On 27 Nov 2025, the HKMA published the updated CA-D-1 Guideline, clarifying exemption criteria for the Banking (Disclosure) Rules, reinforcing five core disclosure principles, mandating web-based disclosure with specific archive requirements, and detailing consolidation bases and materiality assessments for banks. The guidance supersedes the previous V.4 version dated 01.01.25.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Exemption Framework Clarifications
On 27 Nov 2025, the HKMA updated its CA-D-1 Guideline to clarify exemption criteria under the Banking (Disclosure) Rules (BDR), specifying that the 'de minimis' exemption (sections 3(7), (8), (9)) requires the Monetary Authority's written approval based on sustained business operations below specified thresholds, not temporary asset reductions. The guidance further details that exemptions for banks not yet commenced (section 3(14A)) must include business commencement timelines, with withdrawal of exemption required upon business commencement.
Core Disclosure Principles
The revised guideline reinforces five mandatory disclosure principles: (1) clarity for stakeholders; (2) comprehensiveness covering significant risks; (3) meaningfulness to users; (4) consistency over time; and (5) cross-bank comparability. These principles govern all disclosures under the BDR, with Als required to justify exclusions of immaterial information through narrative commentary.
Digital Disclosure Requirements
The guidance mandates web-based disclosure as the primary medium, requiring Als to maintain an archive of all disclosures from 30 June 2013 (for HK-incorporated banks) or 31 December 2014 (for liquidity disclosures). Als must publish disclosures on their website or approved holding company site, with a direct link prominently displayed, and submit copies to HKMA via email within three working days of publication.
Consolidation and Materiality Guidance
The guideline clarifies consolidation bases for disclosures: Als must generally use regulatory consolidation (except for specific sections), with capital disclosures aligning to Return on Capital Adequacy Ratio submissions. Materiality assessments must incorporate HKFRS concepts (HKAS 1, HKAS 8, and HKFRS Practice Statement 2), requiring Als to justify exclusions of immaterial data through narrative explanations.
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