Hong Kong’s investor-identification regime for exchange-traded derivatives is expected to begin in the second quarter of 2028, aligned with the rollout of HKEX’s Orion Derivatives Platform. The regime extends the order-tagging model already used in the securities market to futures, options and stock options traded through the Hong Kong Futures Exchange system.[1][2]
The system separates identity submission from order submission. A relevant licensed corporation or registered institution sends client identification data to a central repository, assigns a Broker-Client Assigned Number, and tags that BCAN to each covered on-exchange order. The exchange sees the code on the order; the repository maintains the mapping to the client identity data.[1][2]
The order and identity travel through linked records
HKIDR-DM data path
| Stage | Information | Responsible party |
|---|---|---|
| Client mapping | Name and identity-document information, or the applicable institutional identifier. | Relevant regulated intermediary submits the mapping to the central repository.Source 1 |
| Broker code | A BCAN assigned to the client. | The intermediary creates and maintains the client code under the regime.Source 1Source 2 |
| Order tag | BCAN attached to the futures, options or stock-option order. | The intermediary includes the code when the order is submitted or arranged for submission to ODP-Trading.Source 2 |
| Regulatory reconstruction | Order activity can be connected to the underlying client mapping. | HKEX and the SFC use the linked data within the regime’s regulatory purposes and privacy framework.Source 1 |
The BCAN adds an order-level surveillance identifier alongside the broker’s account and know-your-customer records. Linking the code to the repository lets the SFC reconstruct client activity across intermediaries with fewer separate post-event requests.[1][4]
Scope follows the exchange order and the intermediary
The regime covers on-exchange futures, options and stock-option orders submitted to the relevant Hong Kong Futures Exchange system. Licensed corporations and registered institutions are in scope when providing covered derivatives brokerage or conducting proprietary trading. It follows the securities HKIDR introduced in March 2023. The Q2 2028 implementation window is aligned with Orion and remains subject to market readiness and regulatory approval.[1][2][4]
Consent controls whether an individual can continue opening positions
Individual client consent outcomes
| Position | Order effect | Data treatment |
|---|---|---|
| Express consent given | The intermediary may tag covered orders with the client’s BCAN and submit the required identity mapping. | Data can be stored, processed, used, disclosed and transferred for the notified regulatory purposes.Source 3 |
| No express consent | The intermediary cannot rely on negative confirmation or an opt-out process. | The required personal-data transfer cannot be treated as authorised by silence.Source 3 |
| Consent later withdrawn | Orders already placed or executed remain unaffected; new opening orders should not be submitted. Close-out orders for existing positions remain permitted. | BCAN and identity data already disclosed continue to be retained and used for the notified purposes.Source 3 |
The close-out route avoids trapping an existing position merely because consent is withdrawn. It also prevents withdrawal from becoming a method for maintaining anonymous new exchange exposure. The SFC says frequent giving and withdrawal of consent may prompt enquiries to the intermediary about the circumstances.[3]
The data mapping and the order route need to work together
For implementation, a broker needs to connect accurate client mappings and explicit-consent records to every covered order route. Changes to client data need to reach the repository, while order controls need to distinguish an opening trade from a permitted close-out after consent withdrawal. Testing those links alongside the Orion migration is more informative than testing the creation of a BCAN in isolation.[1][2][3]
Sources & further reading
- Investor Identification Regime for the exchange-traded derivatives market Hong Kong Securities and Futures Commission · 30 Sep 2026 · Accessed 16 Oct 2026
- HKIDR-DM: Investor Identification Regime at Trading Level for the Exchange-Traded Derivatives Market Hong Kong Exchanges and Clearing · Accessed 16 Oct 2026
- FAQs on obtaining express individual client consent under HKIDR-DM Hong Kong Securities and Futures Commission · 30 Sep 2026 · Accessed 16 Oct 2026
- Investor Identification Regime for the securities market and OTC securities reporting Hong Kong Securities and Futures Commission · Accessed 16 Oct 2026