The Hong Kong Securities and Futures Commission (SFC) issued a circular on 28 November 2025 concerning a series of streamlined post-authorization measures applicable to certain UCITS funds authorized for public distribution in Hong Kong.
Under the streamlined measures, these UCITS funds are no longer required to seek the SFC’s prior approval for certain post-authorization changes that have already been approved by their home state regulator, including:
- changes to key operators (depositary and investment delegates);
- material changes to investment objectives, policies, and restrictions (except for novel or complex product features), and;
- post-authorization notifications, in line with home jurisdiction requirements.
The SFC will continue to carry out post-vetting of scheme changes, including those not subject to prior SFC approval. This will also include the related revised documents filed with the SFC. The SFC may raise follow-up enquiries and/or take appropriate regulatory action in cases of non-compliance to safeguard investor protection.
In the context of this new circular, UCITS funds refer to:
- Undertakings for Collective Investment in Transferable Securities (UCITS) domiciled in France, Luxembourg, Ireland and the Netherlands, and;
- Collective investment schemes domiciled in the United Kingdom and authorized as UK UCITS.
The SFC acknowledges that these UCITS funds are subject to a robust regulatory framework in their home jurisdictions that provides comparable investor protection standards to those in Hong Kong.
The SFC anticipates a 50% drop in scheme change applications under the new framework.
Further details are available in the SFC circular and in the related FAQ.
