Mainland investors in Hong Kong face a critical milestone in the verification process for opening bank accounts without existing accounts. The declaration of the source of funds is crucial for the reactivation of these accounts.

Summary of Key Points

Recently, some banks in Hong Kong, such as HSBC Hong Kong and Chinese-funded bank branches in Hong Kong, have begun requiring “long-term inactive accounts” held by existing mainland investors to submit statements detailing the source of their funds. This is not a new policy but rather the implementation of regulatory requirements issued by the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) in May of this year. If investors fail to submit the statements by the specified deadlines (e.g., August 20th, September 12th, etc.), their investment services may be suspended or terminated, and their accounts may even be closed. However, the banks only require investors to “self-certify” that the source of their funds is legal (from overseas sources) without conducting any substantive verification. Investors are responsible for the accuracy of their statements; active accounts are not affected for the time being.

Detailed Explanation

1. Why the sudden requirement for statements? It’s not a new policy, but the enforcement of an existing rule

This action is not a sudden tightening of regulations in Hong Kong; it’s just the implementation of a notice jointly issued by the HKMA and the SFC on May 22nd of this year. The notice outlined three requirements for mainland investor accounts:

• Identify accounts opened with suspicious or forged documents;
• Address “inactive accounts with zero balances;
• Require new account openings to include statements detailing the source of funds.

The current requirement for existing customers to submit statements is part of the second requirement: addressing inactive accounts. The notice mandates that banks complete the verification of inactive accounts within three months (by the end of August) and close them within six months (by the end of November). Therefore, banks are now urging customers to submit the required statements.

2. Which accounts will be targeted?

Only “inactive investment accounts with zero balances” are affected. Specifically, these accounts must meet the following criteria:

• The account was opened by a mainland investor;
• As of May 22nd, 2026 (the reference date), there is no asset balance in the account;
• No transactions were made in the 12 months prior to the reference date (e.g., no stock or fund purchases, or even no account logins).

In simple terms, if you have an investment account in Hong Kong with no funds and haven’t made any movements for over a year, you may receive a notification. Active accounts (with assets and frequent usage) are not affected for now.

3. What are the consequences of non-compliance?

There are gradual steps leading to the possible freezing or closure of an account:

• August 20th: If you haven’t submitted the statement, your investment services may be suspended (you won’t be able to buy stocks, funds, etc.).
• September 12th: If you still haven’t submitted the statement, your investment services may be terminated (you will no longer be able to use the investment functions).
• By the end of November: If you haven’t completed the required procedures (submitted the statement), your account will be closed, unless you have a valid reason (e.g., you were out of the country and didn’t receive the notification). Additionally, if you used false information when opening the account, your account will be closed immediately, with no chance of submitting a statement later.

4. What should the statement include?

The bank will not verify the source of your funds; you are responsible for providing a statement. The most important requirement in the statement is to “confirm that the investment funds come from legal sources outside of the mainland.” The bank will not check whether the funds came from your Hong Kong salary or were transferred from the mainland; they simply require you to sign a written commitment or confirm via an app notification. Keep a copy of the confirmation.

5. What should ordinary investors do?

• Step 1: Log in to your Hong Kong bank account to see if you have received any notifications regarding the statement requirement (pop-ups, emails, or texts).
• Step 2: Determine whether your account is inactive: Do you have any assets in the account? Have you made any transactions in the past year? If your account is active, you don’t need to do anything. If it’s inactive, submit the statement as soon as possible to avoid having your account services suspended.
• Step 3: Think carefully before submitting the statement: Make sure the source of your funds meets the requirements. Don’t sign the statement blindly; otherwise, you will be responsible for any issues that arise.

In one sentence

Hong Kong banks are requiring inactive mainland investment accounts to submit statements detailing the source of funds as part of the enforcement of existing regulations. Active accounts are not affected, but inactive accounts need to be addressed promptly. Signing the statement is a form of self-certification, and you are fully responsible for the accuracy of the information provided.