On 27 Nov 2025, the HKMA finalised SPM modules, disclosure templates, and banking returns to implement the 2025 Amendment Rules, effective 1 January 2026. Key updates include new cryptoasset classification rules (CRP-1), revised disclosure templates with a new Part XII, and transitional arrangements for banking returns. The changes clarify CBDC treatment, exempt intra-book transfers from capital surcharges, and provide a six-month transition for institutions without cryptoasset exposures.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Introduction
On 27 Nov 2025, the Hong Kong Monetary Authority (HKMA) finalised regulatory updates implementing the Banking (Capital) (Amendment) Rules 2025, Banking (Disclosure) (Amendment) Rules 2025, and Banking (Exposure Limits) (Amendment) Rules 2025, effective 1 January 2026, to address cryptoasset exposures and related reporting requirements.
Revised SPM Modules and Code of Practice
The HKMA finalised new and revised Supervisory Policy Manual (SPM) modules and a code of practice, effective 1 January 2026, primarily to implement the 2025 Amendment Rules. Key revisions include: (i) the new CRP-1 module for cryptoasset classification, clarifying prudential treatment of central bank digital currencies (CBDCs) and streamlining tokenised traditional asset classification; (ii) amendments to modules CA-D-1, CA-G-1, CA-G-5, CR-G-8, CR-G-9, CR-L-5, LM-1, MR-1, MR-2, and the Banking (Exposure Limits) Code; and (iii) clarifications that intra-book transfers from cryptoasset reclassifications are exempt from capital surcharges under MR-1.
Revised Disclosure Templates and Tables
The HKMA issued revised disclosure templates and tables under the Banking (Disclosure) Rules (BDR), effective 1 January 2026, featuring a new Part XII for cryptoasset exposures. The package replaces existing templates and tables, reflecting updated capital standards and disclosure requirements. Authorized Institutions must use the revised templates for reporting periods ending after 1 January 2026, accessible via the HKMA’s public website.
Banking Returns and Transitional Arrangements
Banking return templates (e.g., MA(BS)1E, MA(BS)3, MA(BS)3A, MA(BS)26–28) and completion instructions will be available for download in December 2025, with no material revisions from consultative versions. A six-month transitional arrangement applies: Authorized Institutions without cryptoasset exposures as of 1 January 2026 may continue using legacy templates until 30 June 2026. For institutions facing system challenges, temporary alternative arrangements for reporting positions between 31 January and 30 June 2026 may be agreed with the HKMA.
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