Hong Kong has no standalone binding AI Act in 2026 — here is what actually governs business AI use: the PDPO, the PCPD and DPO advisory frameworks, and HKMA and SFC sector circulars.

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

Is AI regulated in Hong Kong? The honest 2026 answer is: there is no standalone binding AI Act, but several existing laws and sector circulars apply. Here is the real picture.

No standalone AI Act

As of 2026 Hong Kong has no standalone, binding AI Act. Its horizontal AI-governance instruments are advisory: the Digital Policy Office’s Generative AI Technical and Application Guideline (15 April 2025), the PCPD’s Artificial Intelligence: Model Personal Data Protection Framework (11 June 2024), and the government’s Ethical AI Framework. The binding constraints on business AI are existing law — chiefly the Personal Data (Privacy) Ordinance — plus sector-regulator circulars that bind only the firms they cover (the HKMA’s GenAI consumer-protection guidance for banks, and the SFC’s November 2024 circular for licensed corporations). The government convened a committee in March 2026 to review whether legislation is needed.

What actually governs AI

Three layers: existing technology-neutral law (chiefly the PDPO for personal data); advisory government frameworks (the PCPD’s AI Model Framework, the Digital Policy Office’s April 2025 generative-AI guideline, the Ethical AI Framework); and binding-within-their-regime sector circulars (the HKMA’s GenAI consumer-protection guidance for banks, the SFC’s November 2024 circular for licensed corporations).

What it means for your business

A general Hong Kong business is not subject to an AI Act, but must still follow the PDPO and should adopt the advisory frameworks, which increasingly shape procurement and customer expectations. Regulated firms must meet their sector circular. The government convened a committee in March 2026 to review whether legislation is needed, so expect movement.

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.