What is Hong Kong's Quantum Preparedness Index?

A banking-sector readiness score the Hong Kong Monetary Authority launched alongside its "Whitepaper on Quantum Preparedness of Hong Kong's Banking Sector" on 27 July 2026. It scores the sector across four dimensions -- Awareness, Planning, Pilots, and Practical Preparedness -- on a 10-point scale. The initial sector-wide score was 2.3, with 32% of surveyed banks having not begun preparation at all.

Does Hong Kong have a binding post-quantum cryptography requirement?

No. The HKMA whitepaper is advisory -- its obligations on authorized institutions are consistently phrased "should" or "may," and the foreword describes HKMA's approach as encouraging the industry "to begin early," not requiring it. The one Hong Kong instrument that does use binding "shall" language -- OGCIO's IT Security Guidelines [G3] -- contains no mention of quantum computing or post-quantum cryptography at all.

What does Hong Kong's binding cryptography standard actually require?

RSA-2048 or equivalent. OGCIO's IT Security Guidelines [G3] (version 10.2, April 2025), binding on government bureaux and departments, requires that for CONFIDENTIAL-or-above information, asymmetric encryption "shall be at least 2048-bit for the RSA encryption" or ECC with at least 224-bit keys, with China's SM2 permitted as an alternative. Those are exactly the classical primitives every other jurisdiction on this tracker is planning to retire, and the document has no migration or quantum-risk provision attached.

Does Hong Kong's whitepaper name specific post-quantum algorithms?

No. ML-KEM, ML-DSA, SLH-DSA, XMSS, LMS, and HQC appear only in the appendix glossary as acronym expansions. The document never references FIPS, sets no deprecation date for classical algorithms, and sets no key-size threshold of its own.

By when does HKMA want Hong Kong's banking sector quantum-ready?

2030, aiming for a full QPI score of 10. That's the target HKMA states for the sector as a whole reaching full practical readiness, not a specific compliance deadline tied to a binding rule.

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Hong Kong's Only Binding Cryptography Rule Still Mandates RSA-2048

HKMA's Quantum Preparedness Index puts the banking sector at 2.3 out of 10. The one document that actually says 'shall' -- OGCIO's IT Security Guidelines -- has never mentioned quantum computing at all.

PQC Security EditorialOctober 18, 20264 min read

Hong Kong's banking regulator just told the industry it scores 2.3 out of 10 on quantum readiness. The document the regulator can't point to when asking banks to fix that is the one piece of Hong Kong cryptography regulation that actually uses the word "shall" -- because that document still mandates RSA-2048, and has never once mentioned quantum computing.

A real number, an honest one

The Hong Kong Monetary Authority launched its "Whitepaper on Quantum Preparedness of Hong Kong's Banking Sector" on 27 July 2026, alongside the first Quantum Preparedness Index (QPI) -- a sector-wide score across four dimensions: Awareness, Planning, Pilots, and Practical Preparedness. The initial result: 2.3 out of 10. Thirty-two percent of surveyed banks hadn't begun preparing at all.

HKMA didn't soften that number, and the whitepaper records something more telling than the score itself: one of the industry's own top-three requests, recorded directly in the document, was for "Clear Supervisory Expectations & Timelines" -- banks asking their regulator for rules that don't exist yet.

The document that actually says "shall" has nothing to do with this

Hong Kong's binding cryptography standard isn't the whitepaper. It's OGCIO's (the Digital Policy Office's) "IT Security Guidelines" [G3], mandatory for government bureaux and departments, currently at version 10.2 (April 2025). Its language is unambiguous:

"For information classified as CONFIDENTIAL or above, the symmetric encryption key length shall be at least 128-bit for the AES encryption or equivalent. Subject to operational needs, the requirement can also be met by SM4. Whereas the asymmetric encryption key length shall be at least 2048-bit for the RSA encryption. Alternatively, the requirement can be met by Elliptic Curve Cryptography (ECC) encryption with a key length of at least 224-bit or equivalent, as well as SM2 subject to operational needs."

We checked the full document directly. It contains zero occurrences of "quantum" or "post-quantum." RSA-2048 and ECC-224 -- the exact classical primitives every other jurisdiction on this tracker is actively planning to retire -- remain Hong Kong's binding government minimum, with no migration provision, no sunset date, nothing acknowledging that quantum computing changes the calculus for either algorithm.

That's the gap worth sitting with: Hong Kong's quantum-readiness conversation is real, recent, and measured with an actual score, but it's entirely advisory and confined to banking. The one instrument carrying legal "shall" force hasn't been touched by any of it.

What the whitepaper gets right anyway

To be fair to HKMA, the whitepaper is more substantive than a lot of advisory guidance on this tracker. It names cryptographic inventory directly and specifically:

"A comprehensive cryptographic inventory, sometimes referred to as a CBOM, provides the foundation for assessing exposure, prioritising remediation activities, and tracking transition progress."

One of the QPI's four sub-indices is literally "Cryptographic Discovery and Inventory," and the whitepaper's own recommendations include commissioning one, "accepting that it will be imperfect at first and improve with iteration" -- a realistic, non-punitive framing that's more useful than a regulator demanding perfection out of the gate. The baseline it's measuring against is thin: most surveyed institutions still track cryptography in spreadsheets or have no formal discovery process at all, which the 2.3 score reflects honestly.

What the whitepaper doesn't do is name an algorithm. ML-KEM, ML-DSA, SLH-DSA, XMSS, LMS, and HQC appear only in the appendix glossary, as acronym expansions -- the document never cites FIPS, sets no deprecation date, and specifies no key-size threshold of its own. Its Figure 5 even tabulates government PQC migration deadlines for Canada, the US, Australia, the EU, Singapore, India, the UK, and Germany. Hong Kong isn't a row in its own comparison table.

What to do with this

If you're a Hong Kong-regulated bank, the whitepaper's "should" and "may" language doesn't mean the pressure isn't real -- a supervisor publishing your sector's readiness score at 2.3 and recording your own industry's request for firmer rules is a clear signal about where this is heading, even without a binding deadline yet. Building a real cryptographic inventory now, the thing HKMA explicitly recommends and most institutions still lack, puts you ahead of wherever the eventual binding rule lands rather than scrambling once it does.

If you're a government contractor working against OGCIO's IT Security Guidelines, don't mistake "binding" for "quantum-aware" -- version 10.2 asks for RSA-2048 and says nothing about what happens after a quantum computer can break it.

The Hong Kong country page tracks both documents with their primary sources.

Frequently asked questions

What is Hong Kong's Quantum Preparedness Index?: A banking-sector readiness score the Hong Kong Monetary Authority launched alongside its "Whitepaper on Quantum Preparedness of Hong Kong's Banking Sector" on 27 July 2026. It scores the sector across four dimensions -- Awareness, Planning, Pilots, and Practical Preparedness -- on a 10-point scale. The initial sector-wide score was 2.3, with 32% of surveyed banks having not begun preparation at all.
Does Hong Kong have a binding post-quantum cryptography requirement?: No. The HKMA whitepaper is advisory -- its obligations on authorized institutions are consistently phrased "should" or "may," and the foreword describes HKMA's approach as encouraging the industry "to begin early," not requiring it. The one Hong Kong instrument that does use binding "shall" language -- OGCIO's IT Security Guidelines [G3] -- contains no mention of quantum computing or post-quantum cryptography at all.
What does Hong Kong's binding cryptography standard actually require?: RSA-2048 or equivalent. OGCIO's IT Security Guidelines [G3] (version 10.2, April 2025), binding on government bureaux and departments, requires that for CONFIDENTIAL-or-above information, asymmetric encryption "shall be at least 2048-bit for the RSA encryption" or ECC with at least 224-bit keys, with China's SM2 permitted as an alternative. Those are exactly the classical primitives every other jurisdiction on this tracker is planning to retire, and the document has no migration or quantum-risk provision attached.
Does Hong Kong's whitepaper name specific post-quantum algorithms?: No. ML-KEM, ML-DSA, SLH-DSA, XMSS, LMS, and HQC appear only in the appendix glossary as acronym expansions. The document never references FIPS, sets no deprecation date for classical algorithms, and sets no key-size threshold of its own.
Does the HKMA whitepaper require a cryptographic inventory?: It recommends one explicitly, naming the artifact directly: "a comprehensive cryptographic inventory, sometimes referred to as a CBOM, provides the foundation for assessing exposure, prioritising remediation activities, and tracking transition progress." One of the QPI's four sub-indices is "Cryptographic Discovery and Inventory." This is a real, named recommendation -- just not a binding requirement, and the whitepaper itself notes most surveyed institutions still rely on spreadsheets or have no formal discovery process.
By when does HKMA want Hong Kong's banking sector quantum-ready?: 2030, aiming for a full QPI score of 10. That's the target HKMA states for the sector as a whole reaching full practical readiness, not a specific compliance deadline tied to a binding rule.