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Revisions to the Banking (Disclosure) Rules and independent review requirements

The Hong Kong Banking (Disclosure) Rules (BDR) have undergone significant revision, and the Hong Kong Monetary Authority (HKMA) has implemented a number of enhancements and updates to the disclosure requirements and disclosure templates. The BDR has introduced several key changes to align with international standards and enhance transparency in the banking sector.

In addition to the BDR, HKMA also published a revised version of the Supervisory Policy Manual (SPM) module CA-D-1 “Guideline on the Application of the Banking (Disclosure) Rules” to provide guidance on the interpretations of certain provisions of the BDR.

Key enhancements along with the revised SPM module CA-D-1, effective from 1 January 2025, encompass:

  • Requirements on definition and determination of “materiality”
  • Alignment with the Basel III Reforms final package and corresponding revisions to the Banking (Capital) Rules
  • Review and approval requirements for a dedicated disclosure policy

Independent review requirements

The HKMA and BDR mandate that Pillar 3 disclosures undergo mandatory independent verification before publication to ensure accuracy and regulatory compliance. The verification must be conducted by suitably qualified personnel who are operationally independent from the staff or management responsible for preparing the disclosed information. The verification encompasses a comprehensive review of disclosure content against regulatory requirements and the bank's actual risk profile.

Banks are required to maintain a record of verification for potential inspection by the HKMA or the bank's internal audit function.

Download our latest publication on the Pillar 3 Disclosures