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Hong Kong

Last updated : January 30, 2026

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Digital ID Overview

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Hong Kong’s digital ID system, ‘iAM Smart’, was launched in December 2020.[18] It is a mobile application for HKID holders aged 11 and above, enabling users to log in and access digital government and private services via their mobile phones in a smart and convenient manner.[19] It has four main features: for authentication to access online government and private services such as health records, tax records, library services, and paying bills; electronic signatures for legal documents and online processes; ‘e-ME’ form filling function to complete forms automatically; and set up personal assistant services for receiving government service updates.[20] 

Residents can register for ‘iAM Smart’ by downloading and registering for the app remotely, or alternatively, they can visit self-registration kiosks or registration service counters to register.[21] There are also mobile registration teams set up at shopping malls and government premises to assist those in need with registration, such as the elderly.[22] As of 23 December 2025, the Digital Policy Office announced it had amassed over 4 million registered users on the digital service platform.[23] ‘iAM Smart’ is not mandatory but certain government services such as GovHK Notifications have fully migrated (from January 2026 onwards) and can only be accessible via the mobile app.[24] 

Since the ‘iAM Smart’ system is linked to the HKIDs, it is not linked to citizenship and is a marker of identity and legal residency status in Hong Kong. The ‘iAM Smart’ system is more of a functional ID system because it provides identity authentication to access public and private online services while relying on the HKID card system as the foundational system that establishes legal identity. Because access to ‘iAM Smart’ is contingent on possessing a valid HKID card, only Chinese citizens, permanent residents, and foreign nationals who are eligible for HKIDs, are able to access the digital ID system. Stateless persons who do not have the HKID are unable to register for the ‘iAM Smart’ app and access the public and private services linked to it. 

The ‘iAM Smart’ platform was first announced in the 2017 Policy Address, to develop plans to provide an electronic identity for all Hong Kong residents, enabling them to use a single digital identity and authentication method to conduct online government and commercial transactions.[25] The ‘iAM Smart’ platform was developed by the Office of the Government Chief Information Officer (OGCIO), now merged with the Efficiency Office to be the Digital Policy Office, as a government-led initiative.[26] The government conducted targeted user engagement through design-thinking workshops involving selected citizens from different demographic groups to gather feedback on user experience and interface design of the ‘iAM Smart’ platform.[27] In addition, consultations were undertaken with relevant authorities, such as the Privacy Commissioner, focusing on the compliance of the digital ID registration process with data protection and information security requirements.[28]

Law

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Domestic law and policy

There is no specific legislation governing Hong Kong’s ‘iAM Smart’ digital ID system nor is digital ID defined in any legislation. The government defines electronic authentication on its official website as ‘the process of establishing confidence in user identities presented electronically to an information system’ while a digital certificate is defined as ‘a form of electronic record that serves as an identification of who you are in conducting online transactions.’[29]

The Electronic Transactions Ordinance (ETO) (Cap. 553), enacted in 2000, does provide the legal basis for the digital signing feature on ‘iAM Smart’ platform, as it recognizes the validity of electronic or digital signatures by having the same legal status as paper-based signatures.[30] Besides ‘iAM Smart’ platform, the ETO also provides the legal framework for the Hong Kong Post e-Certs, digital certificates issued by a recognized certificate authority to verify identity and enable legally binding digital signatures, and the Digi-Sign ID-Certs, digital certificates issued by a commercial certification authority.[31]

The ‘iAM Smart’ government has a dedicated hotline and email for individuals to contact should they encounter any fraud or scams related to ‘iAM Smart’ as well as information not to use fraudulent ‘iAM Smart’ websites.[32]

Data Protection

Hong Kong’s main data protection law is the Personal Data (Privacy) Ordinance (Cap.486), as amended in 2021 (PDPO) and its regulator as the Office of the Privacy Commissioner for Personal Data (PCPD).[33] It was first enacted on 20 December 1996, where it introduced data subject rights in Hong Kong, specifying obligations for data controllers and overseeing the collection, processing, holding, and use of personal data.[34] The amendments in 2012 focused on the governing the use and provision of personal data in direct marketing while the current 2021 amendments introduced penalties for doxxing, the unauthorized disclosure of personal data without consent.[35] According to DataGuidance, the PDPO does not explicitly outline requirements for data processors, data protection officers, or mandatory breach notifications in the event of a breach and there are gaps in the implementation of Section 33 on regulating data transfers.[36] In February 2023, the PCPD announced it was studying amendments to strengthen personal data protection such as establishing a mandatory data breach notification mechanism, requiring data users to develop a data retention policy, empowering the PCPD to impose administrative fines, and introducing direct regulation of data processors.[37] These amendments were reportedly put on hold in 2024.[38]

The safeguards for protection of personal information for the ‘iAM Smart’ system is guided by government policies and guidelines on information security as well as provisions in the PDPO.[39]  The “iAM Smart” system has been awarded ISO/IEC 27001 and ISO/IEC 27701 international standard certifications, assuring that the DPO has formulated and implemented comprehensive information security and privacy management measures.[40] Any personal information provided for registration in the ‘iAM Smart’ system is encrypted and stored in government data centres.[41] For example, any photos provided in the app or registration kiosk is deleted immediately after verification of user’s identity.[42] The system only keeps minimal user records, such as login time or time when digital signing is used and will not access users’ transaction data.[43] The types of personal information stored on the system include the HKID number, name, gender, date of birth, email address, contact number, residential address, as well as biometric data.[44] Biometric data will only be stored in users’ personal mobile phones and will not be stored on the digital ID system.[45] Although the PDPO does not have a legal definition for biometric data or sensitive data, the PCPD has released guidance on the collection and use of biometric data outlining good practices on protecting sensitive personal data.[46] 

Despite all these safeguards and provisions in the PDPO, there are no provisions to prohibit government access to the personal information collected and stored from the ‘iAM Smart’ system. The government announced in October 2025 that it plans on installing tens of thousands of surveillance cameras with AI-powered real-time facial recognition, following the steps of China to use them to monitor public spaces.[47] Researchers have warned there are no clear rules on the use of AI by law enforcement agencies and whether the existing legal framework is sufficient to prevent abuse of power by police.[48] Academics have observed that since the enactment of the National Security Law by China, there have been notable changes in Hong Kong’s internet governance and digital surveillance environment that raise broader questions about privacy safeguards and state access to personal data under evolving legal and policy frameworks.[49] 

International Commitments

Hong Kong has ratified the following major human rights treaties, the 1954 Convention relating to the Status of Stateless Persons as well as the ICCPR, ICESCR, ICERD, CRC, and CEDAW.[50] As a signatory to the CRC, Hong Kong has an obligation to ensure all children are able to access essential services, which includes access to services that are linked to digital systems as well.[51]

Hong Kong became a participating member in the APEC Cross-Border Privacy Enforcement Arrangement (CPEA) in July 2010, where the PCPD is a recognized privacy enforcement authority.[52] The CPEA provides a framework for participating authorities to share information and aid with cross-border data privacy investigations and enforcement matters.[53]

Designed to Include?

The Impact of Digital ID and Legal Identity on Citizenship and Nationality Rights

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The ‘iAM Smart’ digital ID system is not linked to proof of citizenship in Hong Kong, as citizenship is governed by China’s nationality laws and administered separately from the HKID and digital ID.[54] As such, the ‘iAM Smart’ system does not reduce or contribute to statelessness. However, because access to ‘iAM Smart’ is contingent on possession of a valid HKID, which in turn requires legal residency status, the digital ID system indirectly reinforces exclusions faced by stateless individuals who are unable to obtain an HKID.

Stateless individuals who do not qualify for HKIDs are unable to register for ‘iAM Smart’ and are therefore excluded from a growing number of public and private services that are increasingly accessible primarily through the digital app. These include access to government e-services such as digital health records, tax filings, social welfare applications, online appointment systems, library services, and electronic notifications through GovHK, as well as private sector services such as banking, insurance, and utility payments.[55] 

The current legal and policy framework governing digital ID in Hong Kong lacks explicit provisions on inclusivity, transparency, and accountability for individuals without legal identity or residency status. However, the government has undertaken some measures to facilitate access to ‘iAM Smart’ for specific groups, particularly the elderly and persons with limited digital literacy, such as mobile registration teams at shopping malls, self-registration kiosks, and in-person assistance at service counters.[56] The government could undertake more inclusive measures towards vulnerable populations such as stateless individuals, persons with disabilities, and minorities, by ensuring access to essential public and private services can be accessed through alternative mechanisms regardless of possession of a legal identity.

References
1.^

 ‘Hong Kong Identity Cards | Immigration Department’ <https://www.immd.gov.hk/eng/services/hkid/general_info.html> accessed 12 January 2026; ‘Hong Kong Tax ID Number Guide’ <https://taxid.pro/docs/countries/hong-kong> accessed 12 January 2026.

2.^

 ‘Registration/Replacement of Hong Kong Identity Card | Immigration Department’ <https://www.immd.gov.hk/eng/services/hkid/reg_replace.html#under_18> accessed 12 January 2026.

3.^

 ‘INFORMATION ON THE FRONT OF THE HONG KONG IDENTITY CARD’; ‘Human Resources Office - City University of Hong Kong’ <https://www.cityu.edu.hk/hro/en/employee/living/hkid.asp> accessed 12 January 2026.

4.^

 ‘Introduction of New Smart Hong Kong Identity Card and Territory-Wide Identity Card Replacement Exercise | Immigration Department’ <https://www.immd.gov.hk/eng/press/press-releases/20181018.html> accessed 12 January 2026; ‘The Smart Identity Card | Immigration Department’ <https://www.immd.gov.hk/eng/services/hkid/smartid.html> accessed 12 January 2026.

5.^

 ‘Apply for Right of Abode in Hong Kong | Immigration Department’ <https://www.immd.gov.hk/eng/services/right-of-abode-in-hksar/apply.html#perm_id&firstTab> accessed 12 January 2026.

6.^

 ‘Eligibility for the Right of Abode in the HKSAR | Immigration Department’ <https://www.immd.gov.hk/eng/services/roa/eligible.html> accessed 12 January 2026.

7.^

 [email protected], ‘Complete Guide: Hong Kong Identity Card for Foreigners’ (FastLane HR, 22 February 2025) <https://fastlanehr.hk/hong-kong-identity-card-for-foreigners/> accessed 12 January 2026.

8.^

 ‘Registration/Replacement of Hong Kong Identity Card | Immigration Department’ (n 2).

9.^

 ‘Nationality Law of the People’s Republic of China | Immigration Department’ <https://www.immd.gov.hk/eng/residents/immigration/chinese/law.html> accessed 12 January 2026.

10.^

 ‘HKID Card Application & Renewal: Everything You Need to Know’ (Wise, 10 September 2021) <https://wise.com/hk/blog/hkid-card-application-renewal> accessed 12 January 2026.

11.^

 ‘Registration/Replacement of Hong Kong Identity Card | Immigration Department’ (n 2).

12.^

 ‘Registration of a Birth | Immigration Department’ <https://www.immd.gov.hk/eng/services/birth-death/Registration_of_a_Birth.html> accessed 12 January 2026.

13.^

 ‘Registration/Replacement of Hong Kong Identity Card | Immigration Department’ (n 2).

14.^

 ‘Registration of a Birth | Immigration Department’ (n 12).

15.^

ibid

16.^

ibid

17.^

 ‘Hong Kong’s Stateless Children Lost in Translation as Refugee Claims Soar’ Reuters (19 June 2016) <https://www.reuters.com/article/world/hong-kongs-stateless-children-lost-in-translation-as-refugee-claims-soar-idUSKCN0Z503C/> accessed 19 January 2026.

18.^

 ‘“iAM Smart” Adoption by Public and Private Organisations | Digital Policy Office’ <https://www.digitalpolicy.gov.hk/en/our_work/data_governance/common_data_platforms/iam_smart/organisations/> accessed 13 January 2026.

19.^

ibid

20.^

 ‘“iAM Smart” | Digital Policy Office’ <https://www.digitalpolicy.gov.hk/en/our_work/data_governance/common_data_platforms/iam_smart/> accessed 13 January 2026.

21.^

 ‘iAM Smart - About “iAM Smart”’ (iAM Smart - About ‘iAM Smart’) <https://www.iamsmart.gov.hk/en/about.html> accessed 13 January 2026.

22.^

ibid

23.^

 ‘“iAM Smart” Registered Users Exceed 4 Million, Realising “Single Portal for Online Government Services”’ <https://www.info.gov.hk/gia/general/202512/23/P2025122300274.htm> accessed 13 January 2026.

24.^

 ‘iAM Smart - Frequently Asked Questions (FAQs)’ (iAM Smart - Frequently Asked Questions (FAQs)) <https://www.iamsmart.gov.hk/en/faq.html> accessed 13 January 2026; GovHK (www.gov.hk), ‘GovHK: [Important Notice] GovHK Notifications Has Migrated to iAM Smart Platform’ <https://www.gov.hk/en/theme/govhknotifications/?id=15074735> accessed 13 January 2026.

25.^

 ‘“iAM Smart” System in Smart City Blueprint for Hong Kong - Case Studies’ <https://www.emperortech.com/case-studies/epublic-services/Smart-City-Blueprint-for-HK.html> accessed 13 January 2026.

26.^

 ‘Government Launches “iAM Smart” (with Photos)’ (The Government of the HKSAR: Press Releases) <https://www.info.gov.hk/gia/general/202012/29/P2020122900647.htm> accessed 13 January 2026.

27.^

 ‘Design Thinking | Digital Policy Office’ <https://www.digitalpolicy.gov.hk/en/our_work/data_governance/management_consultancy/design_thinking/> accessed 13 January 2026.

28.^

 ‘Legislative Council Panel on Information Technology and Broadcasting - Progress on the Enhancement of “iAM Smart”’ (8 July 2024) <https://www.legco.gov.hk/yr2024/english/panels/itb/papers/itb20240708cb1-903-2-e.pdf> accessed 13 January 2026.

29.^

 GovHK (www.gov.hk), ‘GovHK: Electronic Authentication & Digital Certificates’ <https://www.gov.hk/en/residents/communication/infosec/cybersecurity/digitalcert.htm> accessed 14 January 2026.

30.^

 ‘“iAM Smart” Adoption by Public and Private Organisations | Digital Policy Office’ <https://www.digitalpolicy.gov.hk/en/our_work/data_governance/common_data_platforms/iam_smart/organisations/> accessed 14 January 2026.

31.^

 GovHK (www.gov.hk), ‘GovHK: Electronic Authentication & Digital Certificates’ <https://www.gov.hk/en/residents/communication/infosec/cybersecurity/digitalcert.htm> accessed 14 January 2026.

32.^

 ‘iAM Smart - Anti-Fraud’ (iAM Smart - About ‘iAM Smart’) <https://www.iamsmart.gov.hk/en/anti_fraud.html> accessed 14 January 2026.

33.^

 ‘Hong Kong | Jurisdictions’ (DataGuidance) <https://www.dataguidance.com/jurisdictions/hong-kong> accessed 14 January 2026.

34.^

 ‘Data Protection in Hong Kong, SAR - Data Protection Laws of the World’ <https://www.dlapiperdataprotection.com/?c=HK&t=data-protection-officers#insight> accessed 14 January 2026.

35.^

ibid

36.^

 ‘Hong Kong | Jurisdictions’ (n 33).

37.^

 ‘Legislative Council Panel on Constitutional Affairs: Report on the Work of the Office of the Privacy Commissioner for Personal Data in 2022’ (2023) <https://www.legco.gov.hk/yr2023/english/panels/ca/papers/ca20230220cb2-132-2-e.pdf> accessed 14 January 2026.

38.^

 ‘Hong Kong | Jurisdictions’ (n 33).

39.^

 ‘iAM Smart - Security and Privacy Protection’ (iAM Smart - About ‘iAM Smart’) <https://www.iamsmart.gov.hk/en/about-privacy.html> accessed 14 January 2026.

40.^

ibid

41.^

 ‘iAM Smart - Frequently Asked Questions (FAQs)’ (iAM Smart - Frequently Asked Questions (FAQs)) <https://www.iamsmart.gov.hk/en/faq.html> accessed 14 January 2026.

42.^

 ‘iAM Smart - Security and Privacy Protection’ (n 39).

43.^

 ‘iAM Smart - Frequently Asked Questions (FAQs)’ (n 41).

44.^

ibid

45.^

ibid

46.^

 ‘What’s New: PCPD Revised the “Guidance on Collection and Use of Biometric Data”’ <https://www.pcpd.org.hk/english/whatsnew/biometric_data.html> accessed 14 January 2026.

47.^

 Masha Borak, ‘Hong Kong to Increase the Number of Facial Recognition Cameras | Biometric Update’ (6 October 2025) <https://www.biometricupdate.com/202510/hong-kong-to-increase-the-number-of-facial-recognition-cameras> accessed 14 January 2026.

48.^

 No Author, ‘Hong Kong to Install Surveillance Cameras with AI Facial Recognition’ (The Japan Times, 4 October 2025) <https://www.japantimes.co.jp/news/2025/10/04/asia-pacific/crime-legal/hong-kong-ai-surveillance/> accessed 14 January 2026.

49.^

 Jessica Beyer, ‘Internet Censorship and Digital Surveillance Under Hong Kong’s National Security Law’ (The Henry M. Jackson School of International Studies, 28 March 2024) <https://jsis.washington.edu/news/internet-censorship-and-digital-surveillance-under-hong-kongs-national-security-law/> accessed 19 January 2026.

50.^

 ‘Hong Kong - Statelessness Encyclopedia Asia Pacific - SEAP’ <https://seap.nationalityforall.org/region/regional-overview/east-asia/hong-kong/> accessed 14 January 2026.

51.^

 ‘General Comment No. 25 (2021) on Children’s Rights in Relation to the Digital Environment’ <https://www.unicef.org/bulgaria/en/media/10596/file>.

52.^

 ‘Hong Kong, China’s Participation in the Asia-Pacific Economic Cooperation (APEC), the Organisation for Economic Co-Operation and Development (OECD) Trade Committee and the Pacific Economic Cooperation Council (PECC)’ <https://www.tid.gov.hk/en/our_work/hk_participation_in_ito/hk_in_apec_oced_pecc.html> accessed 14 January 2026.

53.^

 ‘APEC Cross-Border Privacy Enforcement Arrangement (CPEA)’ (APEC) <https://www.apec.org/groups/committee-on-trade-and-investment/digital-economy-steering-group/cross-border-privacy-enforcement-arrangement> accessed 14 January 2026.

54.^

 ‘Nationality Law of the People’s Republic of China | Immigration Department’ (n 9).

55.^

 ‘“iAM Smart” | Digital Policy Office’ (n 20).

56.^

 ‘iAM Smart - About “iAM Smart”’ (n 21).

See Statelessness Overview
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