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Swiss Chinese Law Association — Geneva

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Legal Observatory / Everyday Rights

Legal Update China Hong Kong SAR Regulatory guidance

Hong Kong SAR Details Heat Stress Enforcement and Guidance Note Statistics

The Secretary for Labour and Welfare replied to a Legislative Council question detailing 2023–2025 statistics on workplace heat stress injuries, inspections, warning letters, and updates to the Heat Stress at Work Warning system.

What Changed

  • The Labour Department registered 93 heat stress-related work injury cases from 2023 to 2025 (31 in 2023, 29 in 2024, 33 in 2025), with zero fatalities reported.
  • Inspectors conducted 68,167 summer inspections and issued 2,732 warning letters from 2023 to 2025, with no prosecutions instituted under Cap. 509 general duty clauses.
  • The HSWW system was enhanced in April 2026 and late August 2026 to refine warning sensitivity, triggering conditions, and level-raising mechanisms.

Employers, contractors, and outdoor workers in Hong Kong SAR face ongoing updates and regulatory oversight regarding workplace heat stress prevention. On October 28, 2026, the Secretary for Labour and Welfare, Mr Chris Sun, provided a written reply to the Legislative Council addressing the enforcement, legal status, and practical evolution of the Guidance Notes on Prevention of Heat Stroke at Work (GN) and the Heat Stress at Work Warning (HSWW) system.

**Regulatory Framework and Enforcement**

Under the general duty clauses of the Occupational Safety and Health Ordinance (Cap. 509), employers in Hong Kong SAR are required to provide and maintain working environments and systems of work that are safe and without risk to health, so far as reasonably practicable. This includes conducting workplace heat stress risk assessments and implementing preventive measures. Between 2023 and 2025, the Labour Department (LD) conducted tens of thousands of summer inspections—21,493 in 2023, 23,620 in 2024, and 23,054 in 2025. Over this three-year period, the LD issued 993, 1,031, and 708 warning letters respectively, mainly for failures to conduct risk assessments, keep assessment records, or take adequate preventive measures. No prosecutions were instituted under general duty provisions during these inspections, as no serious contraventions warranting prosecution were identified.

**Work Injury Cases and System Enhancements**

The LD registered 93 heat stress-related work injury cases between 2023 and 2025 (31 in 2023, 29 in 2024, and 33 in 2025), with zero fatalities. Among these, 65 cases were settled after employers paid compensation under the Employees' Compensation Ordinance, three reached private settlements, 17 were withdrawn or unpursued, seven remain under processing, and one did not fall under the ordinance.

First established in 2023 based on the Hong Kong Heat Index, the HSWW system underwent enhancements in 2024 (linking Amber warnings to Observatory special alerts), April 2026 (adjusting warning criteria and location coverage), and late August 2026 (introducing additional triggering conditions and a level-raising mechanism). Additionally, since 2023, government service contracts require tenderers to submit Heat Stroke Prevention Work Plans for non-skilled workers.

Who May Be Affected

Employers, main contractors, outsourced service contractors, and outdoor/high-temperature environment workers in Hong Kong SAR.

Cross-Border Context

Relevant for multinational companies, construction firms, and service contractors managing workforce health and safety compliance within Hong Kong SAR.

What to check next

  • Review Labour Department Guidance Notes on Prevention of Heat Stroke at Work for specific risk assessment factors.
  • Monitor future Labour Department announcements on surprise inspection enforcement thresholds.

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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