Hong Kong passed its CRS 2.0 legislation in 2025 and is targeting implementation in 2028-2029. The key changes:
- Cryptocurrency and digital assets included in reporting scope
- Dual-resident individuals must declare all tax residencies, not just one
- Expanded definition of “investment entity” to capture more fund and asset-holding structures
- More detailed reporting — account holder roles, account types, and status must be specified
For mainland Chinese holding Hong Kong accounts, the practical impact won’t hit until 2029 at the earliest. But the direction is clear: the gap between CRS 1.0 and 2.0 is closing. Any planning that relies on Hong Kong being outside the CRS loop has a limited shelf life.
Sources: Hong Kong government consultation paper 2025, Han Kun Law analysis, OECD CRS 2.0 framework.