Hong Kong: The city's first cybersecurity law is expected to take effect on 1 January 2026

03 Apr 2025    1 minute read
Cybersecurity & Data Privacy Critical Infrastructure Cyber Security Data Privacy Cyber

In brief

On 19 March 2025, Hong Kong's Legislative Council enacted the Protection of Critical Infrastructures (Computer Systems) Bill ("Bill"), which was gazetted as the Protection of Critical Infrastructures (Computer Systems) Ordinance (Cap. 653) ("Ordinance") on 28 March 2025.

Contents

The Ordinance, which is set to take effect on 1 January 2026, aims to enhance cybersecurity standards in relation to the providers of essential services in eight sectors deemed crucial to the normal functioning of the society, namely energy, information technology, banking and financial services, air transport, land transport, maritime transport, healthcare services, and telecommunications and broadcasting services, as well as critical societal or economic activities (such as those managing major sports and performance venues, as well as research and development parks) in Hong Kong. An office for the new Commissioner of Critical Infrastructure (Computer-system Security) ("Commissioner") will be set up to oversee and enforce the new regime.

This article considers the Government's amendments during the Second and Third Readings of the Bill, discusses grey areas that await further clarification from the Government, potentially by way of Codes of Practice (CoPs), and sets out a high-level comparison of the Ordinance with similar laws in other jurisdictions.

Click here to read the full alert.

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Jacqueline Wong, Knowledge Lawyer, has contributed to this legal update.

Contact Information
Isabella Liu
Partner
Hong Kong
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isabella.liu@bakermckenzie.com
Dominic Edmondson
Special Counsel
Hong Kong
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dominic.edmondson@bakermckenzie.com

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