restricted; shadow AI controlled AI-CTRL-011, AI-CTRL-001 TC-L01-001, TC-L01-004, TC-L01-008, TC-L04-001; HK-T1 Direct
4 Risk-commensurate management: materiality and risk assessment sets the review depth; senior sign-off, independent validation and adversarial testing for material cases; end-to-end testing; tailored monitoring; fallback, recovery and a kill switch or equivalent; auditable records and outcome tracing AI-CTRL-011, AI-CTRL-037, AI-CTRL-033, AI-CTRL-034, AI-CTRL-038, AI-CTRL-009, AI-CTRL-040, AI-CTRL-025, AI-CTRL-008 TC-L01-005, TC-L01-015, TC-L01-018, TC-L01-021, TC-L02-013, TC-L14-016; HK-T1 Partial The wiki gates release on a security review; independent statistical model validation is outside its scope
5 Risk management frameworks: data within approved parameters and PDPO compliance, contracts that stop providers training on data without authorisation, masking; third-party due diligence, contracts, monitoring, concentration and exit; layered cyber controls against data poisoning and prompt injection AI-CTRL-017, AI-CTRL-013, AI-CTRL-014, AI-CTRL-031, AI-CTRL-005, AI-CTRL-029 TC-L13-001, TC-L16-008, TC-L16-023, TC-L03-021, TC-L15-004; HK-T1 Direct
6 Resources and expertise: adequate resources and capacity; organisation-wide awareness; role-specific training AI-CTRL-044 TC-L03-038, TC-L02-022; HK-T1 Direct
7 Accountability for outputs: controls against hallucination; stronger review where customers could be materially affected; rules for withholding, referring or blocking outputs AI-CTRL-039, AI-CTRL-023, AI-CTRL-020 TC-L05-018, TC-L03-033; HK-T1 Direct
8 Explainability and transparency: document explainability and its limits; inform stakeholders of purpose, functions, limits and the basis of material outcomes; prefer more explainable arrangements AI-CTRL-041 TC-L03-029, TC-L03-003; HK-T1 Direct
9 Ethical use and fair treatment: no unfair bias; monitoring and sampling of customer-affecting outputs; clarification, review and redress; tell consumers about AI use and its risks before service; existing disclosure and opt-out expectations continue AI-CTRL-041, AI-CTRL-013 TC-L03-031, TC-L03-032, TC-L03-008; HK-T1 Direct

Of the nine principles, seven are a direct match and two are partial. The partial ones are board understanding of AI with quantitative risk appetite, and independent model validation, the same two gaps found for the MAS Guidelines.

The same mapping is available as a CSV file: hkma_ai_guidance.csv.