APAC Monthly Private Wealth Legal Developments – December 2025

HKEX publishes Compliance Bulletin regarding HKIDR BCAN-CID mapping file submission requirements

The HKEX has published the 16th issue of its Compliance Bulletin to remind exchange participants (EPs) and relevant regulated intermediaries (RRIs) regarding certain salient points in relation to the Hong Kong Investor Identification Regime (HKIDR) under the Rules of the Exchange (SEHK Rules), specifically on the submission requirements of the broker-client assigned numbers (BCAN) – client identification data (CID) mapping file.

• Requirements under the SEHK Rules – RRIs are reminded to observe and comply with the requirements under SEHK Rules 538A(3) and 538A(4) regarding the preparation and submission of the BCAN-CID mapping file to the SEHK in the prescribed manner and by the specified deadlines.  They are also reminded to review the reference materials available on the dedicated HKIDR webpage.
• Common deficiencies and instances of non-compliance – Among other things, certain RRIs have tagged orders with a non-recorded BCAN (ie, BCAN which is not included in BCAN-CID mapping file and validated by the SEHK’s system).  While such orders are not rejected by SEHK’s trading system, tagging with a non-recorded BCAN constitutes a breach of SEHK Rules 538A(3) and 538A(4), and will give rise to standard penalties.
• Good practices – The SEHK has set out some of the good practices observed regarding the submission of the BCAN-CID mapping file, such as those related to system testing, automation of processes, robust system controls to prevent non-compliant order tagging, maker-checker mechanism, timely reconciliation of internal records with submissions to the SEHK, and proper staff training.
• Standard penalties – RRIs (which are EPs) are reminded that non-compliance with SEHK Rules 538A(3) and 538A(4) will give rise to the application of the Standard Penalty Procedures as stipulated in Part II of the Disciplinary Procedures of the SEHK Rules.

The HKEX notes that the requirements and examples set out in the compliance bulletin are not exhaustive.  EPs and RRIs should take into consideration their own circumstances to ensure full compliance with the relevant rules and requirements, and seek their own professional advice on their specific situations where appropriate.  [31 Dec 2025]

HKMA issues further FAQs on sale and distribution of green and sustainable investment products following thematic review

The HKMA has issued a circular to inform registered institutions (RIs) that it has prepared further frequently asked questions (FAQs) to clarify aspects of the circular guidance dated 29 November 2023 on the sale and distribution of green and sustainable investment products (2023 Circular) (see our previous update).

Since the issue of the 2023 Circular, the HKMA has conducted a thematic review on RIs' implementation of the expected standards under the circular.  The following are some observations by the HKMA:

• RIs have generally implemented the expected standards, including putting in place policies, procedures and controls to manage greenwashing risks.
• There is an increase in the number of RIs participating in bookbuilding activities, and they have implemented the expected standards in the 2023 Circular for such activities.
• Some RIs have yet to establish proper policies and procedures governing the classification framework for green and sustainable investment products.  They have committed to enhancing their policies and procedures to strengthen the governance and oversight of these products.

The latest FAQs include additional guidance and further practices noted from RIs.  They also clarify the inapplicability of the expected standards (except on bookbuilding) in the 2023 Circular to transactions where RIs do not market or classify the investment product as green and sustainable.  [29 Dec 2025]

AFRC proposes mandatory sustainability assurance to reinforce Hong Kong as leading green finance hub

The AFRC has published a consultation paper on a proposed regulatory framework for sustainability assurance in Hong Kong.  The proposed framework seeks to promote high-quality assurance by adopting international standards, enhancing the credibility and reliability of sustainability disclosures, and ensuring a level playing field for all assurance providers.  Feedback is required to be submitted by 30 March 2026 via this form.

The consultation paper covers five key proposals under the framework:

• Subject to further consultations by the HKEX and relevant financial regulators, all entities subject to mandatory reporting using the Hong Kong Financial Reporting Standards Sustainability Disclosure Standards (Mandatory HKSDS Reporting) must obtain independent assurance;
• Subject to the above further consultations, all in-scope entities must obtain limited assurance in phase 1 (Scope 1 and 2 greenhouse gas emission disclosures from the third financial year of the Mandatory HKSDS Reporting) and phase 2 (all remaining HKSDS-mandatory disclosures from the fifth financial year of the Mandatory HKSDS Reporting);
• Mandatory assurance must be provided by registered sustainability assurance providers (SAPs);
• Mandatory assurance must be carried out in compliance with the Hong Kong Standard on Sustainability Assurance 5000; and
• A single regulatory model is proposed to register and regulate all SAPs and oversee the related standard-setting by the Hong Kong Institute of Certified Public Accountants.

The AFRC welcomes feedback from all stakeholders, in particular listed companies and non-listed financial institutions, investors, assurance providers (whether certified public accounting firms or not), and professional bodies.  [29 Dec 2025]

HKMA announces total quota allocated for RMB Business Facility and list of participating banks from Phase 2 onwards

The HKMA has announced the expanded list of 40 participating banks starting from Phase 2 of the RMB Business Facility, with the total quota allocated to participating banks increased from RMB 50 billion to RMB 100 billion.  This follows the HKMA's announcement on 26 September 2025 of the introduction of the facility in three phases (see our previous update).

The scope of eligible RMB financing activities was broadened to cover RMB capital expenditure and working capital term loans in Phase 2, which commenced on 1 December 2025.  The 40 participating banks can apply for RMB funds from the HKMA within their assigned quota under the facility, to provide RMB financing to local and overseas corporates.

The specific quota assigned to each of the 40 participating banks is based on the bank’s existing scale of relevant business, expected pipeline, and the geographical reach of its overseas intragroup banking entities.  The facility usage of the 24 banks that participated in the previous RMB Trade Financing Liquidity Facility and Phase 1 of the present facility has also been taken into account. 

The HKMA will consider adding more participating banks as appropriate, subject to actual facility usage and market demand.  [29 Dec 2025]

FSTB and SFC conclude consultations on VA dealing and custodian services regimes and launch further consultation on VA advisory and management services regimes

The FSTB and the SFC have jointly published consultation conclusions on legislative proposals for establishing licensing regimes for virtual asset (VA) dealers and custodian service providers (see our previous update regarding the launch of the consultations).  They have also launched a further consultation on new regimes for VA advisory and management service providers.  Comments are required to be submitted by 23 January 2026.

Conclusions on licensing regimes for VA dealers and custodian service providers

In view of the market support, the FSTB and the SFC will proceed with the legislative proposals.

• The VA dealer regime will be closely aligned with that for Type 1 regulated activity (dealing in securities) under the Securities and Futures Ordinance, with similar exemptions under consideration.
• The VA custodian service provider regime will focus on managing risks related to safekeeping private keys of client VAs in Hong Kong, to secure client assets and protect investors.
• No deeming arrangements will be granted to existing VA dealing or custodian service providers.  Industry stakeholders already engaged in or interested in providing VA dealing or custodian services are encouraged to reach out to the SFC or the HKMA (as applicable) as soon as possible to initiate the pre-application process.

Consultation on licensing regimes for VA advisory and management service providers

• In response to the feedback received, the FSTB and the SFC has launched a further consultation on establishing separate licensing regimes for VA advisory and management service providers, instead of covering the relevant VA activities under the licensing regime for VA dealing service providers as originally proposed.  This revised regulatory approach will model itself on the regulatory framework applicable to the conventional securities market, and will provide better clarity as regards the scope of activities regulated under different VA licensing regimes.

The FSTB and the SFC aims to finalise the legislative proposals for establishing the licensing regimes for VA dealing, advisory, management, and custodian service providers under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, with a view to introducing a bill into the Legislative Council in 2026.  [24 Dec 2025]

SFC issues circular to licensed corporations regarding exemption for non-centrally cleared equity options from margin requirements

The SFC has issued a circular to inform licensed corporations that, to align with the latest global developments, it will exempt non-centrally cleared single-stock options, equity basket options and equity index options (collectively, non-centrally cleared equity options) from its margin requirements until further notice.

The margin requirements were originally scheduled to take effect on 4 January 2026.  However, to prevent regulatory arbitrage and considering that licensed corporations’ exposures to non-centrally cleared equity options are currently insignificant, the SFC has decided to align the exemptions of its margin requirements with the approaches in the EU and the UK.

The amendments to paragraph 7(e) of Part III of Schedule 10 to the SFC's main code of conduct to reflect the above have been gazetted.  [22 Dec 2025]

HKMA, CEDB and IPD launch IP Financing Sandbox

The HKMA, in collaboration with the CEDB and the IPD, has launched the Intellectual Property (IP) Financing Sandbox.  Three major banks have joined the sandbox as inaugural participants, and have solicited interest from clients from the biotechnology, electronics and technology sectors to conduct pilot trials of IP financing through the sandbox. 

The sandbox aims to assist pilot sectors in leveraging IP assets for financing, providing a risk-controlled environment for authorised institutions (AIs) to conduct pilot trials of financing arrangements based on IP assets (such as patents, trademarks and copyrights), supported by professional service providers such as IP valuation firms and legal practitioners participating in the sandbox. 

AIs will be able to test the full lifecycle of an IP financing transaction, and may seek feedback from the HKMA and receive support from other participating stakeholders in developing and refining their IP financing arrangements.  The HKMA, the CEDB and the IPD have jointly repared operating principles for the sandbox.

Based on the practical insights gained from the sandbox, the HKMA will share good practices and consider the need for developing further supervisory guidance on the credit risk management aspect of IP financing.  The Government, through the CEDB and the IPD, will also assess the need for developing a set of local IP valuation guidelines incorporating standards that are acceptable to all stakeholders.  [22 Dec 2025]

OTC Clear outlines planned initiatives for 2026

OTC Clearing Hong Kong Limited (OTC Clear) has issued a circular setting out a series of planned initiatives for 2026 to enhance operational resilience, trade efficiency and risk management for clearing members.

• Secure File Transfer Protocol (SFTP) facilities upgrade for the Report Access Platform – A technical upgrade will be implemented in the first quarter of 2026.  A verification session will be arranged to allow clearing members to test compatibility.
• Annual OTC Clearing and Settlement System (OCASS) / OTC Account Services Information System (OASIS) data centre failover rehearsal – The rehearsal, taking place tentatively in the third quarter of 2026, is aimed at familiarising clearing members and related parties with contingency procedures for failover of OCASS / OASIS data centres, as well as data centre failover of other HKEX systems.  Details of the rehearsal will be announced in the second quarter of 2026 tentatively.
• Enhancement to HKD settlement workflow – OTC Clear plans to leverage its account on the Real Time Gross Settlement platform for HKD settlements starting in 2026 (tentative).  A familiarisation session for interested clearing members is tentatively planned for the fourth quarter of 2026, with details to follow in the third quarter.
• Provision of risk parameter files for margin estimation – OTC Clear will introduce enhanced margin estimation capability in 2026 to enable clearing members to simulate standalone trades to estimate margin requirements for new positions prior to execution, and to project incremental margin impact when adding new trades to an existing portfolio.
• Additional Approved Trade Registration System (ATRS) for Deliverable FX Derivative – OTC Clear plans to connect to an additional ATRS in 2026 (tentative) for the submission of the Original FX Derivatives Transaction. Further details on this arrangement are expected to be communicated in the third quarter of 2026.
• Margin buffer for client clearing – To reduce trade rejections caused by temporary insufficient margin balances of the clearing member’s relevant client collateral accounts, OTC Clear plans to introduce an optional client margin buffer service in the third quarter of 2026 tentatively (further details to be announced).

OTC Clear highly recommends clearing members to coordinate with their IT teams and vendors for planning and preparation in light of the above.  [19 Dec 2025]

HKEX consults on proposed enhancements to board lot framework

The HKEX has announced (via a press release and a circular) that it has published a consultation paper on proposed enhancements to the board lot framework for the Hong Kong securities market, aimed at improving market efficiency, reducing operational complexity and improving investor accessibility.  Feedback on the proposals is required to be submitted by 12 March 2026.

The proposed enhancements apply to equities and real estate investment trusts, and comprise of the following three components:

• Reduction of board lot value floor guidance from HK$2,000 to HK$1,000;
• Introduction of board lot value ceiling guidance at HK$50,000;
• Reduction of board lot units to a set of eight standardised options: 1, 50, 100, 500, 1,000, 2,000, 5,000, and 10,000 shares.

The consultation paper proposes a two-phase implementation approach:

• In the first phase, new issuers will be required to list with standardised board lot units and adhere to board lot value guidance, while existing issuers will be required to follow the updated guidance on board lot values.
• In the second phase, each existing issuer will be required to adopt one of the standardised board lot units within a specified period following their transition to uncertificated shareholding under the Uncertificated Securities Market initiative.  Aligning the implementation schedule of the two initiatives avoids the need to reprint share certificates following board lot unit changes.  Further details on the transition will be communicated at a later stage.

Separately, the HKEX is also considering enhancements to its odd lot trading mechanism to improve trading efficiency under the new board lot framework.  More details will be announced in due course.  [18 Dec 2025]

HKSCC outlines 2026 planned initiatives for securities market

The HKSCC has issued a circular setting out a series of planned initiatives for the securities market in 2026 to support system resilience, automation, and post‑trade infrastructure modernisation.

• Secure File Transfer Protocol (SFTP) facilities upgrade for the Report Access Platform – A technical upgrade will be implemented in the first quarter of 2026.  A verification session will be arranged to allow participants and designated banks to test compatibility.
• Digital platform for exchange traded product (ETP) creation and redemption – A new digital platform will be introduced to facilitate in‑kind creation and redemption processes for relevant ETPs, designed to streamline operational workflows.  The platform is scheduled for rollout in 2026, subject to technical readiness and regulatory approval.
• New post-trade services on Orion Cash Platform – In mid‑2026, subject to regulatory approval, the HKSCC will launch new clearing services to support real‑time trade information and reference data transmission via the Application Programming Interface.  In late 2026, subject to regulatory approval, the SFTP service will be extended to support participants in uploading batch files for corporate action instructions (details to be announced in the first quarter of 2026).
• Uncertificated Securities Market (USM) – The SFC, the HKEX, and the Federation of Share Registrars Limited are jointly progressing the implementation of the USM.  The dedicated webpage includes guides and FAQs to prepare the market for implementation.  Briefing and practice sessions will also be held in due course. 

A summary of the initiatives are set out in the appendix to the circular.  [18 Dec 2025]

SFC publishes quarterly report for July to September 2025

The SFC has published its quarterly report, summarising key developments from July to September 2025. The highlights covered by the report include (among others):

Maintaining market resilience and mitigating harm

• The SFC conducted 56 on‑site inspections to assess intermediaries’ compliance and operational resilience.
• A joint SFC-HKMA statement was published to caution against abrupt stablecoin‑linked market movements, and the SFC and other regulators launched the Anti‑Scam Consumer Protection Charter 3.0 to strengthen collaboration with technology and telecommunications firms to combat financial scams.  An investor education campaign on scams was also launched.
• The SFC fined six licensed corporations a total of HK$45.5 million and disciplined nine individuals by suspending their licences or prohibiting them from re-entering the industry for four months to life.
• The SFC collaborated with the Stock Exchange of Hong Kong Limited in its first disciplinary action against two former directors of a listed company for failing to cooperate in investigations conducted by both regulators.
• The SFC opened 22 new enquiries into listed company affairs and 60 new misconduct investigations.
• The SFC is reviewing the feedback on its consultation on restricting the use of certain names to avoid misleading investors.

Enhancing Hong Kong market competitiveness

• Twenty‑four IPOs raised over HK$70 billion, more than 70% higher than a year ago.  The SFC processed 121 new listing applications, including pre-profit biotech and specialist technology companies.
• The SFC and HKMA announced the Fixed Income and Currency (FIC) Markets Roadmap to reinforce Hong Kong’s role as a global FIC hub.
• Various initiatives to enhance market infrastructure and efficiency were underway, including increase in position limits for exchange-traded derivatives based on three major stock indices, and phase 1 of the reduction in minimum trading spreads.
• The number of new licensees and registrants totalled 3,865.

Transforming markets via technology and ESG

• Consultations on VA dealing and custodial regimes closed in August 2025.  The SFC and the HKMA allowed intermediaries to offer staking services and use off‑platform VA trading services of licensed virtual asset trading platforms (VATPs).
• As at the end of September 2025, 11 VATPs were licensed and eight applications were under review.  Three additional VA spot exchange traded funds investing directly in bitcoin and Ether were authorised in July 2025.
• The SFC authorised two tokenised retail money market funds, bringing the total to five with HK$5,387 million in assets under management.
• The SFC co‑hosted various sustainability‑focused events, including during the Hong Kong Green Week.

Enhancing SFC’s resilience and efficiency

• The SFC upgraded the WINGS system for electronic submissions for company re-domiciliation and itinerant professional regimes, and for meeting VATP record-keeping requirements. The Financial Return Form on WINGS was also expanded to collect hedge fund data biannually from licensed firms holding the Type 9 (asset management) licence.
• Senior executives spoke at over 25 events, and the SFC and HKMA co‑hosted the Hong Kong FIC Forum 2025.  [17 Dec 2025]

HKMA issues circular following thematic review to provide guidance on combating high-end money laundering

The HKMA has issued a circular to share observations regarding high-end money laundering, ie, money laundering and terrorist financing (ML/TF) typologies that involve the use of sophisticated methods to circumvent the anti-money laundering and counter-financing of terrorism (AML/CFT) controls of financial institutions.

The circular follows the HKMA's thematic review of the adequacy and effectiveness of AIs’ AML/CFT controls in mitigating the ML/TF risks associated with high-end money laundering.  The review found that AIs had generally established adequate and effective AML/CFT controls, although some areas for enhancement were identified.

• Understanding ML/TF risks: There was room for improvement in some AIs’ implementation of customer risk assessment frameworks.  AIs should pay attention to risk factors such as multiple nationalities or material changes in customer profiles (especially when multiple risk factors exist), and apply effective additional controls proportionate to those risks.  Adequate training and guidance to staff should be provided.
• Customer due diligence (CDD): Some AIs need to improve the implementation of CDD measures so that it is proportionate to the ML/TF risks associated with customer relationships.  AIs should periodically monitor the portfolios of retail high-net-worth customers and apply additional CDD measures proportionate to the associated ML/TF risks.
• Source of wealth (SoW) and source of funds (SoF): In a few cases, the AIs' front-line staff had over-relied on customer representations when establishing SoW and SoF, without seeking clarification regarding ambiguities, challenging the reasonableness of the information provided, or obtaining additional documentation for corroboration.  AIs should provide front-line staff with sufficient operational guidance and support to effectively handle higher-risk customer relationships.
• Transaction monitoring: Certain alerts were closed by AIs without sufficient justification and analysis.  AIs should adequately assess the reasonableness of transactions taking into account the customer risk profiles and historical transactions.
• Information sharing among banking affiliates: Some AIs had mechanisms for sharing information concerning customer relationships presenting higher-risk indicators among affiliates of their banking groups operating in different jurisdictions, enabling a more holistic view of customer relationships.

AIs are advised to conduct gap analyses and optimise AML/CFT controls based on the above guidance.  The HKMA will continue to engage with the industry and provide further guidance where appropriate.  [12 Dec 2025]

SFC issues circular regarding update to FSP list under OTC derivatives clearing regime taking effect on 1 January 2026

The SFC has issued a circular to inform the industry that the revised list of persons designated as financial services providers (FSPs) for the purposes of the Securities and Futures (OTC Derivative Transactions – Clearing and Record Keeping Obligations and Designation of Central Counterparties) Rules (Clearing Rules) was gazetted and took effect on 1 January 2026.

The revised list (Notice no. 7742) can be accessed from the Government Notice page for 12 December 2025 (No. 50, Vol. 29) on the e-Gazette portal. 

This follows the SFC and the HKMA's joint consultation conclusions in June 2025 on the annual update to the FSP list under the over-the-counter (OTC) derivatives clearing regime (see our previous update).

Licensed Persons are reminded that if their average total position in OTC derivatives during a calculation period reaches the corresponding clearing threshold, relevant OTC derivative transactions they enter into on and after the corresponding prescribed day, including those with FSPs, must be centrally cleared in accordance with the Clearing Rules.  Further information can be found in the relevant FAQs.  [12 Dec 2025]

SFC reprimands and fines registered institution HK$10.85 million for failures relating to product due diligence, record-keeping and late reporting following referral of findings from HKMA

The SFC has reprimanded and fined a registered institution HK$10.85 million for failures relating to product due diligence, record-keeping and late reporting between January 2015 and December 2020.  The SFC’s investigation stemmed from a self-report from the institution and a referral of findings from the HKMA.

The SFC found that the institution had failed to:

• take into account one or more special product features of 322 bonds when conducting product due diligence (including two bonds where the institution has failed to classify as 'complex' after the complex product regime came into effect on 6 July 2019);
• update its product due diligence internal policies promptly to reflect the complex product regime;
• ensure that sufficient information (such as special product features or other minimum information) was provided on 29 occasions, and that warning statements relating to the distribution of certain complex products were provided to customers on 14 occasions before or at the point of each transaction;
• keep product due diligence records for 141 bonds; and
• immediately report the product due diligence failures to the SFC.

The institution will implement enhanced complaint handling procedures to review any complaints which may be made by customers who had acquired the affected products during the relevant period.  [11 Dec 2025]

FSTB and IRD launch consultation on implementation of CARF and amendments to CRS to incorporate crypto-assets and digital financial products into framework for enhancing tax transparency and combatting cross-border tax evasion

The FSTB and the IRD have jointly published a consultation paper on proposals to implement the Crypto-Asset Reporting Framework (CARF) and amendments in relation to the Common Reporting Standard (CRS) promulgated by the OECD in Hong Kong.  Comments on the proposal are required to be submitted by 6 February 2026.

The CARF and the amended CRS now collectively represent the prevailing international standards for automatic exchange of information in tax matters (AEOI).

• CARF:  This is a new tax transparency framework which provides for the automatic exchange of tax information on transactions in crypto-assets in a standardised manner with the jurisdictions of residence of taxpayers.  Hong Kong was identified by the OECD as 'immediately relevant' to CARF given its growing crypto-asset sector, and was invited to implement CARF by 2028 at the latest.  As announced in the 2025 Policy Address, the Government will introduce legislative proposals into the LegCo in 2026, such that the reporting crypto-asset service providers can collect the information required under CARF starting from 2027 for the IRD's exchange with partner jurisdictions from 2028.
• Amendments to CRS: This covers digital financial products and provide for enhanced CRS reporting and due diligence requirements.  All jurisdictions implementing the CRS are required by OECD to adopt the amended CRS by 2030 at the latest.  The Government plans to implement the amended CRS from 2029.
• Strengthening the administrative framework for CRS: The OECD has been conducting the second round of peer review on the effectiveness of Hong Kong’s AEOI regime and implementation of the CRS since 2024.  It has raised comments on the identification of the population of reporting financial institutions and the penalty scale and enforcement mechanism.  It is crucial for Hong Kong to address the OECD’s comments.

The FSTB and the IRD will take into account the comments received in the consultation and are aiming to introduce legislative amendments into the LegCo in the first half of 2026.  [9 Dec 2025]

HKEX launches first Hong Kong equity index – HKEX Tech 100 – and enters into licensing agreement with Mainland asset management company for introduction of ETF based on HKEX Tech 100 in the Mainland

The HKEX has launched the HKEX Tech 100 Index, its first Hong Kong equity index that tracks the performance of 100 of the largest Hong Kong-listed companies across six innovative themes: (i) Artificial Intelligence, (ii) Biotech & Pharmaceutical, (iii) Electric Vehicles & Smart Driving, (iv) Information Technology, (v) Internet, and (vi) Robotics.  All constituents are eligible for Stock Connect Southbound trading, ensuring broad accessibility for global and Chinese Mainland investors.

The index incorporates a fast-entry mechanism, allowing newly-listed companies that meet specific criteria to join the index outside of the regular review cycle after they become eligible for Stock Connect Southbound trading.

The HKEX has also entered into a licensing agreement with E Fund Management Company Limited for the introduction of an exchange traded fund (ETF) based on the HKEX Tech 100 Index in the Chinese Mainland, subject to regulatory approval and the issuer’s further announcements.  [9 Dec 2025]

HKEX to enhance margin collateral arrangements at OTC Clear from 2 January 2026

The HKEX has issued a circular to announce enhancements to the margin collateral arrangements at its subsidiary, OTC Clear, with effect from 2 January 2026.  The changes align OTC Clear’s practices with those that have been implemented at the HKEX’s other equities and derivatives clearing houses since 2 October 2025 (see our previous update).

Under the new arrangements, OTC Clear will change the interest payable to, and interest charged to, clearing members in respect of any initial margin, additional margin, ad hoc intra-day variation margin or routine intra-day variation margin delivered in the form of cash and comprising the margin balance.  Participating margin and rates and FX contribution are excluded from these changes.

Interest payments (if any) will be calculated daily based on reference rates from which a handling fee will be deducted.  The initial handling fee of 0.8% per annum took effect from 2 January 2026, and will be reduced by 10 basis points per annum each year until reaching 0.5% per annum on 2 January 2029.  Further details are set out in the circular.

Amendments to the OTC Clear Clearing Procedures to reflect the new arrangements (see clean and marked-up versions) came into effect on 2 January 2026.  [8 Dec 2025]

SEHK provides further updates on Northbound Program Trading Reporting under Stock Connect

The SEHK has issued a circular to provide further updates on the implementation of Northbound Program Trading Reporting under Stock Connect.  Reference is made to its previous circulars regarding:

• the announcement on SSE and SZSE Program Trading Management Measures (Management Measures) (see our previous update);
• the publication of Northbound Program Trading Reporting Guidelines by the SSE and the SZSE (Reporting Guidelines) (see our previous update); and
• an end-to-end (E2E) test session and practice session (see circular).

Also see circular of 31 October 2025 on previous updates provided by the SEHK (see our previous update).

The present circular reminds China Connect exchange participants (CCEPs) and trade-through exchange participants (TTEPs) to comply with the relevant provisions of the Management Measures and the Guidelines, including (but not limited to) reminding their clients to comply with the Management Measures and the Guidelines (and the risk of non-compliance), reminding their clients to fulfil their Northbound Program Trading Reporting obligations prior to engaging in Northbound program trading for the first time, and entering into appropriate arrangements with their clients to set out each other's respective rights and obligations.

To facilitate market readiness, the SEHK arranged an additional optional practice session on 13 December 2025, and extended the E2E test session to 12 December 2025.  CCEPs and TTEPs who wished to participate in the practice session were requested to submit a notification form by 10 December 2025 and complete the E2E test in advance.  [5 Dec 2025]

SFC suspends responsible officer (and director and MIC) for failing to safeguard client assets

The SFC has suspended Ms Loretta Lee Si Kar, responsible officer, manager-in-charge (MIC) and director of Tung Tai Securities Company Limited (Tung Tai), for three months and two weeks.  The suspension follows the SFC’s earlier reprimand and HK$900,000 fine against Tung Tai for failures relating to unauthorised sales of client securities and transfers of client funds between September 2019 and February 2020 (see our previous update).

Ms Lee was Tung Tai’s MIC for risk management between 6 July 2017 and 12 June 2023, and has been its MIC for overall management oversight, operational control and review, key business line, compliance, and anti-money laundering and counter-terrorist financing since various dates from 6 July 2017.

Tung Tai had acted on instructions from a bogus email address and disregarded other red flags, resulting in the sale of client shares and transfer of US$3,301,740 in sales proceeds to overseas bank accounts not designated by the client.  

The SFC found that Tung Tai failed to ensure that client assets were adequately safeguarded and establish effective internal control procedures to protect client assets from theft, fraud and other acts of misappropriation.  The SFC considers that these failures were attributable to Ms Lee’s neglect of her duties as a member of the senior management of Tung Tai.  [3 Dec 2025]

HKEX reminds participants to review system settings and note reporting requirements in relation to PTRM system in derivatives market

The HKEX has issued a circular reminding participants in the derivatives market to regularly review their Pre-Trade Risk Management (PTRM) system settings.  Among others:

• The risk limit settings must be a reasonable reflection of the risk inherent in the trading activity of the pre-trade limit group(s), taking into account current market conditions. 
• New participants are requested to make an appointment with the HKEX for their first-time risk limit settings within 6 months of commissioning.
• PTRM authorised persons should be familiar with the operation of the PTRM system.  Any changes to PTRM authorised persons must be reported to the HKEX immediately. 
• Participants are required to report to the HKATS Hotline immediately after the execution of the following emergency buttons – Stop, Mass Order Cancellation, and Kill Switch.

The circular also outlines the access rights of different categories of PTRM authorised persons, distinguishing between Risk Limit Managers (with full access rights for risk limit modifications and emergency buttons) and Trading Units (with partial access rights for emergency buttons).  [1 Dec 2025]

HKEX issues reminder to participants regarding order volume and price deviation settings on HKATS

The HKEX has issued a circular to remind exchange participants of the following in relation to order volume and price deviation settings on the Hong Kong Automated Trading System (HKATS). 

• Exchange participants should review and determine the maximum allowable volume parameters and order price deviation with 'Restriction' as the action type according to their own trading patterns, practice and risk management requirements.  The parameter settings are to be set at HKATS user and HKATS Online.
• All HKATS users should be familiar with the order volume and price deviation settings on HKATS Online.
• Exchange participants using OMnet Application Programming Interface are requested to review and determine similar price and quantity limits in their systems to minimise error trades resulting from orders entered erroneously.
• Exchange participants who changed their parameters were required to notify their respective exchange by email by 31 December 2025.
• Detailed procedures on parameter settings on HKATS Online are set out in Section 7.5 of the HKATS User’s Guide.

The above is an additional control measure to prevent error trades and does not replace any of the existing internal controls or preventative arrangements of exchange participants.  [1 Dec 2025]

MAS responds to suggestion to raise the limit for the SSB programme

The MAS has published its response to a suggestion to raise to the individual limit of $200,000 for the Singapore Savings Bond (SSB) programme. The SSB programme was launched in 2015 to offer individuals a simple, safe and long-term product to encourage individuals to invest for the long-term.

MAS stated that the individual limit and allocation method ensure that more individuals have access to SSBs and that they will continue to monitor and assess periodically if the $200,000 limit remains appropriate. Currently, the vast majority of SSB investors hold significantly less than $200,000 worth of SSBs, with the median holdings amount being around $30,000. [18 Dec 2025]

MAS consults on updates to the guidelines on liquidity risk management practices for fund management companies

MAS has published a consultation on proposed updates to the guidelines on liquidity risk management for fund management companies. The proposed updates seek to provide greater clarity about MAS' expectations.

Responses are requested by 28 February 2026. [17 Dec 2025]

MAS: Thematic review of firms' recruitment and onboarding training of representatives

The MAS has published its thematic review of financial institutions' recruitment and onboarding training of representatives. The information paper sets out MAS’ supervisory expectations, good practices observed and highlights the following areas which require work: onboarding of representatives; monitoring of representatives with adverse information; onboarding training; and hiring of assistants by representatives and outsourced activities. [4 Dec 2025]

MAS: Keynote address at FIA Asia Derivatives Conference

MAS has published the speech of its Assistant Managing Director (Capital Markets), Mr Lim Tuang Lee, at the Futures Industry Association (FIA) Asia Derivatives Conference.

The director first set the backdrop on recent trends and developments before sharing MAS' strategic priorities for the capital markets, with a special focus on technology.

He explained that MAS' contribution to the capital markets ecosystem is around facilitating innovation, sharpening its supervisory capabilities, and engaging with ecosystem stakeholders to inform how it proceeds.  [3 Dec 2025]

ACSR sets out approach for non-compliance to sustainability reporting requirements

The ACSR, chaired by the SCM, has announced its approach to addressing non-compliance with regulatory sustainability reporting requirements developed in alignment with the National Sustainability Reporting Framework (NSRF). Accordingly, the SCM, Bank Negara Malaysia (BNM) and other relevant authorities will focus on a phased and practical approach in reviewing disclosures.  [8 Dec 2025]

BNM issues policy document on broader application Ta'awun in Takaful

The BNM has issued a policy document on broader application of Ta'awun in Takaful.

The policy document took effect on 28 November 2025. [28 Nov 2025]

SEBI: Certification requirement for compliance officers of managers of AIFs

SEBI has issued a circular to alternative investment funds (AIFs) on certification requirement for compliance officers of managers of AIFs. SEBI specified that the compliance officer of manager of an AIF shall obtain certification from the National Institute of Securities Market by passing the Series-III-C: Securities Intermediaries Compliance (Fund) Certification Examination. SEBI also specified that managers of AIFs shall ensure that, with effect from 1 January 2027, only those persons who have obtained the aforesaid certification shall be appointed as or shall continue to act as compliance officer of managers of AIFs.

The circular shall come into force with immediate effect. [30 Dec 2025]

IFSCA: Internet banking services to clients of IBUs – Review

The IFSCA has issued a circular referencing its April 2024 circular titled 'Internet banking services to clients of IBUs'. The IFSCA confirms that it has decided to lay down specific compliance requirements with respect to the various types of internet banking services mentioned in the April 2024 circular. Specifically, these are: information service; interactive information exchange service; and transactional service.

An IBU that does not offer liability products to its customers will be exempt from implementing the requirements mandated in the circular with respect to interactive information exchange service and transactional service.

An IBU commencing operations after the date of issue of this circular shall not offer liability products to its customers without complying with this circular.

An IBU that commenced operations prior to the date of this circular shall comply with the requirements of the circular by 30 June 2026 or cease onboarding new customers for liability products from 1 July 2026.

IBUs shall obtain and record explicit consent from their customers for registering or deregistering (in case of existing customers) for internet banking services. [29 Dec 2025]

SEBI: Review of simplification of procedure and standardization of formations of documents for issuance of duplicate certificates

SEBI has issued a circular confirming that it has been decided to increase the threshold for simplified documentation from the current Rs. Five Lakhs to Rs. Ten Lakhs. To simplify the documentation, it has been decided to:

• prescribe a standardised Affidavit-cum-Indemnity bond;
• rationalise the documentation for securities having value of more than Rs. Ten Lakhs; and
• do away with notarisation of the Affidavit-cum-Indemnity bond for cases involving securities with value up to Rs. Ten Thousand.

The provisions of this circular shall come into force with immediate effect. [24 Dec 2025]

SEBI: Mandating periodic disclosure requirements – SDIs

SEBI has published a circular: Manding periodic disclosure requirements – Securitised debt instruments (SDIs). The SDI Regulations mandates a special purpose distinct entity and the trustee to furnish information to the Board on a half yearly basis, in the manner as may be specified by Board.

It has been decided that the trustee of special purpose distinct entity shall submit the disclosures on a half yearly basis to the Board and on the stock exchange where the SDIs are listed, within 30 days from the end of March or September.

The provisions of this circular shall be effective from 31 March 2026. [16 Dec 2025]

RBI: Revised directions on maintenance of cash credit, current and overdraft accounts

The RBI has issued a set of amendment directions that revise existing rules regarding the opening and management of cash credit, current, and overdraft accounts by banks.  [11 Dec 2025]

RBI: Master direction on rupee interest rate derivatives

The RBI has published a master direction that updates the regulatory framework for rupee interest rate derivatives (IRD) in line with developments in the IRD market and with a view to support the risk management needs of the broader financial system. It also aims at fostering greater transparency in the rupee IRD market.  [8 Dec 2025]

SEBI consults on revised master circular for foreign portfolio investors

SEBI has published a consultation on a revised master circular for foreign portfolio investors (FPIs), designated depository participants and eligible foreign investors. The updated version incorporates circulars pertaining to FPIs issued since May 2024, streamlines the language and removes duplications and transitory provisions. Feedback was requested by 26 December 2025.  [5 Dec 2025]

SEBI consults on review of existing position limits for trading members in equity derivatives segment

SEBI has released a consultation paper on the review of existing position limits for trading members in the equity derivatives segment. The aim of the exercise is:

• to align the metric of position limit for trading members to that specified for the clients (i.e. futures equivalent (FutEq) or delta);
• to augment such limit with an absolute limit keeping in mind the open interest level in different indices;
• to enable trading members to compute their own FutEq positions intraday so that during market hours they can take suitable action if their utilization approaches or crosses trading member level proposed limits.

Feedback was requested by 26 December 2025. [4 Dec 2025]

RBI issues consolidated Master Directions

The RBI has announced the issuance of 244 Master Directions consolidating the instructions currently administered by the Department of Regulation on an 'as-is' basis, and a list of 9445 circulars that are being repealed or withdrawn as a consequence of the new issues. These Master Directions will serve as the sole library of regulations administered by the Department of Regulation. [1 Dec 2025]

SECP issues new sustainability reporting guidelines in line with global practices

The SECP has issued an MC adopting the Philippine Financial Reporting Standards (PFRS) on sustainability disclosures. The circular shall take effect fifteen days after publication in two newspapers of general circulation.

The MC adopts PFRS S1 on the General Requirements for Disclosure of Sustainability-related Financial Information and PFRS S2 on Climate-related Disclosures.

Both PFRS are aligned with the International Financial Reporting Standards issued by the International Sustainability Standards Board.

PFRS S1 and PFRS S2 will be implemented in a tiered approach, beginning in fiscal year 2026. [29 Dec 2025]

SECP: Revised rules for beneficial ownership declaration

The SECP has issued a MC which sets out the Beneficial Ownership (BO) Disclosure Rules of 2026 and consolidates existing SECP regulations governing the submission of BO information. This revised regulatory framework aims at improving the accuracy and timeliness of corporate BO disclosures, in support of ongoing efforts to prevent the misuse of corporate entities for illicit activities.

Among other matters, the rules provide:

• verification mechanisms to validate BO information and address discrepancies;
• controlled access by authorized parties, subject to applicable laws and safeguards; and
• a 20% reporting threshold, in accordance with rules issued by the Anti-Money Laundering (AML) Council.

The circular took effect on 1 January 2026. [23 Dec 2025]

BSP cites commitment to capital market development, cross-border payments in ASEAN+3 forum

The BSP underscored its commitment to advance capital market development and cross-border payments during the 4^th ASEAN+3 Economic and Financial Stability Forum in Hong Kong.  BSP Deputy Governor Zeno Ronald R. Abenoja, in a panel discussion during the event, remarked: 'The BSP is working to deepen the money market and introduce more market-oriented operations.'

He said the aim is to enhance liquidity to improve monetary policy transmission and strengthen the Philippines’ integration into regional and global financial markets. He added that these are also steps to safeguard the financial system amid global uncertainties and accelerating digital transformation. On cross-border payments, the Deputy Governor emphasized the potential of tokenization, particularly for digital retail payments and remittances. By leveraging stablecoin technology, transactions can become faster, cheaper, and more accessible.  [17 Dec 2025]

SECP seeks views on guidance for regulated entities on establishing and maintaining a cyber resilience framework

The SECP has published a notice requesting responses on the proposed draft memorandum circular on guidance for regulated entities on establishing and maintaining a cyber resilience framework.

Responses are requested by 16 January 2026. [17 Dec 2025]

BSP and SEC partner to protect retirement savings

The BSP and the SECP have signed a memorandum of agreement (MoA) on data sharing as well as access to, and use of, information from the Personal Equity and Retirement Account System (PERASys). Under the MoA, the BSP and SEC will collaborate to ensure the secure sharing and responsible use of data concerning PERA contributors, aiming to better serve Filipinos investing for their retirement.  [8 Dec 2025]

SBV: Ensuring safe and smooth payment activities during 2026 Lunar New Year

SBV has issued a document requesting SBV entities, the credit institutions, the foreign bank branches, and payment intermediary service providers to synchronously implement measures to ensure safe and smooth payment activities in response to increased demand during the 2025 year-end settlement period and the 2026 Lunar New Year (Tet).

FSC amends the Principles to facilitate Taiwan’s financial industry in recruiting asset management professionals

The FSC has amended the 'Required Qualifications for Foreign Specialist Professionals with Specific Financial Expertise' and Principles for Recognition of Qualifications'.

FSC has revised the Principles to expressly include asset management (including multi-family offices) in the list of key industries. The change is intended to help the domestic finance industry recruit foreign specialist professionals in the field of asset management. [29 Dec 2025]

FSC announces 2026 examination focuses

The FSC has announced its key examination focuses for 2026; a total of 113 examination focuses have been designated. These have been formulated with reference to broader economic and geopolitical developments, public concerns, the FSC’s supervisory priorities, regulatory measures announced in 2025, and key observations requiring improvement from on-site examinations. For 2026, four major topics have been selected as areas of special attention: fraud prevention; anti-money laundering; financial consumer protection; and cyber resilience. [18 Dec 2025]