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Effective Date: January 1, 2026

Organizations designated as Critical Infrastructure Operators (CIOs) must be fully compliant. Start your preparation now to avoid penalties and ensure business continuity.

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Understanding the CI Bill

Hong Kong's Protection of Critical Infrastructures (Computer Systems) Bill was passed on March 19, 2025, establishing comprehensive security requirements for designated operators.

Regulatory Authority

A new Commissioner's Office under the Security Bureau will oversee compliance, supported by Designated Authorities for specific sectors.

Regulated Entities

Applies to designated Critical Infrastructures (CIs), Critical Infrastructure Operators (CIOs), and Critical Computer Systems (CCSs).

Penalties

Non-compliance can result in fines from HK$300,000 to HK$5 million, with additional daily fines for continuing offenses.

Covered Sectors

The Bill covers eight essential service sectors, plus other infrastructure whose damage could substantially affect critical societal or economic activities.

Energy

Power generation, transmission, and distribution facilities

Information Technology

Data centers, cloud services, and IT infrastructure

Banking & Financial Services

Banks, payment systems, and financial institutions

Air Transport

Airports, air traffic control, and aviation services

Land Transport

Railways, tunnels, and public transportation systems

Maritime Transport

Ports, shipping, and maritime logistics

Healthcare Services

Hospitals, clinics, and medical facilities

Telecommunications & Broadcasting

Telecom networks, ISPs, and broadcast services

Other Covered Infrastructure

Major sports and performance venues, technology parks, and other infrastructure whose damage or data leakage could substantially affect critical societal or economic activities.

CIO Compliance Obligations

Critical Infrastructure Operators must fulfill three categories of obligations under the Bill.

Organizational Obligations

  • Maintain an address and office in Hong Kong
  • Notify authorities of ownership and operation changes
  • Establish a Computer System Security Management Unit (can be outsourced)
  • Supervise the unit with decdicated and qualified security professionals

Prevention Obligations

  • Inform authorities of material changes to CCSs
  • Formulate and implement a Security Management Plan
  • Conduct (at least) annual security risk assessments
  • Conduct (at least) biennial independent security audits

Incident Response Obligations

  • Conduct Security Drills (at least) Biennial
  • Implement and submit an Emergency Response Plan
  • Report serious incidents within 12 hours
  • Report other incidents within 48 hours

Our CI Compliance Services

Comprehensive services to help your organization achieve and maintain compliance with the Protection of Critical Infrastructures Bill.

Security Management Plan Development

Development of comprehensive security management plans aligned with CI Bill requirements and industry best practices.

  • Policy and procedure development
  • Security governance framework
  • Change management processes
  • Documentation templates

Annual Risk Assessment

Mandatory annual security risk assessments to identify, evaluate, and prioritize security threats to your critical computer systems.

  • Threat landscape analysis
  • Vulnerability assessment
  • Risk scoring and prioritization
  • Mitigation recommendations

Biennial Independent Audit

Independent security audits conducted every two years to verify compliance and assess the effectiveness of security controls.

  • Independent third-party assessment
  • Control effectiveness testing
  • Compliance verification
  • Audit report and attestation

Incident Response Planning

Development and implementation of emergency response plans to meet the Bill's incident reporting and response requirements.

  • Emergency response plan development
  • Incident classification framework
  • Reporting procedure templates
  • Tabletop exercises and drills

Security Unit Staffing Support

Assistance in establishing and staffing your Computer System Security Management Unit with qualified professionals.

  • Role and responsibility definition
  • Qualification requirements
  • Recruitment support
  • Training and certification

Your Compliance Journey

A structured approach to achieving CI Bill compliance before the July 2026 deadline.

1

Initial Assessment

2-4 Weeks

Comprehensive gap analysis to understand your current compliance status and identify critical areas requiring attention.

2

CCS Identification

3-6 Weeks

Identify and document all Critical Computer Systems within your organization and their dependencies.

3

Security Management Plan

4-8 Weeks

Develop comprehensive security policies, procedures, and governance frameworks aligned with CI Bill requirements.

4

Security Control Implementation

8-16 Weeks

Implement required security controls, establish the Security Management Unit, and deploy monitoring capabilities.

5

Testing & Validation

4-6 Weeks

Conduct security assessments, tabletop exercises, and validate incident response procedures.

Compliance Achieved and Maintaining

Ongoing

Maintain compliance through annual risk assessments, biennial audits, and continuous monitoring.

Start Your CI Compliance Journey Today

Now is the time to assess your readiness and begin implementation. Our experts are ready to guide you through every step of the compliance process.