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POLICY EXPRESS · PE-ITIB-180 · Innovation, Technology and Industry Bureau

AI Risk Governance and the Commissioner for AI

Seven risk areas, a new Commissioner and no AI statute: Hong Kong is governing mainly by guideline while computing power grows thirty-six-fold.

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2 pages · English and 繁體中文 · Built on the 1134211 Framework · Facts as at 25 October 2026

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PE-HB-175: Shortening the Wait for Public Rental HousingPE-EDB-147: Right-Sizing the School System for a Shrinking CohortPE-CEDB-130: Supporting Mainland Enterprises to Go GlobalPE-CMAB-120: Aligning Rules and Mechanisms across the Greater Bay AreaPE-CSB-125: Civil Service Size, Productivity and Establishment Control

The tension and our thesis

The tension

Hong Kong wants to be an AI hub and a trusted one, yet seven risk areas sit with many hands, most tools are guidance rather than law, and capability is scaling faster than the rules.

Our thesis

Publish a dated roadmap for the seven areas, harden public-sector rules, and legislate narrowly where gaps are shown.

Three policy problems this brief examines

  1. 01Soft law leaves seams between the seven areas
  2. 02Capability scales faster than the rules
  3. 03Liability and misuse lack a legal home

Each problem is developed in three layers: the fact, why it persists, and the consequence for the system.

Three options compared

A

A · Framework statute: a risk-tiered AI Ordinance with duties and a regulator.

B

B · Guidance plus sector regulators: more guidelines, procurement rules and regulator oversight.

C

C · Wait and align: defer until the working group and Mainland rules settle.

The scored comparison, the justified recommendation with its phased measures, the implementation challenges, the stakeholder assessment and the success metrics are in the full brief.

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