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Swiss Chinese Law Association — Geneva

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Legal Update China Hong Kong SAR Public consultation

Hong Kong Proposes Lower SIM Card Limits and New Criminal Penalties to Combat Telecommunications Fraud

The Hong Kong SAR Government announced plans to lower individual pre-paid SIM card limits from 10 to three per provider and criminalise unauthorized SIM card transfers and registrations.

What Changed

  • Proposal to lower individual pre-paid SIM card registration limits from 10 to three per provider per person.
  • Proposal to create new criminal offences for unauthorized provision, sale, purchase, rental, or borrowing of registered SIM cards.
  • Announcement of upcoming public and industry consultations on the draft legislative amendments in the coming months.

The Hong Kong Special Administrative Region (HKSAR) Government has announced upcoming legislative proposals to strengthen the Real-name Registration (RNR) Programme for SIM cards and introduce new criminal penalties to curb telephone and cyber fraud. On 11 November 2026, Secretary for Commerce and Economic Development Algernon Yau delivered a consolidated reply in the Legislative Council outlining these policy directions.

Key Regulatory Proposals:

First, the government recommends significantly reducing the maximum registration limit of pre-paid SIM (PPS) cards for individual users from the existing limit of 10 PPS cards per telecommunications service provider (TSP) to three PPS cards per TSP per person. Statistics from TSPs indicate that approximately 98 per cent of individual users currently register no more than three PPS cards per provider, meaning the reduction will affect minimal users while closing potential exploitation avenues for fraud syndicates.

Second, the government proposes to criminalise specific improper conduct concerning registered SIM cards. Proposed criminal offences include providing personal information to register a SIM card intended for use by another person, as well as purchasing, selling, renting, borrowing, or supplying registered SIM cards without lawful authority or reasonable justification. The government is preparing legislative amendments and plans to consult the public and telecommunications industry in the coming months.

Existing Regime and Enforcement:

The RNR Programme, governed by the Telecommunications (Registration of SIM Cards) Regulation (Cap. 106AI), was fully implemented in February 2023. Guidelines issued by the Communications Authority require TSPs to verify user identities using methods such as optical character recognition, manual checks, or 'iAM Smart' (the default method for Hong Kong identity card holders).

Additionally, under a joint blocking mechanism established in September 2022 between the Hong Kong Police Force and major TSPs, providers had blocked over 18,000 local and non-local telephone numbers and suspended fraudulent Voice over Internet Protocol (VoIP) numbers as of the end of September 2026.

Impact:

Telecommunications service providers, businesses, and individuals in Hong Kong SAR must prepare for stricter compliance requirements, reduced PPS registration caps, and potential criminal liability regarding unauthorized SIM card transfers.

Who May Be Affected

Telecommunications service providers, pre-paid SIM card registrants, businesses, and mobile communications users in Hong Kong SAR.

Cross-Border Context

Hong Kong functions as an international telecommunications hub; regulations apply to local SIM cards used for cross-border communications, non-HKID registrants, and overseas VoIP services connecting to local networks.

What to check next

  • Monitor the official release of the upcoming public consultation document by the Commerce and Economic Development Bureau and Security Bureau.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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