APAC Monthly Private Wealth Legal Developments – March 2026
APRA finalises amendments to capital treatment of longevity products
APRA has announced it has finalised amendments to its prudential standards on the capital treatment of longevity products to strength the market for retirement income products and improve retirement outcomes.
The main amendment is the introduction of an option for insurers to use an advanced illiquidity premium (AILP) when determining capital requirements for longevity products, which better reflects the long-term nature of these liabilities. APRA has also put into place supplementary amendments implementing additional risk controls related to the governance, reporting and asset composition of portfolios to which the AILP is applied. These reforms provide a more risk-sensitive and principles-based approach that reduces procyclicality in capital settings while maintaining safeguards, and form part of APRA’s objective of ‘getting the balance right’.
APRA has published the final prudential standards and its response paper. It has also released a draft reporting template for insurers who choose to use the AILP, and is seeking feedback on the template by 12 May 2026.
The reforms will come into effect on 1 July 2026. [31 Mar 2026]
ASIC remakes relief instruments for AFS licensees and overseas banks
ASIC has announced it has remade ASIC Corporations (Foreign Licensees and ADIs) Instrument 2026/121.
The instrument will replace ASIC Corporations (Foreign Licensees and ADIs) Instrument 2016/186, and is due to expire on 1 April 2031. Its primary purpose is to provide relief for foreign companies that are Australian financial services (AFS) licensees and foreign authorised deposit-taking institutions (ADIs). Under the instrument, foreign AFS licensees are exempted from record keeping obligations and the requirement to lodge financial statements and have them audited under Division 6 of Part 7.8 of the Corporations Act 2001, and foreign ADIs are exempted from the requirement to hold an AFS licence when dealing in derivatives and foreign exchange contracts on their own behalf.
ASIC has also extended ASIC Corporations (Licence Conditions—Treatment of Lease Assets) Instrument 2021/229 for five years to 1 May 2031. This instrument allows certain AFS licensees to include lease assets in calculations of their net tangible assets, adjusted surplus liquid funds and surplus liquid funds. [31 Mar 2026]
ASIC remakes technical relief and updated credit disclosure instruments
ASIC has announced it has remade two legislative instruments without substantial changes. The instruments give technical relief to AFS licensees and make minor updates to required reverse-mortgage disclosures by Australian credit licensees.
The legislative instruments are:
- ASIC Corporations (Miscellaneous Technical Relief) Instrument 2026/115, and
- ASIC Credit (Updated details for prescribed disclosure) Instrument 2026/122.
ASIC has assessed that the instruments comprise a necessary part of the relevant legislative framework and that their previous iterations (ASIC Corporations (Miscellaneous Technical Relief) Instrument 2015/1115, and ASIC Credit (Updated details for prescribed disclosure) Instrument 2016/200) have operated effectively. They received no submissions in response to their request for feedback in December 2025.
The instruments are due to expire on 1 April 2031. [31 Mar 2026]
ASIC enforcement: Court orders Binance Australia Derivatives to pay $10 million penalty
The Federal Court has ordered Oztures Trading Pty Ltd (trading as Binance Australia Derivatives) (Binance) to pay a $10 million pecuniary penalty after misclassifying more than 85% of its Australian client base between July 2022 to April 2023, resulting in more than $12 million in losses and fees. Earlier in 2023, ASIC also oversaw approximately $13.1 million in compensation from Binance to the affected clients, and cancelled the AFS licence held by Binance.
ASIC commenced civil penalty proceedings against Binance in December 2024. Binance admitted to all contraventions alleged by ASIC, including to serious failures in Binance’s client onboarding and classification systems, which were exacerbated by poor staff training and inadequate oversight by senior compliance staff. These failures in Binance’s classification system left more than 85% of their Australian customer base exposed to high-risk crypto products which they should not have been able to access, and without consumer protections or rights.
Alongside the financial penalty, the Court has ordered Binance to contribute to ASIC’s legal costs. [27 Mar 2026]
ASIC consultation begins on proposed derivative transaction reporting rules updates
ASIC has announced that it has launched a consultation on its derivatives transaction reporting framework, which is contained in the ASIC Derivative Transaction Rules (Reporting) 2024. The rules set out the requirements for reporting derivative transaction information to derivative trade repositories.
ASIC is seeking to simplify reporting requirements and progressively modernise the framework to be in line with international data standards and the reporting rules of other major jurisdictions. It has provided a detailed list of proposed amendments and a markup of the current rules.
Feedback is requested by 8 May 2026. ASIC plans for the amendments to commence on 1 March 2027. [27 Mar 2026]
ASIC updates financial reporting instruments
ASIC has announced that it has remade three legislative instruments that provide financial reporting relief.
- The new instruments are:
- ASIC Corporations (Rounding in Financial/Directors' Reports) Instrument 2026/183, allowing entities to round amounts presented in financial reports and directors’ reports to the nearest thousand dollars;
- ASIC Corporations (Electronic Lodgment of Financial and Sustainability Reports) Instrument 2026/59, allowing entities listed on the securities exchanges operated by ASX Limited, Cboe Australia, National Stock Exchange of Australia Limited and Sydney Stock Exchange Limited to lodge financial, sustainability and directors’ reports electronically with the market operator instead of ASIC; and
- ASIC Corporations (Disregarding Technical Relief) Instrument 2026/180, allowing entities to prepare a disclosure document or product disclosure statement for ‘continuously quoted securities’ under sections 713 and 1013FA of the Corporations Act 2001 and lodge ‘cleansing notices’ under sections 708A and 1012DA.
These instruments will expire on 1 April 2031. [27 Mar 2026]
ASIC extends intra-fund transfer relief for super trustees
ASIC has announced it has extended the intra-fund transfer relief provided for superannuation trustees until 1 April 2031, under ASIC Corporations (Intra-fund Transfers) Instrument 2026/688. The relief exempts trustees of APRA-regulated superannuation funds who issue superannuation products during an intra-fund transfer from:
- the application form requirements in section 1016A; and
- the cooling-off period requirements in section 1019A of the Corporations Act 2001.
The relief, which was originally provided in ASIC Corporations (Superannuation Accrued Default Amount and Intra-Fund Transfers) Instrument 2016/64), was due to expire on 1 April 2026. [24 Mar 2026]
APRA reports that climate risk could erode Australia’s financial system resilience
APRA has released its Insurance Climate Vulnerability Assessment, which found that a changing climate could decrease home insurance affordability. In turn, this could increase uninsured losses for households, constrain home insurance market growth, amplify credit risk for banks, lead to increased reliance on government support and erode financial system resilience over the next three decades.
APRA has emphasised the importance of government, industry and the community working together to address the widening home insurance protection gap. Areas of focus include emissions mitigation, resilient infrastructure, risk-based land-use planning, insurance innovation leading to improved affordability, and maintaining the financial resilience of regulated entities. [24 Mar 2026]
ASIC consultation open on reforms to relief for managed discretionary account services
ASIC has announced it has opened consultation on proposed changes to the conditional relief scheme for managed discretionary account providers under ASIC Corporations (Managed Discretionary Account Services) Instrument 2016/968.
The scheme provides conditional relief for MDA providers and external MDA custodians from the managed investments provisions in Chapter 5C, the product disclosure provisions in Chapter 6D and Part 7.9, and the financial services disclosure provisions related to statements of advice and financial services guides for MDA services in Chapter 7.7 of the Corporations Act 2001. It is currently due to expire on 1 October 2026.
ASIC is seeking feedback through a simple consultation on whether the scheme should be extended for a further period, and, if so, have any substantive and/or simplification changes made.
Comments are requested by 28 April 2026. [23 Mar 2026]
APRA consultation begins on implementation of Government’s Retirement Reporting Framework
APRA has announced that it has opened consultation on the implementation of the Government’s Retirement Reporting Framework. The framework aims to uplift the retirement phase of superannuation by increasing consistency and transparency in the reporting and tracking of member retirement outcomes. The new data gathered under the framework will be used to report on indicators of a superannuation fund’s product offerings and services, and metrics that demonstrate member outcomes (such as how effectively superannuation funds are supporting members into solutions). It will allow superannuation funds to assess member retirement outcomes and encourage innovative and modernised retirement income solutions.
APRA has been tasked with giving effect to the collection and publication of these member retirement indicators and metrics, including designing reporting standards and forms. It has set out its proposed approach in the consultation paper. The guiding principle to the approach is ‘getting the balance right’ and focusing on competition and efficiency considerations, without unnecessary or unreasonable regulatory impact. APRA has proposed that it will update one existing reporting standard (SRS 607.0 RSE Business Model), introduce one new reporting standard (SRS 611.1 Retirement Member Profile) and update associated definitions in another existing reporting standard (SRS 101.0 Definitions for Superannuation Data Collections). APRA will publish the data collected under these standards annually commencing in 2028. The data will also be shared with ASIC, Treasury and other relevant government agencies.
APRA is seeking input on costs and the impact of the proposed implementation approach to assess opportunities for minimising undue industry costs further. Written submissions are requested by 3 June 2026. [23 Mar 2026]
ASIC launches financial complaints data dashboard
ASIC has announced the launch of its Internal Dispute Resolution (IDR) data dashboard. The dashboard is intended to improve transparency regarding how financial services firms handle consumer complaints and to strengthen accountability across the sector.
The dashboard publishes IDR data reported to ASIC under its dispute resolution framework. Users can view and compare complaints data at an individual firm level. The dashboard allows users to explore complaint volumes and trends over time, broken down by product, issue type and outcome. It also enables users to access information regarding complaint resolution timeframes and monetary remedies paid.
By making this data publicly available, ASIC aims to encourage firms to improve their IDR practices and to enable firms to benchmark their performance against peers. The data is also intended to support ASIC’s regulatory and supervisory work by helping it identify trends, risks and potential misconduct earlier.
ASIC has noted that publication of IDR data complements the Australian Financial Complaints Authority’s reporting of external dispute resolution outcomes, together providing a more complete picture of the financial dispute resolution system. The dashboard builds on ASIC’s broader data‑driven regulatory approach and follows earlier initiatives to publish other regulatory datasets, including reported breach information. [18 Mar 2026]
ASIC consults on changes to net tangible assets requirement for responsible entities
ASIC has announced it has published Consultation Paper 388 Net tangible assets requirement for responsible entities. ASIC is seeking feedback from the industry on whether the current financial thresholds that apply to responsible entities of registered managed investment schemes (set out in ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647) remain appropriate and effective. In addition to this, ASIC seeks feedback on:
- increasing the net tangible asset requirements that apply to other fund operators, i.e. operators of investor directed portfolio services and corporate directors of retail corporate collective investment schemes; and
- the net tangible asset requirements for other categories of licensees.
Feedback is requested by 17 April 2026; ASIC will announce its final position by 31 July 2026. [18 Mar 2026]
Treasury consultation open on reforms to financial adviser education requirements
The Australian Government has launched a consultation on proposed reforms to the education standards for financial advisers. The Government proposes streamlined entry into the industry while retaining the importance of financial advisers possessing a tertiary education.
The consultation paper identifies issues with the existing qualification standards for financial advisers, including that they are 'complex and [lack] flexibility and [have] not been effective in supporting a sustainable pipeline of new financial advisers entering the profession'. The proposed reforms would introduce a more flexible and sustainable pathway for new entrants to the financial advice profession, while retaining core professional safeguards. Under the proposed model, prospective financial advisers would be required to hold a bachelor’s degree or higher. However, the degree would no longer need to be a prescribed financial advice qualification. Instead, entrants would be required to complete minimum study requirements in relevant disciplines such as finance, economics or accounting, together with mandatory financial advice subjects covering ethics, legal and regulatory obligations, consumer behaviour and financial advice fundamentals.
Other key requirements for advisers would remain unchanged including the completion of a professional year, passing the financial adviser exam and meeting ongoing continuing professional development obligations. The Government has emphasised that the reforms are designed to maintain robust education and ethical standards, while improving access to advice and reducing the risk of consumers turning to unlicensed or high‑pressure sales practices.
Feedback is requested by 17 April 2026. [17 Mar 2026]
ASIC proposes to remake relief for exchange-traded warrants
ASIC has announced it is seeking feedback on its proposal to remake two sunsetting legislative instruments which provide relief related to exchange-traded warrants.
The legislative instruments which ASIC proposes to be remade are:
- ASIC Corporations (Margin Lending Relief for Exchange-Traded Instalment Warrants) Instrument 2021/194 (sunsetting 1 April 2026); and
- ASIC Corporations (Exchange-Traded Warrants) Instrument 2016/886 (sunsetting 1 October 2026)
ASIC has assessed that the instruments comprise a necessary aspect of the relevant legislative framework and have operated effectively. ASIC proposes that the legislative instruments be remade for a period of five years with minor amendments to:
- include market neutral language;
- simplify definitions and reword he exemption in draft instrument ASIC Corporations (Exchange-Traded Warrants) Instrument 2026/<Number> to improve its clarity; and
- remove definitions which are contained in the Corporations Act 2001 (Cth).
Feedback is requested by 24 March 2026. [16 Mar 2026]
Treasury requests feedback on new regulatory framework for payment service providers
The Treasury is seeking feedback in relation to Tranche 1 of new draft legislation updating the regulatory framework for payment service providers.
The proposed suite of legislation comprises:
- Treasury Laws Amendment Bill 2026: Payments System Modernisation – the Bill amends the current regulatory framework for payment service providers by establishing a more comprehensive and modernised system that reflects the realities of contemporary payment services, capturing new financial products and services. It is also aimed at tailoring the AFS licensing regime to the diverse functions of providers operating in Australia. Four reforms proposed within the Bill are:
- o the replacement of the purchased payment facility regime with AFS licensing requirements for stored value facility providers;
- o the introduction of a mandatory ePayments Code to set minimum consumer protection standards;
- o the introduction of new safeguards to ensure payment related money can be transferred or returned to its rightful owner; and
- o the establishment of a process for managing dormant funds held by major stored value facility providers.
- Payment Entities (Prudential Regulation) Bill 2026 – the Bill is aimed at addressing current uncertainty within the purchased payment facility sphere by expanding the reach of providers covered by the legislation and ensuring prudential obligations are proportionate to a provider’s reality. The largest reform concerns the introduction of prudential requirements administered by APRA for major stored value facility providers. A determination of a stored value facility provider’s size is done in accordance with the thresholds prescribed in the Bill.
- Payment Entities Supervisory Levy Imposition Bill 2026 and Authorised Non-operating Holding Companies Supervisory Levy Imposition Amendment Bill 2026 – The Bills introduce a levy to be paid by entities which are regulated under the new Prudential Regulation Bill to ensure APRA can recover its supervisory costs.
- Treasury Laws Amendment (Payments System Modernisation) Regulations2026 – The proposed Regulations are aimed at supporting the reforms to payment service provider regulation facilitated by the Bills above. The Regulations will update legislative instruments to reflect new terminology and remove outdated references to concepts which are no longer commonplace in the industry. They also provide a tailored procedure for low‑risk payment products and services and certain exemptions for non‑cash payment facilities. Finally, the Regulations also provide for transitional measures to ensure that the updated framework does not cause significant disruption to the industry.
Comments on the framework are requested by 9 April 2026. [12 Mar 2026]
AFCA publishes updated Rules and Operational Guidelines
AFCA has published an updated version of its Rules and Operational Guidelines. The changes come following significant industry and stakeholder consultation and are aimed at increasing 'fairness, transparency and efficiency' regarding financial complaints. The key changes are as follows:
- AFCA’s jurisdiction has been expanded to allow for the investigation of scam-related complaints involving banks receiving fraudulent funds and unauthorised accounts opened by scammers;
- the names of financial firms found to have failed to comply with AFCA Determinations may be published by AFCA;
- new obligations for paid representatives; and
- the removal of legacy complaints provisions. [12 Mar 2026]
ASIC consults on proposals to bolster transparency on ownership and control of listed entities
ASIC has announced that it is consulting on new measures to strengthen corporate transparency by improving investor visibility of who ultimately owns or controls entities listed on Australian financial markets, including through the better disclosure of interests held via equity derivatives. The proposed measures arise in response to amendments made under the Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Act 2025 (Cth), which were similarly aimed at enhancing beneficial ownership disclosure obligations for listed entities.
The consultation paper, CP387, outlines proposals for a new legislative instrument (the ASIC Corporations (Listed Enhancements Beneficial Ownership Disclosure) Instrument 2026/XX), a revised Substantial Holding Notice and updates to key regulatory guides. Feedback is requested by 21 April 2026. [10 Mar 2026]
ASIC trims regulatory guidance to reduce complexity for financial industry
ASIC has announced changes to its suite of regulatory guidance materials to ensure it remains not only contemporaneous, but allows for financial regulation to become 'simpler, clearer and easier to apply'. As part of the modifications, the regulator has withdrawn:
- RG64 - Failure to Lodge Documents, which covered ASIC’s approach to companies that failed to lodge particular documents; and
- RG40 - Good Transaction Fee Disclosure for Bank, Building Society and Credit Union Deposit and Payments Products, which provided guidance on the correct approach to transaction fee disclosure.
ASIC clarified, however, that more up‑to‑date information on the topics covered in that guidance can be found in its more recent publications and from Moneysmart.gov.au.
The changes also saw minor amendments to RG 104 - AFS Licensing: Meeting the General Obligations and RG205 – Credit Licensing: General Conduct Obligations. [10 Mar 2026]
AUSTRAC publishes guidance on compulsory examination powers
AUSTRAC has published guidance on its new compulsory examination powers under s 172A of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). A notice distributed under this section requires a person to attend an examination, provide relevant documents and answer questions.
AUSTRAC CEO Brendan Thomas affirmed that the powers will be exercised carefully by AUSTRAC, with a clear focus on understanding money‑laundering risks rather than assuming wrongdoing. Mr Thomas explained that 'compulsory examinations are not routine or punitive' and that often 'an examination is simply a way to understand what has happened'. The guidance also contains detail of the protections for witnesses under the section and clarifies what businesses can expect during an examination. [5 Mar 2026]
ASIC Chair delivers speech at the ASIFMA Annual Conference
ASIC Chair Joe Longo recently delivered a speech at the Annual Conference of the Asia Securities Industry & Financial Markets Association, emphasising ASIC’s desire to be 'backers, not blockers, of financial innovation'. His remarks focused on the rapid growth of technologies transforming financial markets, such as asset tokenisation and AI‑driven financial advice, and the regulatory settings needed to support these developments.
Mr Longo explained that these considerations have resulted in 'a review of the ASIC Innovation Hub' and an identification of priority areas where it intends to lead on managing the system‑wide changes brought by emerging technologies. Further, following industry feedback after a decade of regulatory sandboxes, Mr Longo noted ASIC’s interest in finding tailored solutions to better support the transition from sandbox to licensing – a jump that 'very few sandbox participants have successfully made'.
Mr Longo referred to recent work from the Digital Finance Cooperative Research Centre identifying a $24 billion opportunity linked to modernising Australia’s financial infrastructure through tokenisation. Discussing the Reserve Bank’s Project Acacia – a project testing tokenised whole asset markets – Mr Longo emphasised the impact that growing technologies have on financial market infrastructure. It was remarked that the full extent of these opportunities can only be realised 'if the public and private sector work together” and if “regulatory and policy settings enable innovation'. ASIC has commenced several projects in support of this effort, including convening a roundtable of senior financial market experts and form a new advisory group to guide future regulatory models. [5 Mar 2026]
ASIC extends short selling relief for market makers in precious metal-backed exchange traded products
ASIC has extended conditional short selling relief for appointed market makers to support market liquidity in exchange-traded options over Global X Physical Gold Structured and specified structured products referencing precious metals. This extends existing relief for exchange traded products where the risk of settlement failure is low.
From 3 February 2026, the ASIC Corporations (Amendment) Instrument 2026/24 amends the ASIC Corporations (Short Selling) Instrument 2018/745to:
- allow market makers of specified structured products to short sell these products in the course of market making on the same conditions that currently apply to exchange traded fund (ETF) market makers;
- include Global X Physical Gold Structured as an approved product that an appointed exchange-traded option (ETO) market maker can short sell to hedge risks arising from market making activity; and
- extend reporting relief for ETF market makers in certain structured products. [27 Feb 2026]
SEHK reminds exchange participants of end of transition period for Northbound program trading reporting under Stock Connect on 10 April 2026
The SEHK has issued a circular to remind China Connect exchange participants (CCEPs) and trade-through exchange participants (TTEPs) that the 3-month transition period for the Northbound Program Trading Reporting Guidelines will end shortly (see our previous update), and that they are required to complete the relevant reporting by 10 April 2026.
The SEHK advises CCEPs and TTEPs to refer to the websites of the Shanghai Stock Exchange and the Shenzhen Stock Exchange, as well as the dedicated Northbound Program Trading Reporting section on the HKEX Stock Connect website, and to remind their clients who are existing investors to fulfill their reporting obligations by 10 April 2026. [1 Apr 2026]
SFC publishes latest issue of Enforcement Reporter, discussing fund manager misconduct, sponsor misconduct, collaboration with HKMA, among others
The SFC has published Issue No. 7 of its Enforcement Reporter, discussing the following topics:
Fund manager misconduct
- The SFC reiterates that fund managers 'sit at the heart of investor trust' and that failures in governance, disclosure and risk management can rapidly undermine market confidence.
- The SFC issued a circular on 9 October 2024 (previous update) to inform the market of significant deficiencies and substandard conduct identified during its supervisory work in respect of asset management businesses, and stated that it would step up its disciplinary actions in appropriate cases.
- The SFC provided examples of disciplinary actions taken in relation to issues such as fund mismanagement, conflicts of interest, misuse and misappropriation of client assets, window dressing of financial resources, provision of false or misleading information to the SFC, and senior management failures.
Sponsor misconduct
- The SFC stresses that when a sponsor puts its name to a listing, it represents to the market that the issuer’s business has been rigorously tested. Sponsors should apply demanding due diligence standards and exercise professional scepticism throughout the listing process.
- The two disciplinary cases highlighted involve misconduct such as ignoring retail sales red flags, over-reliance on information provided by the listing applicant, inadequate prospectus disclosures and misapplication of the Listing Rules.
Collaboration with HKMA
- The SFC highlights its collaboration with the HKMA, underpinned by the 2002 memorandum of understanding, which facilitates case referrals, joint inspections and supervisory intelligence‑sharing.
- In practice, the partnership has delivered collaborative thematic reviews, shared inspection findings, and coordinated enforcement initiatives targeting concerns that span both regulators’ remits. Two recent case examples have been highlighted.
Modernising secure document exchange – WINGS
- The final section of the bulletin outlines how the WINGS platform (which became fully operational in May 2025) supports swift and reliable communication between the SFC and intermediaries, providing a centralised, audit‑tracked environment that prioritises confidentiality, efficiency and compliance. [31 Mar 2026]
SFC highlights importance of engaging suitable professional advisers in Issue No. 76 of Takeovers Bulletin
In Issue No. 76 of its Takeovers Bulletin, the SFC has reiterated that financial and other professional advisers involved in transactions governed by the Codes on Takeovers and Mergers and Share Buy‑backs (Codes) serve an important role in ensuring that their clients understand and abide by the Codes, and must therefore have the competence, professional expertise and adequate resources to discharge their responsibilities under the Codes.
The SFC notes that it has recently observed a number of cases in which advisers engaged by offerors or offeree companies appeared to lack sufficient understanding of the requirements of the Codes, as evidenced by sub‑standard drafts and incomplete responses. Certain Codes issues were therefore not identified and addressed in a timely manner, even for straightforward transactions.
The SFC reminds advisers to exercise independent judgment and professional assessment of the implications of the Codes, rather than acting merely as middlemen relaying their clients’ requests or copying inapplicable precedent disclosures. The bulletin expressly refers to section 1.7 of the Introduction to the Codes, under which, if the SFC considers that a financial adviser is unable to meet the expected standard, it may not allow that adviser to act in that capacity. Failure to adhere to the requirements of the Codes could also lead to disciplinary action against the relevant parties.
The bulletin also discusses other matters, including a settlement agreement in relation to a disciplinary action and changes to takeovers-related committees. [31 Mar 2026]
HKEX issues 17th issue of Compliance Bulletin outlining key reminders on LOP reporting, dealings with suspended participants and closing of 2025 Attestation and Inspection Programme
The HKEX has published the 17th issue of its Compliance Bulletin to offer the industry a better understanding of its enforcement work and regulatory expectations. The present issue focuses on three areas:
Large Open Position (LOP) reporting requirements for positions held or controlled through multiple brokers
- The HKEX reminds exchange participants (EPs) of the relevant provisions relating to LOP reporting and the key requirements. It is the responsibility of each person holding or controlling the reportable position to fulfill the LOP reporting obligations, regardless of whether the person makes the reporting directly to the relevant exchanges or through EPs or brokers.
- Under the rules and procedures of the relevant exchanges, EPs should inform their clients of the LOP reporting requirements and the responsibilities of reporting. They should maintain adequate procedures and guidelines to ensure their clients are properly informed of the relevant rules and requirements.
Dealings with suspended EPs
- The HKEX notes that certain EPs had dealt with suspended EPs without an appropriate exchange permission, which constitutes a violation of relevant exchange rules and may give rise to disciplinary action.
- EPs are required to review market education materials previously published by the HKEX (see footnote 2 of the circular) and take appropriate steps to ensure that effective policies, controls and oversight arrangements are in place to achieve ongoing compliance with the relevant rules and requirements.
Closure of the 2025 Attestation and Inspection Programme
- The HKEX has closed its 2025 Annual Attestation and Inspection Programme and set out its key findings along with further elaboration in the corresponding compliance reminders to EPs (see 'HKEX announces outcome of the 2025 Annual Attestation and Inspection Programme and commencement of 2026 programme' below).
- EPs and clearing participants (CPs) are expected to keep abreast of all applicable rules and regulations. They should also review their current practices and procedures, adopt appropriate measures to strengthen their controls, and where necessary, take immediate actions to rectify any breaches or deficiencies.
The HKEX notes that the requirements and examples set out in the compliance bulletin are not exhaustive. EPs and CPs should take into consideration their own circumstances to ensure full compliance with the relevant rules and requirements, and seek professional advice on their specific situations where appropriate. [31 Mar 2026]
HKEX announces outcome of the 2025 Annual Attestation and Inspection Programme and commencement of 2026 programme
The HKEX has issued a circular announcing the successful completion of its 2025 Annual Attestation and Inspection Programme, which focused on compliance with China Connect rules and risk management requirements.
The HKEX inspected 20 exchange participants and clearing participants, and received a 100% response rate to the self‑attestation questionnaires from 630 participants on compliance with the relevant rules and requirements in respect of the priority areas and prescribed risk controls.
While most participants had systems and controls in place to comply with the relevant rules and requirements in the priority areas, some common deficiencies and shortcomings were identified. In total, 35 participants were found to have non‑compliance issues and/or control deficiencies in various areas:
- China Connect rules-related areas – For example, failure to comply with various Northbound broker‑to‑client assigned number requirements, inadequate control arrangements to oversee investor eligibility requirements for trading ChiNext and STAR shares, and untimely stock position reconciliation (further details are set out in the compliance reminder in Appendix 1).
- Risk management-related areas – For example, inadequate controls over settlement operations, funding estimation, position management, exposure monitoring and funding arrangements, and inadequate support and arrangements in place for handling of client trades under contingent situations (further details are set out in the compliance reminder in Appendix 2).
Participants are expected to review their current practices and procedures against the compliance reminders, adopt appropriate measures to strengthen their controls, and where necessary, take immediate action to rectify any breaches or deficiencies. The HKEX takes rule breaches and deficiencies seriously and may consider taking disciplinary action against non-compliant participants, including issuing warning letters, imposing fines and initiating disciplinary proceedings.
The HKEX has issued another circular announcing the upcoming launch of the 2026 Annual Attestation and Inspection Programme. The programme will focus on the following priority areas (applicable to different types of participants as stated in the circular): trading and deviated price risk controls; and risk management practices in respect of credit, liquidity, operational, market and financial risk, among others.
The self-attestation compliance questionnaire will cover the Hong Kong Investor Identification Regime.
There will be two live webinar information sessions (English and Chinese) on 28 and 29 April 2026 respectively. The registration deadline for the sessions is 16 April 2026.
Further information on the 2025 and 2026 programmes are available on the HKEX's designated webpage. [31 Mar & 1 Apr 2026]
SFC announce launch of USM regime targeted for 16 November 2026
The SFC has announced that Hong Kong’s uncertificated securities market (USM) regime is targeted to launch on 16 November 2026. A commencement notice to bring USM legislation into effect will be tabled before the Legislative Council in the second quarter of 2026.
The Hong Kong Securities Clearing Company Limited (HKSCC) has also issued a circular regarding the implementation of the USM regime, following on from its earlier circular in August 2025 (see our previous update).
Implementation work led by the HKEX and the Federation of Share Registrars (FSR) is now at the advanced stages:
- The HKEX and relevant share registrars are at an advanced stage of developing and testing their USM-related systems and processes. Market participants will be invited to participate in testing in the coming months.
- The SFC has reviewed and approved amendments to various HKEX rules and operational procedures for implementing the USM regime (see amendments to the Main Board Listing Rules, GEM Listing Rules, General Rules of HKSCC and HKSCC Operational Procedures – further information can be found on the HKEX USM webpage).
- The HKEX and the FSR have updated their respective information papers on USM to include fee and other changes under the new regime (see HKEX USM webpage).
- The SFC is reviewing applications from six FSR members who seek to become approved securities registrars. Information on the status of their applications will be published on the SFC’s website in the coming weeks.
- Various publications and briefings have already been issued and conducted to facilitate the market’s understanding of the new regime and its implications. These efforts will continue going forward.
Upon implementation, newly listed securities will be required to be issued in paperless form from the time of listing. Issuers of securities already listed prior to the launch date will be gradually integrated into the USM regime over a five-year period.
The HKSCC circular sets out information regarding briefing sessions in April 2026, questionnaire to be completed by clearing participants and custodian participants, CCASS terminal user guides, and practice sessions. [30 Mar 2026]
HKEX and Bursa Malaysia sign MOU to enhance market connectivity, announcing first step of collaboration with launch of co-branded index
The HKEX and Bursa Malaysia Berhad have signed a memorandum of understanding MOU aimed at strengthening collaboration and deepening capital market connectivity between Hong Kong and Malaysia. Areas of collaboration include dual listings, exchange traded funds, joint development of indices and investment products, Shariah-compliant securities, and carbon markets.
As a first step of the collaboration, the two exchanges announced the launch of the HKEX Bursa Malaysia Large Cap Index, a new co-branded benchmark aimed at enhancing cross market access for investors. The index measures the performance of the 60 largest companies listed in Hong Kong and Malaysia by market capitalisation, with 30 constituents drawn from each market and index weightings of approximately 60% for Hong Kong-listed companies and 40% for Malaysian-listed companies.
The launch of the index is part of the HKEX's commitment to building an exchange-led index ecosystem that will add vibrancy across the primary and secondary markets, while meeting growing demand for diversified regional investment opportunities.
The HKEX also hosts 30 Malaysian companies listed on its exchange, part of a total of 103 issuers from Southeast Asia in Hong Kong. [27 Mar 2026]
FSTB gazettes Bill to enhance AEOI framework by increasing requirements on reporting financial institutions and penalties for non-compliance
The FSTB has gazetted the Inland Revenue (Amendment) (Automatic Exchange of Information) Bill 2026 to enhance the administrative framework for automatic exchange of information in tax matters (AEOI) in Hong Kong.
Since 2024, the Organisation for Economic Co-operation and Development (OECD) has been conducting the second round of peer review on Hong Kong's implementation of the AEOI regime. Having taken into account the OECD's views, and conducted a public consultation from 9 December 2025 to 6 February 2026, the FSTB proposes to amend the Inland Revenue Ordinance to incorporate various enhancements, including the following (among others):
- Requiring reporting financial institutions to register with the Inland Revenue Department (IRD) to strengthen identification;
- Enhancing the requirements on keeping due diligence records for reporting financial institutions; and
- Raising the penalties imposed on reporting financial institutions for non-compliance (such as by linking the calculation of the maximum amount of the penalty for the offence concerned to the number of the financial accounts involved in that offence).
Further details on the enhancements are set out in the Legislative Council (LegCo) brief.
The Bill will be introduced into the LegCo for first reading on 1 April 2026, with the relevant amendments taking effect on 1 January 2027. The IRD will issue relevant guidance in due course and provide technical support to the industry and answer enquiries. [27 Mar 2026]
HKMA issues guiding principles on consumer protection in use of alternative data
The HKMA has issued a circular setting out guiding principles for authorised institutions (AIs) on consumer protection in the use of alternative data in banking operations. In drawing up the principles, the HKMA has made reference to international experiences and best practices, such as the World Bank report on 'The Use of Alternative Data in Credit Risk Assessment: Opportunities, Risks, and Challenges' published in 2024.
AIs should have put in place clear and comprehensive policies and procedures governing the use of consumer and commercial credit data obtained from credit reference agencies in managing credit risk, in line with the requirements under Supervisory Policy Manual module IC-6 'The Sharing and Use of Consumer Credit Data through Credit Reference Agencies' and module IC-7 'The Sharing and Use of Commercial Credit Data through a Commercial Credit Reference Agency'.
However, given that alternative data is generally more diverse and less standardised or structured in nature, and in light of the expanding availability of data sources, the HKMA considers it necessary to set out some additional guiding principles – focusing on four areas – to be applied on a risk-based approach. AIs are expected to review (and enhance, where necessary) their policies and practices to align with the principles:
- Governance and accountability – The board and senior management of AIs should remain responsible and accountable for approving and overseeing the policies and procedures established for the use of alternative data, as well as all alternative data-driven decisions and processes.
- Transparency and consent management – AIs should establish clear communication with customers to ensure an appropriate level of transparency regarding the use of alternative data.
- Data quality and fairness – AIs should establish clear protocols for suitable and proportionate data validation and evaluation to ensure the quality and fairness of alternative data, as well as the accuracy and fairness of the outcomes from credit risk assessment methods and processes.
- Data privacy and protection – AIs should implement necessary and effective safeguards to address additional privacy and cyber risks associated with the use of alternative data, given the diverse nature of alternative data sources.
AIs are also reminded to refer to HKMA’s previous circulars on the use of artificial intelligence when adopting artificial intelligence in their processes relating to alternative data. [26 Mar 2026]
NFRA hosts inaugural Guangdong-Hong Kong-Macao-Shenzhen Joint Financial Regulatory Meeting
The HKMA and the Insurance Authority have announced that the inaugural Guangdong-Hong Kong-Macao-Shenzhen Joint Financial Regulatory Meeting was held in Nansha, Guangzhou on 23 and 24 March 2026.
The meeting was hosted by the National Financial Regulatory Administration (NFRA) Guangdong Office and attended by representatives from the HKMA, the Hong Kong Insurance Authority, the Monetary Authority of Macao, and the NFRA Shenzhen Office. Officials from relevant departments of the NFRA, Guangdong Province and Guangzhou Municipal Government were also invited to attend.
Participants of the meeting exchanged views on industry developments, supervisory work and market trends, and discussed topics such as:
- Banking industry support for the development of the international innovation and technology hub in the Greater Bay Area;
- Regulatory oversight of artificial intelligence development and application in banking;
- Insurance services to enhance high-quality city development;
- Facilitation of convenient cross-boundary medical insurance services; and
- Protection of consumer rights and interests. [25 Mar 2026]
OTC Clear and HKSCC remind clearing participants of payment obligations
The OTC Clear and the HKSCC have issued circulars to remind clearing participants of the importance of having proper risk management and robust funding arrangements in place to adequately monitor their exposures and fulfil their payment obligations on time, to ensure the smooth operation of the OTC market and the Hong Kong and China Connect markets.
The circulars state that clearing participants must adhere to the settlement timelines stipulated by the respective clearing house. Failure to do so constitutes an event of default under OTC Clear Clearing Rule 1301 and Rule 3701 of the General Rules of HKSCC respectively, the consequences of which include default actions and/or disciplinary actions against the participant concerned, which may lead to trading or membership suspension, imposition of penalties and/or additional risk management measures. Clearing participants are strongly advised to review their operational and monitoring procedures and introduce enhancement measures where appropriate.
The circulars provide examples of the areas that should be covered in the review. They include (among others):
- (OTC Clear) Operational capabilities to perform trade affirmation, contract settlement, portfolio valuation, portfolio reporting and system linkage with an approved trade registration system;
- (OTC Clear) Adequate risk management systems;
- (HKSCC) Funding estimation and position management procedures for collateral requirements and continuous net settlement obligations;
- (HKSCC) Adequacy of funding and banking facilities, particularly for non-HKD;
- Contingency and business continuity plan; and
- Back-up staff arrangement.
The circulars state that, as a best practice, participants should have in place established procedures to project the amount of payment obligations to OTC Clear and the HKSCC, and arrange sufficient funding to meet such obligations in a timely manner. A summary of payment obligations is set out in the Appendix of each circular for reference.
The HKFE Clearing Corporation Limited and the SEHK Options Clearing House Limited issued similar circulars on 20 March 2026 (see our previous update). [23 & 25 Mar 2026]
SFC CEO re-appointed as Chair of IOSCO APRC
The SFC has announced the re-appointment of its Chief Executive Officer CEO, Ms Julia Leung, as the Chair of the Asia-Pacific Regional Committee by the International Organization of Securities Commissions (IOSCO). Her second two-year term will start from the date of the IOSCO’s annual meeting in May 2026.
Ms Leung notes that she will work towards further strengthening the resilience of the APAC region’s capital markets and ensuring a strong and balanced regional voice in dialogues on global finance, addressing issues such as online investment scams, digital assets, public and private markets, and enhancing cross-border supervisory and enforcement cooperation. [25 Mar 2026]
SFC updates intermediaries on HKEX market rehearsals for backbone network upgrade for securities market systems
The SFC has issued a circular regarding two HKEX market rehearsals for backbone network upgrade for securities market systems, which will take place on 11 April and 30 May 2026 respectively. The securities systems involved include OTP-C, OTP-CSC, OMD-C, OMD-CC and the Secure File Transfer Protocol (SFTP) channel of HKEX’s Electronic Communication Platform.
Following the two market rehearsals, further rehearsals will be scheduled from late second quarter to early third quarter, with details to be announced in due course. These rehearsals aim to validate connectivity by simulating daily operations over the enhanced HKEX backbone network.
Relevant regulated intermediaries (RRIs) (ie, SFC-licensed corporations / registered institutions subject to the Hong Kong Investor Identification Regime) which use the SFTP channel to submit the BCAN-CID mapping file and reporting forms to SEHK’s data repository are invited to participate in these rehearsals.
The two rehearsals in April and May 2026 are mandatory for exchange participants and China Connect exchange participants. All other RRIs (ie, non-exchange participants) are strongly encouraged to participate in these rehearsals to ensure operational readiness and a seamless transition.
Further details are set out in an SEHK circular. Only RRIs which are exchange participants are required to submit the notification form via HKEX’s Electronic Communication Platform by 27 March 2026. No enrolment will be required for non-exchange participant RRIs. [23 Mar 2026]
HKCC and SEOCH remind clearing participants of payment obligations
The HKCC and the SEOCH have issued circulars reminding clearing participants of the importance of having proper risk management and robust funding arrangements in place to adequately monitor their exposures and fulfil their payment obligations on time to ensure the smooth operations of the derivatives market.
The circulars state that clearing participants must adhere to the settlement timelines and payment deadlines stipulated by the respective clearing house. Failure to do so constitutes an event of default under HKCC Rule 509 and SEOCH Rule 701 respectively, the consequences of which include default actions and/or disciplinary actions against the participant concerned, which may lead to suspension of participantship, imposition of penalties and/or additional risk management measures. Clearing participants are strongly advised to review their operational and monitoring procedures and introduce enhancement measures where appropriate.
The circulars provide examples of the areas that should be covered in the review. They include (among others):
- Timeliness of completion of position close-out and claiming margin offsets;
- Funding arrangement procedures;
- Adequacy of funding and bank facilities;
- Contingency and business continuity plan;
- Effectiveness of client and proprietary exposure monitoring;
- Back-up staff arrangement;
- Clearing participants' up-to-date contact records at their respective clearing houses and proactive notification of any changes to their clearing houses.
The circulars state that, as a best practice, participants should have in place established procedures to project the amount of payment obligations to HKCC and SEOCH respectively, and arrange sufficient funding to meet such requirements in a timely manner. A summary of payment obligations are set out in the Appendix of each circular for reference. [20 Mar 2026]
SFC imposes 4.5-year ban and HK$1 million fine on former responsible officer for dishonest misconduct
The SFC has prohibited Mr Kuo Che‑jung, a former responsible officer of a licensed corporation, from re‑entering the industry for 4.5 years, and imposed a HK$1 million fine on him, for conducting matched trades and operating secret accounts.
The SFC considers that that Mr Kuo’s conduct was serious and dishonest, raising concerns about his fitness and properness to be licensed:
- Between 2 July and 24 November 2020, Mr Kuo executed 25 matched trades in Hang Seng Index options between the licensed corporation’s proprietary trading account and a securities trading account held in his wife’s name at another brokerage. The trades were carried out at prices favourable to his wife’s account and to the detriment of the licensed corporation, and often outside prevailing bid‑ask spreads, with the potential to undermine market integrity. Mr Kuo ultimately benefitted from the matched trades by arranging for a portion of the trading proceeds in his wife’s account to be transferred to his personal account.
- The SFC also found that Mr Kuo had concealed from the licensed corporation his beneficial interests in his wife’s account, his ownership of two securities trading accounts at another brokerage, and his personal trading activities conducted in these accounts, by repeatedly submitting false declarations to the licensed corporation, preventing the licensed corporation from monitoring his personal trading activities. [19 Mar 2026]
SFC publishes quarterly report for October to December 2025
The SFC has published its quarterly report, summarising key developments from October to December 2025. The highlights covered by the report include (among others):
Maintaining market resilience and mitigating harm
- With SFC approval, the HKEX extended its enhanced default fund sizing methodology to the clearing house for stock options to strengthen financial resilience against defaults.
- The SFC conducted 49 on‑site inspections to assess licensed corporations (LCs)’ regulatory compliance and operational resilience.
- The SFC and The Stock Exchange of Hong Kong Limited issued a joint letter to certain sponsors to express concerns over the declining quality of recent new listing applications and substandard behaviours observed.
- The SFC urged LCs to detect and prevent layering activities in money laundering through effective anti-money laundering and counter-financing of terrorism measures.
- The SFC fined three LCs for a total of HK$19.75 million and disciplined five individuals by suspending their licences or prohibiting re-entry into the industry for periods ranging from 3.5 months to life. Notably the SFC also secured the first custodial sentence against a 'finfluencer' for provision of paid investment advice on social media without a licence.
Enhancing Hong Kong market competitiveness
- Following the SFC's active engagement with the HKEX, changes were made to enable market participants to benefit from higher interest rebates, reducing their funding costs for collateral.
- Following discussions with the SFC, the HKEX consulted the public in December 2025 on enhancing the board lot framework to support trading, clearing and settlement efficiency.
- The SFC launched a consultation on proposed amendments to the Code on Unit Trusts and Mutual Funds aimed to align Hong Kong’s regulatory regime with international regulatory standards and broaden product offerings.
- The SFC launched a new real estate investment funds (REITs) channel in October 2025 to facilitate local and global REIT applicants’ listing preparations and enhance efficiency. It also streamlined the REIT authorisation process.
- The SFC received 2,488 licence applications during the quarter, up 27% year on year.
Transforming markets via technology and ESG
- The SFC published joint consultation conclusions with the Financial Services and the Treasury Bureau on legislative proposals to regulate virtual asset (VA) dealing and custodian service providers under the ASPIRe Roadmap. A further consultation was launched to introduce new regulatory regimes for VA advisers and managers.
- The SFC has enabled licensed VA trading platforms to tap global liquidity and broaden product and service offerings. They are allowed to integrate their order books with their affiliated overseas VA trading platforms, and offer trading in VAs without a 12-month track record for professional investors and for HKMA-licensed stablecoins.
- Progress continued on tokenisation initiatives under Project Ensemble, with the launch of the pilot phase (EnsembleTX) enabling real‑value transactions involving tokenised deposits and assets.
- The SFC continued to co-chair the Green and Sustainable Finance Cross-Agency Steering Group with the HKMA and actively participate in all working groups. It also continued to facilitate ESG fund development while gatekeeping against greenwashing.
Enhancing SFC’s resilience and efficiency
- The SFC continued to upgrade the WINGS system, enabling major banks in Hong Kong to provide structured transaction data to the SFC via WINGS and streamlining the analysis process conducted by investigators. [19 Mar 2026]
HKMA shares findings from thematic review of sanctions screening systems and encourages AIs and SVF licensees to conduct gap analysis
The HKMA has issued a circular to share its observations from a recent thematic review assessing the effectiveness of sanctions screening systems used by authorised institutions (AIs).
The review covered the extent to which system setting and performance, ongoing tuning and testing comply with the regulatory requirements and expectations set out in Chapter 6 of the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism and the associated guidance.
Overall, the HKMA found that the AIs' sanctions screening systems generally met the regulatory expectations and operated within industry benchmarks, and thought it would be helpful to set out in the circular the good practices observed and areas for improvement. The circular covered the following areas:
- Governance and oversight (such as the understanding of sanctions risks and regulatory obligations, and regular reporting to senior management);
- System testing and validation (such as the use of external parties to carry out testing, frequency of testing, and post-testing remedial actions);
- Sanctions list management (such as timely updates to the lists); and
- Adoption of technologies, including artificial intelligence, to optimise sanctions screening processes.
While the thematic review covered only AIs, the observations are also useful to stored value facility (SVF) licensees. AIs and SVF licensees should review their sanctions risk controls through a gap analysis, consider adopting the good practices identified, and be prepared to provide sanctions screening system testing results to the HKMA upon request. [16 Mar 2026]
SFC issues circular regarding HKMA's updates to HKTR reporting service reference manual
The SFC has issued a circular reminding licensed corporations about the HKMA's updates to the Reference Manual for the OTC Derivatives Trade Repository (HKTR) reporting service.
The changes focus on the system implementation of data archiving and the outage window on Sundays.
Following the system implementation of ISO 20022 on 22 September 2025 (see our previous update), the HKTR system has been further enhanced to support the archiving of historical over-the-counter (OTC) derivatives transaction data, along with associated information such as valuations, margin and collateral, with effect from 16 March 2026.
The HKMA announced in December 2025 and February 2026 the system behaviour for data archiving and the revised schedule for system maintenance and adjustment to the Sunday’s outage window. Data archiving for ISO will be conducted regularly during the maintenance window from 12:00pm on Sunday to 00:30am on Monday. This has been reflected in the revised Reference Manual. [16 Mar 2026]
SEHK sets out policy agenda for 2026 and beyond in 2025 Listing Committee Report
The SEHK has published its 2025 Listing Committee Report, which includes a review of the work during 2025 as well as an overview of its policy agenda for 2026 and beyond.
The Listing Committee states that it will continue to look at ways to improve the attractiveness of the Hong Kong markets and review the regulatory framework to ensure that it remains competitive and fit for purpose whilst upholding investor protection standards. The matters that the Listing Committee intends to consider in 2026 and beyond include:
- Consultation conclusions on the review of the structured products listing regime under Chapter 15A of the Main Board Listing Rules;
- Competitiveness review consultation: Phase 1 (see our previous update) and Phase 2;
- Consultation on GEM requirements;
- Consultation on the Chapter 21 investment company regime;
- Alternative trading mechanism consultation: restricted trading mechanism and over-the-counter market;
- Review of Disciplinary Rules;
- Uncertificated securities market rules;
- Consultation on modifications to the listing regimes for specialist technology companies and special purpose acquisition companies; and
- Designating additional recognised stock exchanges for secondary listings. [16 Mar 2026]
HKEX consults on proposals to enhance Hong Kong's listing competitiveness
The HKEX has published a consultation paper setting out proposals in the first phase of its review to enhance the competitiveness of Hong Kong’s listing framework. The proposals aim to broaden the diversity of companies eligible for listing in Hong Kong and enhance investor choice, while upholding robust standards of investor protection. Feedback is requested by 8 May 2026.
The key proposals include (among others):
Weighted voting rights (WVR)
- lowering the market capitalisation threshold and/or revenue requirement for WVR listings;
- allowing a higher WVR ratio cap for larger issuers;
- refining the 'innovative' test to provide an express path to listing with WVR for non-tech issuers applying a new business model; and
- providing greater clarity on external validation requirements.
Issuers listed overseas
- lowering financial eligibility thresholds (for issuers with WVR structures) and the market capitalisation threshold (for issuers without WVR structures) for secondary listings;
- redrafting requirements for conversion from secondary listing to primary listing with clearer guidance; and
- seeking views on further measures to support overseas listed issuers.
Initial listing requirements and arrangements
- codifying existing guidance on ownership continuity and control;
- expanding the permitted use of US GAAP for subsidiaries of US-listed parents and companies with substantial US business operations, and removing certain limitations and requirements;
- allowing commercialised biotech and specialist technology companies to list under the specialist regimes even if financially eligible under the ordinary route;
- expanding the confidential filing option to all new applicants; and
- enhancing transparency when listing applications are not substantially complete and are returned by disclosing the identities and roles of responsible professional parties. [13 Mar 2026]
SFC issues circular regarding recent FATF statements
The SFC has issued a circular regarding recent statements made by the Financial Action Task Force (FATF). They include:
- an updated statement identifying jurisdictions that have strategic deficiencies in their anti-money laundering and combating the financing of terrorism regimes, which include jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures (the Democratic People's Republic of Korea and Iran) and those subject to a FATF call to apply enhanced due diligence measures (Myanmar);
- an updated statement on jurisdictions under increased monitoring (with the addition of Kuwait and Papua New Guinea); and
- other outcomes of the FATF's recent plenary of 11-13 February 2026 – The approvals of a paper on cyber-enabled fraud (published on 24 February 2026), a report on understanding and mitigating the risk of offshore virtual asset service providers (published on 11 March 2026), and a targeted report on stablecoins and unhosted wallets (published on 3 March 2026).
The Insurance Authority issued a similar circular regarding the above FATF statements on 3 March 2026 (see our previous update). [13 Mar 2026]
SFC and ICAC conduct joint operation on alleged insider dealing and corruption involving senior executives of SFC licensed corporations
The SFC and the ICAC have conducted a joint operation codenamed 'Fuse' targeting suspected insider dealing involving corruption. The operation stemmed from the SFC’s initial investigation of the suspected insider dealing activities, which uncovered potential corruption and prompted the SFC to refer the case to the ICAC for investigation.
The persons of interest include senior executives of three licensed corporations, which include two securities firms and a hedge fund management firm.
The regulators searched 14 locations (including offices and residences), and the ICAC arrested six men and two women, including senior executives of the licensed corporations and a middleman.
The investigation is ongoing. It is suspected that:
- senior executives of the two licensed securities firms had accepted bribes of over HK$4 million from the owner of the licensed hedge fund management firm, in return for disclosing confidential share placement information before such information was publicly announced; and
- the hedge fund management firm allegedly used the confidential information to establish short positions for its hedge fund in the relevant stocks by short selling the stocks in the market and/or entering into short equity swap contracts (the stock prices declined upon public announcement of the share placement and the hedge fund allegedly made profits of around HK$315 million).
The individuals are suspected of committing offences under the:
- Prevention of Bribery Ordinance – including offering advantages to agents and agents accepting advantages;
- Organised and Serious Crimes Ordinance – including handling property known or believed to represent proceeds of indictable offences (ie, money laundering); and
- Securities and Futures Ordinance – including insider dealing and other relevant crimes and misconduct. [12 Mar 2026]
HKMA issues circular requiring AIs to prepare strategic business plan to address technological developments within six months
The HKMA has issued a circular requiring authorised institutions (AIs) to proactively assess and adapt their long-term business models in response to accelerating digital transformation.
The HKMA has recently announced the Fintech Promotion Blueprint under 'Fintech 2030' to foster responsible innovation (see our previous update). It encourages the industry to move beyond simple adoption that layers technologies over existing processes, and explore how distributed ledger technology (DLT) and other transformational technologies can revamp banking services and redefine core business models for the future.
The HKMA expects AIs' boards of directors to oversee and endorse a formal strategic business plan to address the technological developments, within six months of the circular (ie by 9 September 2026). Plans should identify opportunities to adapt or transform product offerings, revenue models, customer engagement, risk management and operations, and may factor in how small‑scale real‑world trials can be conducted leveraging the HKMA’s Supervisory Incubator for DLT (see our previous update) to validate the novel business models involved. A selection of AIs will be invited to submit their plans via HKMA’s survey tool.
AIs intending to expand into new digital asset‑related activities should discuss their plans with the HKMA prior to launch.
The HKMA's Executive Director (Banking Supervision), Ms Carmen Chu, has commented that the strategic business plan will help banks understand how emerging technologies are impacting their business models, enabling them to make strategic responses to stay relevant, resilient and competitive. [9 Mar 2026]
SFC Chairman discusses priorities for HKSI in keynote remarks
In his keynote remarks at the Hong Kong Securities and Investment Institute (HKSI) Chair's Cocktail, Dr Kelvin Wong (SFC Chair) discussed the role of the HKSI as a guardian of professional competence and public trust, as well as three priorities he hopes that the HKSI will pursue:
- keep raising the bar on competence as new products and risks emerge, often driven by artificial intelligence;
- nurture judgement in addition to knowledge, to help practitioners embed good conduct, manage conflicts, ensure suitability, and treat customers fairly so that 'doing the right thing' is not a slogan, but a reflex; and
- broaden and strengthen the talent pipeline.
Dr Wong added that laws, rules and new technologies are important, but in the end, it is people – with the right skills, values and mindset – who keep our markets fair, orderly and vibrant. The SFC will continue to be a close and committed partner of the HKSI in fostering competence, judgment and a talent pipeline. [6 Mar 2026]
SEHK announces arrangements for test session and market rehearsal for implementation of Phase 2 of minimum spread reduction in securities market
The SEHK has announced an optional test session and mandatory market rehearsal to facilitate the implementation of Phase 2 of the reduction of minimum spreads in the Hong Kong securities market, targeted for mid-2026 (see our previous update).
- Optional end‑to‑end test session (23 March to 2 April 2026): Exchange participants and broker supplied systems vendors are strongly encouraged to join the Orion Central Gateway – Securities Market session to verify the respective system changes in relation to the implementation of Phase 2. HKEX Orion Market Data Platform – Securities Market will be available for testing during the same period (see separate circular from the HKEX Information Services Limited).
- Mandatory market rehearsal (April 2026 following completion of the above test session): All exchange participants are required to participate in this market rehearsal to confirm their readiness (further details to be announced in due course). [6 Mar 2026]
Regulators launch GenAI Sandbox++ to foster AI innovation across financial services
The HKMA, the SFC, the Insurance Authority, and the Mandatory Provident Fund Schemes Authority, in partnership with the Hong Kong Cyberport Management Company Limited (Cyberport), have announced the launch of the Generative Artificial Intelligence (GenAI) Sandbox++ initiative, a expanded version of the 2024 GenAI Sandbox (see our previous update).
The regulators state the initiative has been widened to cover multiple financial sectors, including banking, securities and capital markets, asset and wealth management, insurance, mandatory provident funds (MPF) and stored value facilities. GenAI Sandbox++ continues to prioritise risk management, anti‑fraud, and customer experience, while advancing 'AI vs AI' strategies that use AI tools to manage the risks created by AI adoption.
Participating institutions will receive targeted supervisory guidance, technical support, and complimentary graphics processing unit access at Cyberport’s AI Supercomputing Centre, enabling them to develop and pilot and refine AI use cases in a risk‑controlled environment.
The initiative aims to strengthen collaboration among regulators, financial institutions and technology firms to support responsible AI innovation and deeper cross‑sector and cross-boundary partnerships. It seeks to catalyse the development of sector‑specific and cross‑sector AI solutions – for example, AI‑driven insurance underwriting and claims processing, tools to support suitability and compliance assessments in investment product distribution, tools for MPF administration, and broader industry use cases such as intelligent customer chatbots and advanced fraud‑detection systems.
The regulators have issued a joint circular to encourage the industry to apply for participation in the GenAI Sandbox++, setting out details on the application process and assessment criteria in an annex. Applications are open until 30 June 2026. [5 Mar 2026]
HKMA and AMCM sign revised MoU to expand scope of collaboration
The HKMA and the AMCM have signed a revised memorandum of understanding (MoU) that broadens the scope of collaboration between the two authorities to include additional areas such as financial infrastructure linkage, information exchange on currency and data statistics, and industry training and engagement.
Both authorities noted that the revised MoU supports their shared strategic objective of developing the Guangdong–Hong Kong–Macao Greater Bay Area into an international financial hub. [3 Mar 2026]
SEHK issues reminders to exchange participants regarding aspects of order input and trading
The SEHK has issued the following circulars to remind exchange participants regarding order input and trading:
- Circular OPS/CS/003/26: Exchange participants should review and determine their own order consideration limit (also known as notional value in OCG-C interface specifications) in accordance with their business needs and financial strength; and
- Circular CT/025/26: All order inputs are valid and all trades concluded should not be amended or cancelled unless otherwise determined by the Board of the SEHK. [2 Mar 2026]
MAS: Key enforcement actions Q1 2026
MAS has published a summary of the key enforcement actions it has taken during the period January to March 2026. [1 Apr 2026]
MAS announces successful conclusion of phase two of Project MindForge
MAS has announced the successful conclusion of phase two of Project MindForge, which culminates in the publication of an AI Risk Management Toolkit for the financial services sector. This toolkit, developed collaboratively by a consortium of 24 leading banks, insurance companies, capital market firms, and other industry partners, provides financial institutions with resources for managing AI-related risks across traditional AI, generative AI, and emerging agentic AI technologies.
The MindForge AI Risk Management Toolkit features an ‘AI Risk Management Operationalisation Handbook’ that provides detailed, practical guidance on implementing AI risk management frameworks. This handbook is accompanied by a supplement that features a compilation of AI case studies that document the experiences and lessons learned from financial institutions.
The Operationalisation Handbook is organised into four sections, which are aligned with MAS’ proposed Guidelines:
- Scope and oversight – Establishment of AI governance framework, and clarity of roles and responsibility for AI oversight;
- AI risk management – Identification of AI usage, risk materiality assessment, and AI inventorisation through organisational systems, policies and procedures;
- AI lifecycle management – Implementation of controls covering the entire lifecycle of AI use; and
- Enablers – Development of organisational capabilities, infrastructure, and resources to enable ongoing responsible AI use and risk management.
To facilitate broader industry adoption of AI risk management practices and solutions, MAS will establish an AI risk management workgroup comprising MindForge consortium members and other industry practitioners under the BuildFin.ai initiative to develop implementation resources, facilitate knowledge sharing, and build capabilities and frameworks for managing risks from newer AI technologies such as agentic AI. [20 Mar 2026]
MAS consults on proposed regulatory framework for CSDs
MAS has published a consultation setting out proposals to update and enhance the regulatory regime for central securities depositories (CSDs). The proposals are intended to appropriately align the regulatory regime for CSDs with those governing other systemically-important market infrastructure such as central counterparties and securities settlement systems under the Securities and Futures Act 2001. Among other changes, MAS is proposing to adopt an entity-neutral approach and also to apply to two-tier approach to CSDs.
MAS will consult on legislative amendments after it has finalised these proposals. Feedback to the CP is requested by 20 April 2026. [19 Mar 2026]
MAS consults on dematerialisation
MAS has published Consultation Paper on Proposed Dematerialisation Regime for Shares of Listed Companies. In the CP, MAS sets out proposals for a regime that will remove the requirement for physical share certificates and allow title to shares of listed companies to be evidenced electronically.
MAS will consult on legislative amendments after it has finalised these proposals. Feedback to the CP is requested by 20 April 2026.
Note that references to CSDs in this CP should be understood as referring to any person approved under the proposed regulatory framework for CSDs which MAS is currently consulting on. [19 Mar 2026]
MAS issues prohibition orders against individuals following AML convictions
MAS has announced that it issued prohibition orders under the Financial Services and Markets Act 2022 against two individuals convicted of charges relating to a major money laundering case from August 2023. Reflecting "the gravity of the misconduct", MAS imposed prohibition orders of 16 and 7 years. [17 Mar 2026]
MAS: Guidelines on environmental risk management – transition planning
MAS has published three guidelines that set out its supervisory expectations for banks, insurers and asset managers to manage the transition and physical risks they and their portfolios face from climate change. In particular, MAS expects relevant firms to:
- assess and manage the risks by adapting their business models, governance and risk management practices in a forward-looking manner;
- engage customers and investee companies to better understand the climate-related risks they face and their management of such risks, so as to avoid the indiscriminate withdrawal of credit, insurance coverage, or investments, and support broader financial stability; and
- keep pace with the development of knowledge and capabilities relating to the measurement and management of climate-related risks, as data and methodologies around the understanding of such risks continue to improve.
The guidelines will take effect from September 2027. [5 Mar 2026]
MAS: Response to PQ on green and sustainability-linked loan data
MAS has published its response to a Parliamentary question on the total value and number of green and sustainability-linked loans in Singapore over the past five years. MAS stated that a total of 261 green, social, sustainability, and sustainability-linked loans, worth SGD 137.3 billion, were taken up by Singapore companies between 2020 and 2024. [4 Mar 2026]
SCM updates guidelines on fund management, lodge and launch framework and Islamic capital market products and services
SCM has published revisions to the:
- Guidelines on Compliance Function for Fund Management Companies – the amendments facilitate the investment into private debt notes and Islamic private debt notes by licensed fund management companies;
- Guidelines on Unlisted Capital Market Products under the Lodge and Launch Framework – the Guidelines were revised to facilitate the issuance of private debt notes and Islamic private debt notes by private companies to specific persons; and
- Guidelines on Islamic Capital Market Products and Services – the revisions update certain requirements and provide clarity on the process and application of certain requirements under the Guidelines. [30 Mar 2026]
BNM: Revised reference rate framework
BNM has published a policy document on a revised reference rate framework, effective 1 July 2026, aimed at ensuring timelier and effective monetary policy transmission in practice. The revised framework strengthens expectations on banks to promptly reflect reference rate changes to customers' monthly instalments for their floating retail loan or financing. It also enhances disclosure standards for the benefit of customers. [27 Mar 2026]
SCM establishes innovation lab to develop new ICM products and instruments
SCM has announced the establishment of the Islamic capital market (ICM) Innovation Lab (FIKRALab), a structured co-creation and applied research and development platform to develop new ICM products and instruments.
The FIKRALab, an initiative under the Capital Market Masterplan 2026–2030, aims at advancing Malaysia’s ICM, anchored on Maqasid al-Shariah and guided by Halal-Toyyib. Through the FIKRALab, the SCM seeks to catalyse the development of Maqasid al-Shariah-driven ICM products and services that deliver ethical objectives, real economic value and broader social impact. [26 Mar 2026]
BNM: Highlights of Hire-Purchase (Amendment) Act 2026
BNM has published a consumer guide on key changes introduced by the Hire‑Purchase (Amendment) Act 2026. The legislation will come into force on 1 June 2026, with a transition period until 31 March 2027 during which banks may update their systems, processes, and infrastructure. The reforms are intended to strengthen consumer protection, improve transparency in hire‑purchase financing and provide greater flexibility through digital documentation options. [17 Mar 2026]
SCM: MyCIF launches MSME funding initiatives
SCM has announced that the Malaysia Co-Investment Fund launched new initiatives for micro, small, and medium enterprises (MSMEs) to seek funding in emerging growth areas. The initiatives comprise:
- the Silver Economy Scheme to encourage investments into MSMEs supporting Malaysia’s ageing population, specifically in care-tech, specialised healthcare and senior living; and
- the VC/PE Profit-Sharing Incentive to attract venture capital and private equity led deals on equity crowdfunding platforms, giving opportunities to crowd investors to participate in institutionally backed deals. [16 Mar 2026]
BNM policy document: Technology requirements for payment services firms
BNM has published a policy document that outlines new requirements for managing technology risks by payment services firms. The publication is designed to consolidate the technology requirements within the payment sector into a single policy document, primarily for the approved issuers of electronic money, registered merchant acquirers and money services businesses. [12 Mar 2026]
SCM: Capital Market Masterplan 2026-2030
SCM has published the Capital Market Masterplan 2026-2030, a strategic blueprint aimed at positioning Malaysia’s capital market as a key driver of national growth and economic prosperity.
With a long-term 20-year vision, the plan is intended to support economic transformation by accelerating growth in emerging sectors while strengthening the market’s role in building a more advanced, inclusive, sustainable and regionally integrated economy. [9 Mar 2026]
BNM/SCM consult on sustainable finance taxonomy
The Malaysia Taxonomy for Sustainable Finance Taskforce, co-chaired by BNM and SCM under the Joint Committee on Climate Change, has published a call for feedback on its proposed taxonomy for sustainable finance. The publication covers:
- key elements of sustainable finance taxonomy;
- taxonomy assessment and classification approach as well as consolidation of taxonomy reporting at entity and portfolio level based on underlying exposures; and
- applicability of the taxonomy for insurance and takaful operators.
Feedback is requested by 14 April 2026. [2 Mar 2026]
SECT amends regulations to accommodate tokenised funds
SECT has amended certain regulations to accommodate the sale and redemption of mutual fund units issued in tokenised form. The changes are intended to enable faster transaction processing and to enhance clarity and appropriateness. [2 Apr 2026]
SECT consults on proposed amendments to credit rating requirements for bonds with foreign risk exposure
SECT has issued a consultation on proposed amendments to the credit rating requirements applicable to the issuance and offering of bonds in Thailand by foreign entities, as well as securitized bonds with foreign risk. The proposed amendments aim to align the requirements with the practices of international credit rating agencies and to facilitate fundraising by issuers.
Feedback is requested by 20 April 2026. [20 Mar 2026]
SECT consults on issuing Travel Rule to strengthen AML risk management
SECT has published a consultation on proposed principles for establishing requirements for receiving and transmitting information accompanying digital asset transfers (known as the Travel Rule). The proposal is designed to ensure that digital asset business operators possess sufficient supporting information for anti‑money laundering verification and risk management, align with international standards, and support the effective prevention of technology‑related crimes. Comments are requested by 25 March 2026. [10 Mar 2026]
SECT revises criteria for determining major shareholders of securities and digital asset business operators
SECT has announced revisions to the criteria for determining persons who qualify as major shareholders of securities and digital asset business operators requiring approval. The revised criteria are intended to ensure that the approval process also covers ultimate controlling persons.
SECT stated that business operators must review the status of their major shareholders and submit approval requests for any individuals who meet the new criteria within 180 days. [5 Mar 2026]
SECT allows Thai ESG funds to invest in JUMP+ firms
SECT has issued a notification revising the regulations governing Thailand ESG Funds to expand the scope of eligible assets to include shares of listed companies participating in the Stock Exchange of Thailand’s JUMP+ Program with a Corporate Governance Report score of at least 90. [4 Mar 2026]
SECT broadens definition of institutional investors and expands types of eligible investment capital
SECT has announced it approved amendments to the definition of institutional investors to appropriately encompass capital market business operators and personnel. It has also broadened the investment capital definition to more accurately reflect investors’ financial standing and encompass a wider range of existing investment products. [4 Mar 2026]
SEBI consultation: Reintroduction of open market buy-back of shares or other specified securities through stock exchange
SEBI has published a consultation on proposals to re-introduce open market buy-back of shares or other specified securities through stock exchange as an additional method under SEBI (Buy-Back of Securities) Regulations, 2018. Responses are requested by 23 April 2026. [2 Apr 2026]
RBI: Payments Vision 2028\
The RBI has published the Payments Vision 2028 outlining 15 initiatives that will be undertaken over the next three years. The document focuses on user empowerment, strengthening safeguards against fraud, enhancing efficiency of cross-border payment frameworks and promoting ease of doing business, among others. [27 Mar 2026]
RBI: Unique identifiers in financial markets
The RBI has published a master direction on unique identifiers in financial markets, with a view to improve accessibility of regulatory instructions and ease of doing business. Legal entity identifier (LEI) and unique transaction identifier (UTI) are key data elements identified globally for reporting over-the-counter derivative transactions. While LEI uniquely identifies the counterparties to a transaction, UTI serves as a single unique reference number for the transaction. [27 Mar 2026]
SEBI launches 'Verified' label for stock trading apps
SEBI has launched an investor protection measure in the form of a Verified Label for stock trading apps of brokers registered with SEBI. SEBI, in collaboration with Google, has taken this initiative to implement a first-of-its-kind 'Verified' badge on Google Play, for all stock trading apps in India that are offered by entities that are registered with SEBI. The 'Verified' label may be extended to apps of other regulated intermediaries. [25 Mar 2026]
SEBI: Addendum to SEBI Circular on intraday borrowing by mutual funds
SEBI has announced that, in order to address the operational challenges raised by asset management companies, the application of provisions related to intraday borrowings in clause 5.9.1 of its 20 March 2026 Master Circular will apply from 15 July 2026. [25 Mar 2026]
SEBI consults on facilitating the 'gifting' of mutual fund units
SEBI has published a CP on introducing a gift card/gift PPI(prepaid payment instrument) for mutual funds. SEBI is proposing to facilitate the gift of mutual fund units via a new Gift Card or Gift PPI. This is expected to improve financial inclusion through onboarding of new investors in the mutual fund space.
Responses are requested by 14 April 2026. [24 Mar 2026]
SEBI: Master Circular for Mutual Funds
SEBI has updated the Master Circular for Mutual Funds and includes all relevant circulars issued to Mutual Funds till 20 March 2026. This Master Circular shall come into force with effect from 1 April 2026. [20 Mar 2026]
SEBI consultation: Modified norms for nomination in demat accounts and mutual fund folios
SEBI has published a consultation on proposed modifications to the rules for nomination in demat accounts and mutual fund folios. The proposals are aimed at improving investor on-boarding and nomination processes.
Comments are requested by 7 April 2026. [17 Mar 2026]
SEBI consults on simplification of documentation requirement for transmission of securities
SEBI has published a consultation on proposals to simplify the documentation requirement for transmission of securities and to revise limits for simplified documentation. Reponses are requested by 2 April 2026. [12 Mar 2026]
RBI: Directions on prudential norms on declaration of dividend and remittance of profit
The RBI has published a set of revised Directions on prudential norms concerning declaration of dividend and remittance of profits. The Directions will come into effect from financial year 2026-27. [10 Mar 2026]
RBI: Draft amendment Directions on limiting customer liability in digital transactions
The RBI has published for feedback revised Directions on limiting liability of customers in unauthorised electronic banking transactions. The amendments are designed to: enhance the scope of existing instructions to cover other categories of fraudulent electronic banking transactions, reduce the time taken by banks to process complaints related to fraudulent electronic banking transactions, and introduce a compensation mechanism for small value fraudulent electronic banking transactions.
The proposed compensation mechanism will be in force for one year from the effective date of the Directions. Comments are requested by 6 April 2026. [6 Mar 2026]
SEBI: Regulatory reporting by AIFs
SEBI has published a circular on the reporting format and the frequency with which alternative investment funds are required to submit activity reports to SEBI. The circular has immediate effect. [4 Mar 2026]
IFSCA sets out fee structure
IFSCA has published a circular setting out its fee structure for entities undertaking or intending to undertake permissible activities in the IFSC, or persons seeking guidance under the Informal Guidance Scheme. [2 Mar 2026]
SECP, DICT and NPC advisory on borrowers' data privacy
SECP, the Department of Information and Communications Technology and the National Privacy Commission have issued a joint advisory which reminded lending and financing companies about the existing rules on processing of borrowers' personal data for loan-related transactions. The advisory particularly discusses online lending platforms. [24 Mar 2026]
SECP: Request for comments on the proposed amendments to 2015 SRC Rules which identifies Qualified Buyers that are exempt from registration
SECP has proposed amendments to Rule 10.1.11.1 of the 2015 Implementing Rules and Regulations of the Securities Regulations Code (2015 SRC Rules). The rule identifies Qualified Buyers that are exempt from registration because they possess the financial capacity and investment sophistication necessary to evaluate the risk associated with securities offerings.
Comments are requested by 31 March 2026. [20 Mar 2026]
SECP consults on term limit of exchange broker directors
SECP has published for consultation a draft memorandum circular on proposed rules on the term limit of broker directors of an exchange.
According to the proposal, a broker director may be elected for a term of one year, subject to a maximum cumulative period of ten years, whether consecutive or intermittent, in the same exchange. Responses are requested by 19 March 2026. [4 Mar 2026]
BSP raises due diligence threshold for cash withdrawals
BSP has decided to raise the threshold for cash withdrawals that would trigger enhanced due diligence from ₱500,000 to ₱1 million. The increase follows consultations with banks and industries, which showed a large number of legitimate cash transactions above the original threshold. There remains to be no thresholds on non-cash withdrawals.
The BSP also clarified that for individuals and businesses with regular large transactions, the EDD will be done on a per customer basis, not per transaction. [2 Mar 2026]
FSC: Primary examination findings and corrective actions for FIs in H2 of 2025
FSC has announced its primary examination findings and for financial institutions in the H2 of 2025. The findings are set out by business activity, accompanied by recommended corrective actions. The findings cover 12 industry sectors including financial holding companies. The main issues include: anti-money laundering, countering the financing of terrorism and countering proliferation financing (AML/CFT/CPF); customer protection; cyber security; and real estate lending business. [19 Mar 2026]
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