Hong Kong's Legislative Council has passed the Inland Revenue (Amendment) (Automatic Exchange of Information) Bill 2026 on 17 June 2026, strengthening the AEOI administrative framework with new requirements effective 1 January 2027, including mandatory financial institution registration, enhanced due diligence, and increased penalties.
Hong Kong’s government welcomed the passage of the Inland Revenue (Amendment) (Automatic Exchange of Information) Bill 2026 by the Legislative Council on 17 June 2026, to enhance the administrative framework for the automatic exchange of information in tax matters (AEOI) in Hong Kong.
This follows Hong Kong’s Legislative Council announcing on 15 June 2026 that it will meet on 17 June 2026 at the LegCo Complex, where it will resume the Second Reading debate on the Inland Revenue (Amendment) (Automatic Exchange of Information) Bill 2026.
Since 2018, Hong Kong has been conducting automatic exchange of financial account information in relation to tax matters with partner tax jurisdictions on an annual basis, in accordance with the Common Reporting Standard developed by the Organisation for Economic Co-operation and Development (OECD) and on the premise of data confidentiality and security.
This enables the relevant tax authorities to conduct assessments on their tax residents for detecting and combatting cross-border tax evasion.
In light of the comments made by the OECD after conducting the peer review on Hong Kong’s implementation of the AEOI regime earlier, the Government agrees that there is a need to enhance the relevant administrative framework.
Starting from 1 January 2027, new requirements will be implemented, including requiring reporting financial institutions to register with the Inland Revenue Department (IRD) for strengthening identification, enhancing the requirements on financial institutions for keeping due diligence records, and raising the penalties to increase deterrence.
The Secretary for Financial Services and the Treasury, Christopher Hui, said, “Hong Kong has all along been supporting international efforts in enhancing tax transparency and combatting cross-border tax evasion. As an international financial centre, Hong Kong has an obligation to enhance the AEOI administrative framework to address the OECD’s views. This will also help Hong Kong maintain a favourable rating in the peer review and boost the confidence of other tax jurisdictions in Hong Kong’s tax system. This will be conducive to Hong Kong’s expansion of the Comprehensive Avoidance of Double Taxation Agreement network, which will provide Hong Kong businesses with greater tax certainty and avoidance of double taxation when expanding their businesses overseas.”
To assist the industry in adapting to the new requirements and enhance tax certainty, the IRD will issue relevant guidance and maintain communication with the industry to provide technical support and answer enquiries.
