Mutual recognition of funds between Ireland and Hong Kong: A guide for Irish UCITS seeking Hong Kong market access

The Ireland-HK MRF framework

The Ireland-HK MRF, which aligns with Hong Kong’s existing mutual recognition of funds arrangements with other jurisdictions, including Australia, France, Luxembourg, Mainland China, Malaysia, the Netherlands, Switzerland, Taiwan, Thailand, the United Kingdom and the United Arab Emirates, streamlines the SFC authorisation process for eligible Irish UCITS (the “Irish Covered Funds”) for public offering in Hong Kong under section 104 of the Securities and Futures Ordinance. 

Once authorised by the SFC under the Ireland-HK MRF, Irish Covered Funds must remain authorised by the CBI for public offering to retail investors in Ireland, continue to operate and be managed in accordance with Irish laws and their constitutive documents, comply with all applicable Hong Kong laws and regulations in relation to sales and distribution in Hong Kong and additional SFC requirements for authorisation, post-authorisation and ongoing compliance, provide fair treatment and equivalent protection to investors in both jurisdictions and also make ongoing disclosures available simultaneously in both markets.

Eligibility criteria for Irish UCITS

Under the Ireland-HK MRF, Irish Covered Funds are deemed compliant with the Hong Kong regulatory requirements provided they meet specified eligibility criteria.  To qualify as an “Irish Covered Fund” under the Ireland-HK MRF, an Irish UCITS must be authorised by the CBI for public offering in Ireland and fall within one of the following categories:

1. general equity funds, bond funds, mixed funds or funds investing in other schemes;
2. feeder funds, with underlying funds meeting eligible types;
3. unlisted index funds;
4. passively managed index-tracking exchange traded funds (“ETFs”); or
5. listed open-ended funds (i.e. active ETFs).

In addition, an Irish Covered Fund must satisfy the other eligibility requirements set out in Annex B of the SFC circular (the “Eligibility Requirements”), which include:

1. a leverage limit of 100% of net asset value (“NAV”) using the commitment approach;
2. no investments in physical commodities (e.g. precious metals), real estate, crypto-assets, cryptocurrencies or related certificates;
3. no share classes with hedging beyond currency risk;
4. having at least one dealing day for redemption every two weeks; and
5. appointment of a Hong Kong representative.

The CBI must provide a certificate directly to the SFC confirming that the Eligibility Requirements are met before the application will be considered by the SFC.  Each Irish Covered Fund must also, among other things, appoint a Hong Kong representative in compliance with the SFC Handbook for Unit Trusts and Mutual Funds (the “UT Code”).

Potential applicants are encouraged to consult with the SFC’s Investment Products Division prior to submitting a formal application under the Ireland-HK MRF to clarify how the relevant requirements apply to their specific fund structure, features and circumstances.

Authorisation timeline

An application of an Irish Covered Fund seeking SFC authorisation under the Ireland-HK MRF will be processed under one of the three processing streams below:

Conclusion

Hong Kong’s asset management industry, with mutual fund assets under management reaching approximately HK$2 trillion (approximately US$256 billion) as of mid-2025, presents a compelling growth opportunity for Irish UCITS managers.  While the Ireland-HK MRF is still in its early stages following its launch in May 2025, it serves as a strategic gateway to Asia’s sophisticated and increasingly wealth-driven retail investor base.  By leveraging this framework, Irish UCITS managers can accelerate market entry, achieve regulatory alignment and enhance operational efficiency.  This initiative should be viewed not only as a means to broaden distribution, but also as a platform for Irish UCITS managers to strengthen global brand presence and capture long-term growth in Asia’s dynamic wealth management landscape.

Authored by Michael Wong, Sonia Ngan, and Nicole Yeung.