Hong Kong Tax News Flash
March 2026, Issue 3
Bill to strengthen Hong Kong’s CRS administrative framework introduced
Following the consultation conducted from December 2025 to early February 2026 on the implementation of the Crypto-Asset Reporting Framework (CARF) and the amended Common Reporting Standard (CRS) in Hong Kong, the legislative bill proposing changes to the CRS regime (Bill) was gazetted on 27 March 2026. The Bill seeks to strengthen the administrative framework for the automatic exchange of tax information (AEOI) under the CRS, in response to the latest OECD peer review comments.
The proposed amendments focus on three areas: mandatory registration for reporting financial institutions (RFIs), updated record-keeping obligations and strengthened sanctions for non-compliance. The Government aims to secure passage of the Bill by the end of June 2026 to meet the deadline set by the OECD. The relevant amendments will take effect on 1 January 2027. While the Bill’s current scope is limited to the implementation of these administrative measures in relation to CRS, these provisions are expected to establish the precedent for the future rollout of CARF.
It should be noted that the amendments proposed under the Bill relate solely to the strengthening of the administrative framework for CRS. Separately, enhanced requirements on due diligence and reporting under the amended CRS (commonly referred to as ‘CRS 2.0’) are expected to take effect from 1 January 2028. RFIs should therefore be mindful that the current Bill represents only the first phase of a broader set of changes to Hong Kong’s AEOI regime, and should begin planning ahead for the more substantive operational changes that CRS 2.0 will introduce.
This news flash outlines the changes proposed under the Bill and sets out our observations.
Contact us
South China and Hong Kong Tax Leader, China M&A Tax Leader, PwC Hong Kong
Tel: +[852] 2289 5616
South Private Clients and Family Office Tax Leader, PwC Hong Kong
Tel: +[852] 2289 3816
