HKEX's mandatory network tests: two August Saturdays you can't skip
Welcome back. One thing that matters, the rest in a line each, and one review worth retelling. Five minutes, every Monday. This issue covers the week of 20–26 July 2026 — a quiet week for enforcement, but a busy one for funds and a hard deadline for anyone plugged into HKEX.
HKEX's backbone upgrade brings mandatory test sessions — the first is 8 August
On Monday the SFC issued Circular 26EC44, setting out the schedule for HKEX’s Post Release Tests (PRTs) ahead of the phased rollout of its upgraded backbone network for the securities market systems. The tests exist so firms can prove their connectivity before each phase goes into production — and for some firms, showing up is not optional.
- Who's in scope: Exchange Participants and China Connect Exchange Participants must take part in PRT 1 and PRT 2. Other Relevant Regulated Intermediaries that use the SFTP channel to submit BCAN-CID Mapping Files and Reporting Forms under the Hong Kong Investor Identification Regime are invited and may join voluntarily.
- What to do: book the sessions, and confirm whoever owns your HKEX SFTP connectivity will actually run the test — not just plan to.
- By when: PRT 1 is Saturday 8 August, PRT 2 is Saturday 22 August (both mandatory for EPs); PRT 3 on Saturday 5 September is optional. Refer to HKEX’s own circular dated 21 July 2026 for the logistics.
- ProductsThe SFC published an updated framework for authorising listed structured funds (Circular 26EC43), covering leveraged and inverse products and a new Defined Outcome Listed Structured Funds category, and superseding its May 2020 L&I circulars — read it before you plan any such product.
- ProductsA new SFC–Securities Commission Malaysia MoU dated 23 July expands mutual recognition of funds to Malaysian funds (26EC37) and Malaysian REITs (26EC38) — a wider recognised-fund shelf if you distribute to HK retail.
- OTC derivativesEnrolment closes today (27 July) for the SFC's OTC derivatives regime webinar on 14 August (26EC41) — worth a seat if the new OTCD licensing regime could reach your activities.
A 76% jump in fund sales, and the review that followed
Not a fine this week, so a review to keep on your radar: in September 2025 the SFC and HKMA launched a concurrent thematic review of how intermediaries distribute non-exchange traded investment products (Circular 25EC48), after their 2024 joint survey showed collective investment scheme (CIS) sales rose 76% year on year. The review examines selected firms’ policies, systems, controls and management oversight — and, centrally, their compliance with the suitability requirement under the Code of Conduct: product due diligence, suitability assessments, and the information given to clients.
The control that keeps you out of the findings: make product due diligence and each suitability assessment a documented step, not a conversation. If a fund is on your shelf, keep a dated due-diligence file; for every recommendation, record why it suited that client’s circumstances. When the findings land, “we did it but didn’t write it down” reads the same as “we didn’t do it.”
That's issue two. Forward it to the RO who runs compliance solo. See you next Monday.
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