Hong Kong SAR's AI agenda: key takeaways from the 2026 Policy Address and first Five-Year Plan

On 16 September 2026, the Hong Kong Government released its first Five-Year Plan (2026-2030), aligned with the Chinese Mainland's 15th Five-Year Plan, alongside the Chief Executive's 2026 Policy Address. One of the central themes touched upon was artificial intelligence (AI), where the Government outlined a range of sector-specific AI initiatives and the city’s AI risk-governance strategy.

AI as a core industry

The Five-Year Plan positions AI as a core industry for Hong Kong's future development, aiming to empower different sectors of the economy through AI. To that end, the Government will continue to advance its “AI+” Initiative on all fronts, with a dual focus on developing an AI industry in Hong Kong and driving the adoption of AI across the wider economy.

On the infrastructure and regulatory fronts, the Sandy Ridge Data Facility Cluster in the Northern Metropolis is expected to come into operation by 2029 to provide the computing power needed for Hong Kong's AI industry, and the Government will review existing legislation with a view to putting in place a regulatory framework for AI development and a robust AI and data governance system aligned with national and international standards.

Application and risk management of AI

Building on strategies pursued over the past few years, a new position of Commissioner for AI is to be created within the Digital Policy Office (DPO) to support the various bureaux on AI-related work, with overall co-ordination provided by the Chief Secretary for Administration. In parallel, a Task Force on the “AI City Brain” System, led by the Chief Secretary for Administration, will develop an integrated city management system linking up departmental data on works, environment, transport and emergency response.

Sector-specific initiatives will also be rolled out across areas including finance (where the Hong Kong Monetary Authority's (HKMA) Generative AI Sandbox has been upgraded to a cross-sector “GenA.I. Sandbox++” extending beyond banking to securities, wealth management, insurance and the Mandatory Provident Fund), construction, the legal sector, transport, social welfare, tourism, broadcasting and government and public services. The Government will also launch an AI upskilling campaign and expand training and inclusion programmes to support the wider adoption of AI across the economy.

AI Risk Governance

The Policy Address identifies a range of AI-related risks, including the misuse of AI to commit crime, user responsibility, the protection of minors, the control of AI Agents and the impact of AI on employment. In response, the Government's AI risk-governance strategy focuses on seven aspects, several of which involve reviewing existing laws, consulting on new legislation or expanding regulatory frameworks, alongside sectoral guidelines and other soft-law instruments:

1. Combating the use of AI in criminal activities. The Law Reform Commission's Cybercrime Sub-committee is reviewing existing laws and will consult publicly on measures to tackle deepfake pornography, online scams and fraud using deepfake technology, with legislation to be considered on the basis of its recommendations. The Financial Services and the Treasury Bureau will separately consult later in 2026 on expanding the legal framework to require sectors such as technology and telecommunications to detect and remove fraudulent content, including AI-generated fraud.

2. Enhancing protection of minors. Under the Values Education Curriculum Framework (2026), the Education Bureau will support schools in guiding students on the prudent use of AI tools. A dedicated task force under a working group led by the Department of Justice will review the risks associated with minors' use of social media, including interaction with AI, and assess the need for further legislative or administrative measures.

3. Promoting market assessment of AI ethical risks. The Innovation, Technology and Industry Bureau will select pilot departments to require bidders on public-facing AI service projects to comply with AI guidelines issued by the DPO and submit safety and ethics compliance declarations, with the requirement to be extended progressively across the Government.

4. Safe and orderly AI adoption. The DPO will work with industry bodies to develop sector-specific AI application guidelines, accreditation and governance frameworks. The HKMA and the Insurance Authority have prepared action plans to foster responsible AI adoption, and the Securities and Futures Commission (SFC) will supervise the establishment of governance frameworks and industry risk-management and internal-control measures.

5. Legal liability for accidents caused by AI products. A working group led by the Department of Justice will consider whether existing law adequately addresses liability arising from accidents or damage caused by AI products, and will study ways to address these issues through legislation or soft-law instruments such as codes of practice, codes of conduct and guidelines.

6. Management of AI agents. The DPO is piloting the use of AI agents in the Government and has incorporated provisions into an AI adoption guide for departments. Based on that experience, the DPO, together with the Hong Kong Artificial Intelligence Research and Development Institute (AIRDI), will promulgate AI agent safety-management guidelines applicable to society at large in 2027.

7. Impact on employment. The Labour and Welfare Bureau will publish a mid-term update to its Manpower Projection analysing the impact of AI adoption on Hong Kong's labour market, and will develop upskilling and reskilling measures accordingly.

Looking ahead

Read together, the Five-Year Plan and Policy Address signal that Hong Kong is treating AI as an increasingly strategic initiative to be applied across the economy, while developing a governance framework that combines targeted legislation with sectoral guidelines, codes of practice and other soft-law instruments. Businesses operating in Hong Kong will want to keep a close eye on developments (including any public consultations, sector guidelines and, in some areas, legislative proposals) expected to follow.

Please get in touch with the Linklaters Asia TMT/IP team if you would like to discuss any aspects of the above.