Submissions and Reports

The Chamber has called on the Chief Executive to assist businesses, especially small and medium enterprises, in navigating the challenging environment. Additionally, on behalf of members, the Chamber has put forward recommendations to raise Hong Kong’s competitiveness in key industries and accelerate the transformation into a sustainable city.

The Chamber acknowledges the HKEX’s efforts to enhance the corporate governance of listed issuers to strengthen Hong Kong’s competitiveness as a leading financial hub, as well as align to with international practices. Notwithstanding the forgoing, we put forward the recommendation that many of the proposed new rules – including that related to board governance effectiveness and independence - would merit further assessment on their necessity, as well as potential benefits and drawbacks of implementing them in the local context, in light of their potential impact on the general business community. In making such a suggestion, the Chamber draws from the principles of the globally recognized regulatory impact analysis approach, which considers the need for the identification of concrete issues that require tackling when implementing new regulatory initiatives.

The Chamber largely agrees with the Security Bureau’s proposed introduction of a new legislation to enhance the protection of the critical computer systems of critical infrastructure, acknowledging the significance of safeguarding the cybersecurity of the city’s essential services in upholding Hong Kong's stability and status as a global financial centre. At the same time, the Chamber recommends that consideration be given to putting in place a new regulatory regime that is proportional and balanced, principle and risk-based based, and aligned with international-standards - to facilitate business compliance and stakeholder trust - and which keeps pace with advancements in innovation and technology. We also seek further clarity on the regulatory scope and targets which would help provide certainty to local and international market participants.

The Chamber recognizes the objectives of present industry-led efforts to develop a Voluntary Code of Conduct for ESG ratings and data products providers (the Code), and regards this form of regulatory intervention as a proportionate measure, to foster the growth of a transparent and trusted market for the sector, and to facilitate companies due diligence in light of increasing sustainable investment awareness.
In relation to the design and implementation of the proposed Code, we suggest amongst others, that consideration be given to incorporating suitable flexibility and interoperability to facilitate voluntary adoption by the wider business community, in the light of potential resource and real data provision challenges.

The Chamber generally supports the Government’s proposals to transform Lau Fau Shan into a tech hub and eco-tourism hotspot, in line with its blueprint for the development of the Northern Metropolis. We recognize that such efforts would benefit businesses, particularly the tech sector, through creating opportunities for cross-border corporate synergies and development alongside Qianhai and Nanshan in Shenzhen.
At the same time, we highlight several conceptual and practical issues relating to these proposals, which we suggest that the Government take into consideration when taking forward the megaproject.

The Chambers continues to express support for the Government’s efforts in developing a robust market for VA development in Hong Kong, thereby recommending that the development of the proposed licensing regime for over-the-counter VA trading services strikes a balance between facilitating the continued demand for VA trading opportunities amidst the rapidly evolving digital landscape, against the need to safeguard investor interests and preserve market integrity.
In its response, the Chamber also puts forward suggestions on the execution of the legislative proposals, in such aspects as the scope of services which would be permitted under the new licensing regime as well as the proposed supervisory scope.

The Chamber strongly advocates for greater collaboration with the international community in enhancing tax transparency and combating tax evasion amid the growing digitalisation of the economy. With the imminent implementation of the GloBE rules and the complexity they entail, we urge the Government to provide comprehensive guidance on all facets of the new rules to assist businesses in their compliance efforts.

The Chamber firmly believes in the critical importance of expanding Hong Kong’s tax treaty network and has put forward a number of suggested jurisdictions in response to an invitation from the Financial Services and the Treasury Bureau. We hold high hopes that substantive progress can be achieved in the near term by actively engaging the jurisdictions. Additionally, we highly recommend that the Government allocate additional resources to expedite the process.

The Chamber fully supports the Government’s proposed implementation of the Basic Law Article 23 Legislation, which is a welcomed step in the right direction for Hong Kong as it seeks to fulfill its constitutional duty and safeguard national security under the principle of “one country, two systems”. Whilst Hong Kong’s economic and social prosperity, as well as competitiveness as an international business hub rests upon such developments, sufficient clarity on the legal provisions and solid education and support from the Government for businesses and the public should also be considered to facilitate awareness and consensus building for the new legislation.