Submissions and Reports

The Chamber welcomes the Consultation Paper's objectives of broadening the pool of companies eligible for listing in Hong Kong while maintaining strong investor protection and market confidence. The Chamber considers that the proposed measures, taken together, could further reinforce Hong Kong’s position as a leading international financial centre.

From an implementation perspective, we also highlight the importance of enhancing efficiency and clarity in the listing process without compromising regulatory standards. Our suggestions cover, amongst others, the potential benefits of facilitating threshold relaxations for overseas issuers and introducing closely supervised grace periods for minor, non‑material compliance matters, to improve market accessibility while safeguarding regulatory integrity.

The Chamber welcomes the Government’s proposals to enhance IP tax deductions - including allowing deductions for acquisitions of IP from associated companies and recognizing upfront lump sum licence fees as deductible expenses - to keep Hong Kong on par with, and preferably more favourable, than that of other competing regional IP trading centres, in particular Singapore, so as to reinforce the city’s positioning as a regional IP trading hub.

We also recommend that any safeguards against abuse of the proposed expanded tax exemptions should be necessary, proportionate and not unduly burdensome, in order to maintain Hong Kong’s attractiveness to IP owners and investors. In addition, alignment with overseas benchmarks on valuation thresholds and practical treatment of IP portfolios would help balance tax integrity with commercial reality.

The Chamber supports the Government’s proposed extension of the Virtual Asset (VA) regulatory regime to VA advisory and VA management services, which is a positive and timely development for accelerating Hong Kong’s development as a global digital asset hub. A more comprehensive framework can provide regulatory clarity for market participants while reinforcing the city's attractiveness as leading financial and innovation centre, consistent with the principle of “same activity, same risks, same regulation.”

As the regulatory regime evolves, the Chamber encourages an approach that remains responsive to market innovations, including developments such as Real-World Asset Tokenization. Additional guidance on the application of marketing related prohibitions - particularly in relation to online and cross border activities – is also recommended in supporting industry compliance. Taken together, a flexible, robust and balanced regulatory structure will be conducive to safeguarding investor interests and the continued growth of Hong Kong’s virtual asset ecosystem.

The Chamber broadly supports the proposed enhancements to the HKMA’s Prototype of the Hong Kong Taxonomy for Sustainable Finance (Phase 2A), whilst putting forward other suggestions on its practical implementation, to achieve the objectives of enhancing Hong Kong’s position as a leading green finance hub and meeting carbon neutrality goals.

We commend the Taxonomy’s alignment with international frameworks — such as those adopted in the EU — in establishing a common language for identifying environmentally sustainable activities. At the same time, we recommend that continued attention is given to Hong Kong’s specific circumstances, particularly in relation to its energy landscape, infrastructure, and market developments. This would help maintain the Taxonomy's relevance and adaptability in the face of evolving market dynamics.

To maximise the Taxonomy’s effectiveness, we also advocate for a practical and proportionate approach to implementation, especially in sectors where decarbonisation pathways are still evolving.

The Chamber recognizes the efforts of the Government to continue to enhance Hong Kong’s regulatory frameworks for virtual asset (VA) dealing and custodian services, which are pivotal to fostering sustainable industry growth and reinforcing the city’s status as a leading global financial hub. We call for a pragmatic approach for shaping a regulatory environment that is both agile and internally competitive – one that balances strong investor protection with the need to foster innovation. Our recommendations are centered on proposals relating to the scope of permissible services under the VA regime and regulatory oversight, as well as transitional arrangements, amongst others.

The Chamber expresses broad support for the Government’s overarching vision for the development of the areas surrounding Hung Hom Station and its adjacent waterfront (“the Zone”), with particular emphasis on improving connectivity and commuting, and transforming the Hung Hom and Victoria Harbour area into a prominent harbourfront landmark; thereby reinforcing Hong Kong’s position as a world-class international city. We also offer specific comments on land use planning and design strategies to further enhance the Zone’s development. These include the adoption of a holistic and integrated development approach, a review of the residential-to-commercial ratio, and recommendations to further strengthen connectivity, branding, as well as the overall visibility and sustainability of the Zone.

The Chamber welcomes the SFC's proposed amendments to the Securities and Futures (Stock Market Listing) Rules and their objectives of enhancing market efficiency, transparency, investor protection, and accountability. We agree in general with the proposals, viewing them as in line with international regulatory developments, whilst also offering suggestions to enhance their effectiveness. Recommendation is also given to the measured usage of SFC’s post-listing powers, which should be reserved for situations where there is clear risk of harm to the investing public, to preserve Hong Kong’s attractiveness for quality listings.

The Chamber commends the Government's ongoing efforts to advance the Northern Metropolis (NM) mega-project and have submitted our latest general recommendations to support its comprehensive development in the short and medium term. Specifically, we have conveyed our members' perspectives on the design and execution of the Pilot Large-Scale Land Disposal Scheme, emphasizing key considerations such as financial and investment aspects, as well as land supply and management challenges. These insights aim to encourage industry participation and foster effective collaboration with the Government in building this new metropolis.

The Chamber expresses in principle support to the HKEX’s proposals to enhance its IPO Price Discovery and Open Market Requirements framework, recognizing that this approach aligns with internationally recognized best practices for regulation, focusing solely on instances where a clear and demonstrable need for regulation is necessary. As part of our recommendations, we advocate that the requirement of enhanced disclosure in the IPO listing prospectus of a possible downward adjustment of up to 10 per cent below the indicative offer price be removed, as investors’ interests are sufficiently protected by present rules.

The Chamber expresses general support for the HKEX’s proposals to expand its paperless listing regime, thereby elevating Hong Kong’s regulatory framework for listed companies to align with global sustainability objectives. Taking note of the current market landscape, we nevertheless advocate for the incorporation of a degree of flexibility into the regime, with consideration of the practicability of some of the digitalisation proposals, such as that related to corporate communications, payments and web accessibility. Such an approach would facilitate a balanced addressing of the needs of listed issuers, securities holders and investors.