How the HKMA’s consumer-protection guidance on generative AI shapes AI use by authorised institutions in Hong Kong — binding within the HKMA regime.

dgm is an independent osFoundry integration partner — not affiliated with osFoundry’s maker (OS LLC), and dgm has no completed client integrations yet.

If you are a Hong Kong bank or authorised institution using generative AI, the HKMA’s guidance is binding within its regime. Here is what it expects.

What the HKMA has issued

The HKMA issued consumer-protection principles for Big Data Analytics and AI in 2019, and on 19 August 2024 issued consumer-protection guidance specifically for generative AI in customer-facing applications. The 2019 four principles — governance and accountability, fairness, transparency and disclosure, and data privacy and protection — are extended to generative AI, with added attention to hallucination risk and explainability.

What it expects

Authorised institutions should apply governance across the AI lifecycle (data preparation, fine-tuning, output evaluation, monitoring), especially for customer-facing uses. The HKMA also issued guidance in September 2024 on using AI to monitor suspicious activities, and launched the GenA.I. Sandbox (expanded to Sandbox++ in March 2026) for supervised experimentation.

How to comply

Treat AI as a governed system: document the model, validate it, keep humans accountable, and protect customer data under the PDPO. osFoundry’s managed cloud pins data to the US, EU or Japan — it does not currently offer a Hong Kong managed region (its nearest managed region is Japan). To keep data in Hong Kong, the honest path is self-hosting osFoundry (BYO Cloud) inside a Hong Kong cloud region such as AWS Asia Pacific (Hong Kong) ap-east-1, Microsoft Azure East Asia (Hong Kong SAR) or Google Cloud asia-east2 (Hong Kong), or running models locally on-device.

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.