On 29 Dec 2025, the HKMA issued further FAQs clarifying that the expected standards under the 2023 G&S Circular (excluding bookbuilding) do not apply to transactions where investment products are not marketed or classified as green or sustainable. The FAQs also confirm that registered institutions may utilise existing regulatory guidance for product disclosure to satisfy the 'Disclosure' standards, enhancing clarity and operational efficiency.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Introduction and Purpose of the Circular
On 29 Dec 2025, the Hong Kong Monetary Authority (HKMA) issued further Frequently Asked Questions (FAQs) to clarify the application of the expected standards for the sale and distribution of green and sustainable investment products, building upon the 2023 G&S Circular. The FAQs address industry enquiries and enhance customer experience while ensuring investor protection, following a thematic review of registered institutions' implementation of the 2023 G&S Circular.
Key Clarifications on Applicability of Expected Standards
The HKMA clarifies that the expected standards (except for bookbuilding activities) set out in the 2023 G&S Circular do not apply to transactions where registered institutions do not market or classify the investment product as green and sustainable. This addresses a specific gap identified during the thematic review, reinforcing that the regulatory expectations are contingent on the product's classification and marketing as green or sustainable.
Guidance on Product Disclosure Practices
Registered institutions may continue to follow existing regulatory guidance on streamlining product disclosure to meet the 'Disclosure' expected standards outlined in the 2023 G&S Circular. This provides flexibility for institutions to leverage established practices while ensuring compliance with the disclosure requirements for green and sustainable investment products.
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