The new requirements for Hong Kong investment accounts from May 2026 refer to circulars issued on the same day, 2026-05-22, by the Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA). When a Chinese Mainland investor opens an investment account (which, at a bank, includes the investment function of an integrated account), the investor must sign a written declaration confirming that the investment funds come from lawful sources outside the Mainland, and money may move in and out only through eligible bank accounts in the investor's own name. Existing accounts are reviewed under two headings: dormancy and the authenticity of documents. The measures govern investment accounts, not opening a Hong Kong bank account as such; non-investment functions such as savings, deposits and payments are outside their scope.
Regulatory update column · Based on public documents as at 2026-10-24. Banks are subject to Annexes 1 and 2 of the HKMA circular; securities firms are subject to Appendices B and C of the SFC circular.
Timeline: three documents on the same day
| Date | Issuer | Document | Key points |
|---|---|---|---|
| 2026-05-22 | SFC | Circular to licensed corporations (SFO/IS/018/2026) and Appendices A–C | Review of the account opening practices of 12 licensed brokers found deficiencies such as accepting suspicious or forged documents; additional measures set for Chinese Mainland investors' investment accounts |
| 2026-05-22 | HKMA | Circular to all authorized institutions (B1/15C, G16/1C) and Annexes 1 and 2 | Requires banks to apply similar measures; Annex 1 sets out the measures for banks, Annex 2 is a set of FAQs |
| Published 2026-05-22 (issued 2026-05-09) | CSRC and seven other Mainland authorities | Implementation plan for a comprehensive crackdown on illegal cross-border securities, futures and fund business (abridged version reproduced on the Shanghai Stock Exchange website) | The text states that "a 2-year concentrated rectification period will be set to clear up illegal existing business", and that domestic investors will be guided to invest overseas through lawful channels such as Southbound Stock Connect, QDII and Cross-boundary Wealth Management Connect |
| 2026-08 | — | Media reports | Media reported that Hong Kong banks had begun asking existing Mainland clients to verify the offshore source of their investment funds (Caixin, 2026-08-18, secondary source) |
Appendix A to the SFC circular discloses that in the most serious case, more than 50% of the client accounts sampled by the SFC had used forged documents at account opening, for example identical broker statements with only the name, address or account number changed. The SFC requires brokers to warn clients of the consequences of submitting forged documents, including termination of the account, a report to law enforcement agencies and possible criminal prosecution. This is the immediate background to the new measures.
Who is covered and key definitions
Who must apply the measures: The SFC circular applies to licensed corporations (LCs, such as securities firms); the HKMA circular applies to registered institutions (RIs, meaning banks carrying on securities business).
"Investment account": A footnote to the HKMA circular explains that, for banks, this means investment accounts and the investment function of integrated accounts.
"Chinese Mainland investor": An individual investor who uses a PRC Resident Identity Card and/or passport as proof of identity, as shown in the bank's records or the identity documents provided at account opening (HKMA Annex 1).
Where the measures do not apply:
| Situation | Basis | Notes |
|---|---|---|
| Non-investment functions (savings, current account, time deposits, payments, loans, credit cards) | HKMA Annex 2, Q3 and Q6 | Suspension and closure apply only to the investment function of an integrated account |
| Corporate and institutional clients | HKMA Annex 2, Q12; SFC Appendix C, Q10 | The measures target individual clients; banks must still complete normal due diligence on corporate clients |
| Southbound Wealth Management Connect customers | HKMA Annex 1 | Follow the existing rules jointly set by regulators in both places |
That Annex 1 does not apply to corporate clients is simply a statement of fact. Banks will still identify beneficial owners and the source of funds, and holding investments through a company raises separate legal, tax and foreign-exchange issues.
New investment accounts: the five requirements of Measure 3
HKMA Annex 1 provides that from the circular date (2026-05-22), all banks must apply Measure 3 whenever they open an investment account for a Chinese Mainland investor, whatever the account opening method:
- Obtain a written declaration covering: - (a) confirmation that all funds supporting the investment activities and related settlement "come from lawful sources outside the Mainland"; - (b) confirmation that the investor has no account that has been closed or suspended by any licensed corporation or registered institution for using suspicious or forged documents; - (c) an undertaking to notify the bank within 7 business days of any change to the declared information; - (d) confirmation that the investor understands the bank may disclose the investor's personal and other relevant information at the request of law enforcement or regulatory authorities.
- Designate settlement accounts: the investor must settle through bank accounts in their own name held with a Hong Kong licensed bank (for example, the bank itself) or a bank supervised by a banking regulator in an eligible jurisdiction, and all future money in and out must go only through these accounts. The eligible jurisdictions are those on the list published on the SFC's "acceptable account opening approaches" webpage.
- Closure condition: if the source of funds is later found to be unlawful or in breach of Mainland capital controls, the investment account must be closed.
- Keep records: the account opening process must be properly documented for compliance checks and audit.
- Provide information to the HKMA: provide the number and details of new investment accounts, and the declarations, on request.
Annex 2, Q7 explains that the written declaration may be obtained on paper or electronically; Q11 explains that Measure 3 also applies when a Chinese Mainland investor opens an account in person in Hong Kong. HSBC Hong Kong's investment account opening page already tells Chinese Mainland investors that they must submit the declaration before investment services can be activated (accessed 2026-10-24).
Existing investment accounts: Measures 1 and 2
Existing accounts are handled in two categories:
| Item | Measure 1: accounts opened with suspicious or forged documents | Measure 2: dormant zero-balance investment accounts |
|---|---|---|
| Which banks | Banks selected by the HKMA on a risk basis and notified separately | All banks, from the circular date |
| Scope of review | Investment accounts opened since January 2023 (or a period specified by the HKMA) using suspicious or forged documents | Chinese Mainland investors' investment accounts with no asset balance on 2026-05-22 and no client-initiated transactions in the previous 12 months |
| Review deadline | Within 3 months of the HKMA's request, carried out by an independent party | Within 3 months of the circular date |
| What the client can do | After written notice, close out positions and transfer funds out within a reasonable time | Confirm that their information is still valid, sign the written declaration and designate a settlement account in their own name; once the bank is satisfied the procedure is complete, the account can be used again |
| Closure deadline | Within 6 months of completing the review (exceptions must be documented with reasons) | Accounts that have not completed reactivation may be closed within 6 months of the circular date (exceptions must be documented with reasons) |
| Other consequences | Possible report to law enforcement agencies; the client may not open another investment account with the bank or its affiliates | For integrated accounts only the investment function is suspended; non-investment functions are unaffected |
Annex 2 adds that where the same client holds at least one investment account with a non-zero balance or that is not dormant at the same bank, the bank may treat the client relationship as a whole and need not close the zero-balance dormant account. For accounts with transactions after the reference date, deposits, purchases and new positions should be stopped until the client completes the reactivation procedure.
In addition, the main text of the HKMA circular requires all banks to review internally, as soon as possible, whether they have accepted suspicious or forged documents, and to close the accounts concerned.
Compared with the SFC version: under SFC Appendix B, both Measure 1 and Measure 2 are carried out by selected licensed corporations "at the SFC's request", whereas Measure 2 in HKMA Annex 1 applies to all banks. The two should not be confused.
What it means in practice
What you can still do: open and use savings, current and time deposit accounts; use FPS and payment services; invest through lawful channels such as Southbound Wealth Management Connect and Southbound Stock Connect (HKMA circular and Annex 2), with the eight-authority notice also listing QDII.
What to prepare: when adding investment functions, sign the written declaration and designate a settlement account in your own name; be ready to explain the lawful source of your investment funds (see Source of funds and source of wealth); notify the bank within 7 business days if your declared information changes.
Claims that do not hold up:
| Claim | What the documents say |
|---|---|
| "Hong Kong no longer opens accounts for Mainland residents" | The circulars target investment accounts; the HKMA reaffirms a risk-based approach for non-investment accounts |
| "All Mainland clients' accounts will be closed" | Closure targets accounts opened with forged documents and dormant zero-balance investment accounts that have not completed reactivation |
| "Just sign the declaration - where the money comes from doesn't matter" | If the source of funds is later found to be unlawful or in breach of Mainland capital controls, the account must be closed |
| "Funding from a third party's account is fine" | Measure 3 requires all money in and out to go only through eligible bank accounts in the investor's own name |
How suspension or closure is handled is covered in Rejections, document requests and closure.
How Singapore compares
As at 2026-10-24, this site has not seen the Monetary Authority of Singapore (MAS) issue a comparable written declaration requirement aimed at investors of a particular identity; Singapore applies general customer due diligence, such as MAS Notice 626, to all customers.
The enforcement background is worth noting: on 2025-07-04 MAS took regulatory action against 9 financial institutions, with penalties totalling S$27.45 million, for shortcomings including failing to follow up adequately on concerns about customers' source of wealth. Singapore does not draw lines by identity, but its scrutiny of source of funds is just as substantive. Singapore KYC and source-of-funds explanations are covered in bankaccount.com.sg source of funds and source of wealth (in English).
What we are watching
This page will be revised when there are official updates. We are following:
- [ ] Progress of the HKMA's reviews at banks selected under Measure 1, and any public statements
- [ ] Bank notices after the 6-month closure period for dormant zero-balance investment accounts ends (around 2026-11-22, counting from the circular date)
- [ ] Updates to the SFC's list of "eligible jurisdictions"
- [ ] Implementing details of the eight Mainland authorities' crackdown plan (the version reproduced by the Shanghai Stock Exchange is abridged)
- [ ] How banks handle declarations for existing active accounts (so far only reported in the media)
If you would like help interpreting how this applies to you, you can register your enquiry through this site's contact details. This article is not legal advice; bank notices and the original regulatory texts prevail.
Sources and dates
- Expected controls for account opening and maintaining relationships with clients with investment accounts (B1/15C, G16/1C) — Hong Kong Monetary Authority (HKMA) · 2026-05-22
- Annex 1 – Additional measures for opening and managing investment accounts of Chinese Mainland investors — Hong Kong Monetary Authority (HKMA) · 2026-05-22
- Annex 2 – Frequently asked questions for the circular on expected controls for account opening — Hong Kong Monetary Authority (HKMA) · 2026-05-22
- Circular to licensed corporations – Expected controls for account opening and maintaining relationships with clients (SFO/IS/018/2026, Appendices A–C) — Securities and Futures Commission (SFC) · 2026-05-22
- Open Investment Account (notice on the Chinese Mainland investor declaration) — The Hongkong and Shanghai Banking Corporation (HSBC Hong Kong) · 2026-10-24
- 中国证监会等八部门关于印发《综合整治非法跨境证券期货基金经营活动实施方案》的通知(上交所网站转载,有删减) (Notice by the CSRC and seven other authorities on the implementation plan for a comprehensive crackdown on illegal cross-border securities, futures and fund business; abridged version reproduced on the Shanghai Stock Exchange website) — CSRC, Ministry of Industry and Information Technology, Ministry of Public Security, People's Bank of China, State Administration for Market Regulation, National Financial Regulatory Administration, Cyberspace Administration of China, State Administration of Foreign Exchange · 2026-05-09
- Hong Kong banks ask mainland clients to verify offshore source of investment funds (media report, secondary source) — Caixin Global · 2026-08-18
- MAS takes regulatory actions against 9 financial institutions for AML-related breaches — Monetary Authority of Singapore (MAS) · 2025-07-04