This mainland–Hong Kong standard contract does not cover Macao. Macao needs a separate assessment.

Does signing it clear the PDPO?

No. You still have to meet the six principles and openness duties. The contract is only part of a cross-boundary arrangement.

04 / 15·PDPO, cross-border data, and private AI

The GBA standard contract for mainland–Hong Kong personal information

12 October 2026

Direct answerThe 2023 standard contract for cross-boundary personal information between the mainland and Hong Kong is a voluntary facilitation tool. It does not apply automatically to every transfer and it does not cover Macao. It does not replace the six PDPO principles, and it does not by itself mean the mainland Personal Information Protection Law is fully satisfied. Have a lawyer who knows both regimes check the actual transfer before you sign.

What it is and is not

It is an optional contract text for certain personal-information flows between the mainland and Hong Kong. It is not a substitute for section 33 coming into force, and it does not apply to Macao.

When an SME should look at it

If systems, support, or HR send identifiable personal information from Hong Kong to a mainland organisation, or the other way, list the fields and the recipient, then ask counsel whether the standard contract or another PIPL route fits.

Do not treat a filled template as compliance

The standard text still has to match the real processor, purpose, and security measures. A wrongly completed schedule misleads clients more than having no contract.

Questions

Does it cover Macao?: This mainland–Hong Kong standard contract does not cover Macao. Macao needs a separate assessment.
Does signing it clear the PDPO?: No. You still have to meet the six principles and openness duties. The contract is only part of a cross-boundary arrangement.

This article is general information, not legal advice. PCPD guidance changes — check the latest version before you rely on it.

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