On 31 Dec 2025, the HKMA mandated financial institutions to submit a self-assessment of compliance with the Code of Banking Practice 2025 for the period 10 December 2024 to 31 December 2025, requiring detailed reporting on institutional and subsidiary compliance, with negative responses necessitating rectification plans. Submissions must be filed by 31 March 2026 via the Common Submission Platform using approved electronic signatures.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Introduction
On 31 Dec 2025, the Hong Kong Monetary Authority (HKMA) issued the Self-Assessment of Compliance with the Code of Banking Practice 2025, providing a mandatory reporting template for financial institutions to assess adherence to the Code for the period 10 December 2024 to 31 December 2025, with submissions due by 31 March 2026.
Reporting Period and Scope
The self-assessment must cover the reporting period from 10 December 2024 to 31 December 2025, requiring submission by 31 March 2026. Institutions must assess compliance across all business segments and channels, including subsidiaries and affiliated companies controlled by them that provide banking services in Hong Kong but are not licensed or regulated by Hong Kong financial authorities. These entities must be explicitly listed in the 'List of Subsidiaries' worksheet.
Assessment Requirements
Institutions must complete Part I (for the institution) and Part I(A) (for subsidiaries/affiliated companies) with specific responses to Code provisions. Negative responses to any requirement necessitate detailed explanations in Part I - Details or Part I(A) - Details, including policy gaps, non-compliance descriptions, rectification plans, and incident reporting dates. For Part II, supplementary questions address internal monitoring systems, staff training, new product compliance, and specific Code sections (e.g., APR exceeding 36%, branch closure notices, credit card marketing to students).
Submission Procedures
The completed template must be submitted via the Common Submission Platform in EXCEL format, accompanied by scanned signed copies of the 'Covering Page' and 'Declaration' (if applicable) in PDF. Electronic signatures are mandated, with acceptable forms including digital signatures via Hongkong Post e-Cert, scanned manual signatures, or email approvals. Institutions must ensure proper authorisation controls for electronic signatures and confirm compliance via the 'Signature and Submission Arrangement' checkbox.
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