Insights and Analysis

Streamlined measures on post-authorisation matters for SFC-authorised UCITS funds in Hong Kong

05 December 2025

Key takeaways

The Securities and Futures Commission (the “SFC”) has further streamlined measures for various post-authorisation matters for certain UCITS funds that are authorised to be sold to retail investors in Hong Kong.

Acknowledging that UCITS funds offer investor protection and safeguarding of investor interests which are on par with Hong Kong’s regulatory standards, the SFC’s updated streamline measures aim to facilitate UCITS funds in implementing changes that are subject to their respective home regulator’s supervision, which will in turn boost Hong Kong’s competitiveness as a leading financial hub for global asset managers.

Under the current regime, eligible UCITS funds from specified jurisdictions are afforded a streamlined authorisation process with the SFC in order to be marketed and sold to retail investors in Hong Kong. All SFC-authorised UCITS funds must comply with the relevant Hong Kong requirements in relation to post-authorisation matters.

On 28 November 2025, the SFC published further streamline measures for SFC-authorised UCITS funds to cover the following post-authorisation matters (to be effective from the date of publication (“Effective Date”)):

Change of key operators
SFC prior approval will no longer be required for a change of depositary/custodian and investment delegates which are subject to the home regulator’s supervision, regardless of whether the new depositary/custodian is currently acting in the relevant role of other SFC-authorised funds.
Material changes in investment objectives, policies and restrictions
SFC prior approval will no longer be required for certain material changes in relation to investment objectives, policies and restrictions which comply with the UCITS fund’s home jurisdiction requirements. However, changes which involve novel or complex product features and/or changes which may have local policy implications will still require SFC prior approval. The SFC have provided non-exhaustive examples of these changes, which include:
- Changes that would result in the reclassification of the UCITS fund as a complex product¹ for distribution in Hong Kong.
- Changes that would result in the UCITS fund investing significantly in² or have exposure to novel/complex asset classes (e.g., virtual assets, instruments with loss absorption features, insurance linked securities etc.).
- Changes that would result in the UCITS fund being converted into a specific fund type which is subject to local policy considerations (e.g., conversion from a non-ESG fund to an ESG fund³, or conversion from a variable NAV money market fund to a constant NAV money market fund etc.).
Post-authorisation notifications

To the extent that changes to a UCITS fund do not require SFC prior approval, the notice period and content requirements will generally follow that of the home regulator, unless otherwise specified by the SFC.

For the avoidance of doubt, any existing applications received by the SFC on or before the Effective Date will be processed by the SFC in accordance with existing approval or authorisation processes.

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

References

A non-exhaustive list of investment products that are considered to be “non-complex” and “complex” (as the case may be) may be found here: https://www.sfc.hk/en/Rules-and-standards/Suitability-requirement/Non-complex-and-complex-products.
Significant investments in asset classes refer to investments that exceed the currently permitted exposure for each specific type of asset class as set out in the relevant SFC FAQs.
ESG funds generally refer to SFC-authorised funds which incorporate environmental, social and governance (ESG) factors as their key investment focus and which is reflected in the fund’s investment objective or strategy in accordance with the SFC’s Circular to management companies of SFC-authorised unit trusts and mutual funds: https://apps.sfc.hk/edistributionWeb/api/circular/openFile?lang=TC&refNo=21EC27.