Safeguarding Hong Kong’s Critical Infrastructure: How Businesses Should Prepare for the New Cybersecurity Regulation

Hong Kong’s Critical Infrastructure (Computer System) Protection Ordinance (Cap. 641) is set to take effect soon. This landmark regulation marks the city’s first legal framework dedicated to protecting the cybersecurity of essential information systems — the backbone of Hong Kong’s economy and public safety.

The ordinance aims to ensure that critical computer systems remain secure, resilient, and continuously monitored, preventing disruptions, data breaches, or other risks that could jeopardize social stability or economic operations.

1. What Is “Critical Infrastructure”?

According to the Security Bureau and the draft legislation, Critical Infrastructure (CI) covers sectors that form the foundation of Hong Kong’s essential operations:

• Energy and utilities (electricity, water, gas, etc.)

• Financial systems (banking, payment platforms, securities trading)

• Transport and logistics (ports, railways, aviation control systems)

• Telecommunications networks (telecoms and internet infrastructure)

• Healthcare and public health systems

• Government information systems and public service platforms

Any cyberattack or disruption to these systems could cause widespread service outages, financial losses, and even threats to public safety — making them the key targets for regulatory protection.

2. From Defense to Continuous Monitoring

Unlike traditional defensive approaches that rely solely on firewalls or antivirus tools, the new ordinance requires proactive, continuous monitoring and incident reporting to ensure system integrity at all times.

Key obligations for CI owners include:

1. Appointing a Responsible Person

   Each organization must assign a dedicated officer responsible for cybersecurity and compliance, coordinating risk management and reporting.

2.  Implementing and maintaining security measures

   Organizations must adopt appropriate technical and management controls — such as network segregation, access control, intrusion detection, and regular backups.

3. Establishing a continuous monitoring mechanism

   CI owners are required to continuously monitor system activity, login patterns, network traffic, and potential intrusion attempts to identify anomalies early.

4. Incident notification and response

   If a cyber incident (e.g., data breach, ransomware attack, or system failure) impacts a critical service, the organization must report the incident within the designated timeframe to the Cyber Security and Technology Crime Bureau (CSTCB) and cooperate with investigations.

5. Regular audits and security testing

   Periodic penetration tests, audits, and simulations are required to verify the effectiveness of implemented controls.

3. Legal Penalties for Non-Compliance

The ordinance introduces clear penalties to strengthen accountability and enforcement:

• Failure to report incidents or cooperate with investigations: up to HK$200,000 fine and 12 months’ imprisonment.

• Failure to take remedial or required security measures: up to HK$1,000,000 fine and 2 years’ imprisonment.

• Obstruction of enforcement actions: additional fines or imprisonment depending on severity.

This means cybersecurity compliance is no longer a purely technical matter — it is now a legal responsibility for corporate management and executives.

4. Why “Continuous Monitoring” Is the Core of Compliance

“Continuous Monitoring” is not just a technology — it’s a governance process that ensures long-term system integrity and transparency.

A robust monitoring framework should include:

• Real-time monitoring — consolidate system data streams to detect irregular activities.

• Centralized alert management — visualize risks through dashboards for faster decision-making.

• Automated incident alerts — notify the security team and management immediately upon anomalies.

• Continuous improvement — use audit and incident findings to refine controls over time.

5. How Businesses Can Prepare

CC Concept recommends organizations follow a structured approach to achieve compliance readiness:

1. Conduct a system review and risk assessment — identify vulnerabilities and integration gaps.

2. Implement a unified monitoring platform — centralize visibility across on-premises and cloud systems.

3. Establish automated reporting and classification mechanisms — ensure incidents are categorized and escalated properly.

4. Develop an incident response and notification manual — clearly define roles and escalation paths.

5. Conduct regular drills and awareness training — build a culture of compliance and readiness.

6. Conclusion: Compliance Builds Resilience

The Critical Infrastructure (Computer System) Protection Ordinance represents a major step toward strengthening Hong Kong’s digital resilience.

By implementing continuous monitoring and timely reporting, businesses not only meet regulatory obligations but also enhance their capacity to respond swiftly to cyber threats.

CC Concept helps organizations implement comprehensive compliance frameworks — from system audits and monitoring design to reporting workflows — ensuring that your IT infrastructure operates securely, transparently, and in line with regulatory expectations.