Hong Kong governs AI through advisory frameworks and sector circulars rather than a binding AI Act like the EU — what that difference means for a Hong Kong business operating across both.
dgm is an independent osFoundry integration partner — not affiliated with osFoundry’s maker (OS LLC), and dgm has no completed client integrations yet.
Hong Kong and the European Union have taken opposite approaches to AI rules. If you operate in or sell into both, the difference is worth understanding precisely.
Hong Kong’s approach: advisory plus sectoral
As of 2026 Hong Kong has no standalone binding AI Act. Its AI-specific instruments are advisory (the PCPD’s Model Framework, the Digital Policy Office’s generative-AI guideline), and the binding constraints are existing law (the PDPO) plus sector circulars (HKMA, SFC) that bind only the firms they cover.
The EU’s approach: binding and risk-tiered
The EU AI Act is a binding regulation that classifies AI systems by risk and imposes obligations accordingly, with significant penalties. It can apply extraterritorially, so a Hong Kong business serving EU users may fall within scope.
What it means for you
A Hong Kong-only business is not subject to an AI Act but should follow the PDPO and the advisory frameworks. A Hong Kong business serving EU customers may need to meet EU AI Act obligations on top. Building governance around testing, documentation and accountability positions you for both.
Where dgm fits
dgm is an independent integration partner that helps Hong Kong businesses adopt osFoundry — scoping a first use case, handling the build, and connecting AI to the systems you already run. dgm is independent of osFoundry’s maker (OS LLC) and has no completed client integrations yet, so everything described here is a service offered, not a past result. If you want to scope a practical first project, dgm can help you map it out.