On 10 Oct 2025, the HKMA regularised the Cross-boundary Credit Referencing (CBCR) initiative following successful pilot outcomes, providing guiding principles for authorized institutions to implement cross-boundary credit data sharing between Hong Kong and the Mainland. The HKMA outlines two recommended collaboration models and emphasises AIs' obligations to integrate CBCR into credit risk management systems, ensure data security and customer consent, and conduct consumer education to support GBA financial integration.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Introduction
On 10 Oct 2025, the Hong Kong Monetary Authority (HKMA) issued a circular outlining the regularisation of the Cross-boundary Credit Referencing (CBCR) initiative following successful pilot outcomes, providing guiding principles for authorized institutions (AIs) to implement and expand cross-boundary credit data sharing between Hong Kong and the Mainland, particularly within the Guangdong-Hong Kong-Macau Greater Bay Area (GBA).
CBCR Initiative Overview
The CBCR initiative, comprising the Southbound Scheme (Mainland credit data to Hong Kong banks) and Northbound Scheme (Hong Kong credit data to Mainland banks), addresses the challenge of limited credit history availability for cross-boundary customers. It aims to enable banks to conduct more informed credit assessments, facilitating easier, faster, and lower-cost access to credit for businesses and individuals operating across the boundary, thereby supporting GBA financial integration.
Pilot Programme Outcomes
Following a 2024 Memorandum of Understanding (MoU) between HKMA and the People’s Bank of China (PBoC), a pilot programme validated the operational and technical feasibility of CBCR workflows. The pilot covered diverse scenarios (e.g., account opening, trade financing, mortgages) and data types (traditional and alternative), facilitating over 20 corporate and personal loans exceeding HK$260 million while upholding data security and privacy standards.
Recommended Collaboration Models
The HKMA has identified two recommended models for CBCR implementation: (i) the Direct Transfer Model, where credit reference information is transferred directly from home CRAs to local CRAs for onward bank use (suitable for commercial CBCR); and (ii) the Indirect Model enabled by data portability, where customers collect their credit data via the Shenzhen-Hong Kong cross-boundary Data Validation Platform (utilising blockchain for document verification without transferring original data), suitable for consumer CBCR involving sensitive personal information.
Guiding Principles for AIs
The HKMA reminds AIs of existing requirements under the Personal Data (Privacy) Ordinance, the Code of Practice on Consumer Credit Data, and the Supervisory Policy Manual (SPM) modules IC-6 and IC-7. Key guiding principles include: (a) transitioning from pilot to scalable solutions through process optimisation and automation; (b) proactively integrating CBCR into credit risk management systems, ensuring compliance with HKMA guidelines and implementing necessary operational changes; and (c) conducting consumer education to build public trust regarding CBCR benefits, data handling, and credit access improvements.
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