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Critical Infrastructure Law

What Is the New Critical Infrastructure Law, and Why Should You Care?

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On January 1, 2026, Hong Kong will begin enforcing one of its most significant cybersecurity regulations to date: the Protection of Critical Infrastructures (Computer Systems) Ordinance. 

Commonly referred to as the Critical Infrastructure Law (CIL), this legislation marks a transformative moment in how cybersecurity is governed in sectors that keep a nation up and running. Whether your organisation is based in Hong Kong or you operate remotely, if it supports critical infrastructure, this law reshapes your responsibilities, technology stack, reporting obligations, and overall cyber risk posture.

This blog explains what CIL is, who it affects, and how your organisation can prepare, both in Hong Kong and in future expansion zones like Singapore, Malaysia, and beyond.

What Is the Critical Infrastructure Law?

The Hong Kong government passed this ordinance to enhance the protection of computer systems that support critical infrastructure operations. 

These systems encompass vital public services and key economic sectors, including healthcare, transportation, finance, telecommunications, and energy.

CIL mandates that all entities operating in these sectors must:

  • Implement stringent cybersecurity controls
  • Continuously monitor their security posture
  • Be capable of rapid incident response
  • Report annually on their compliance via a Statement of Assurance (SoA)

Who Does It Affect?

This regulation applies to any organisation identified as supporting critical infrastructure in Hong Kong:

  • Local service providers and utility operators
  • Multinational companies with subsidiaries or operations in the country
  • Cloud, cybersecurity, and IT vendors supporting critical systems
  • Foreign entities delivering services into Hong Kong remotely

If your organisation plays any role in ensuring the integrity or uptime of public systems, you’re likely subject to this law, and similar regulations are expected to emerge across the APAC region.

Why Was It Introduced?

The rise of sophisticated cyberattacks, especially those targeting national infrastructure, has forced governments to rethink digital security. 

As a major financial and technological hub, Hong Kong faces a heightened risk.

This law aims to:

  • Standardise cybersecurity protocols across critical sectors
  • Provide real-time reporting to regulators
  • Prevent disruptive, large-scale attacks
  • Align Hong Kong’s practices with global frameworks like NIST and ISO/IEC 27001

Core Requirements of CIL

The CIL regulation is not just about patching software in your organisation. It is about governance, accountability, and resilience.

Key mandates include:

  1. Appointing a responsible officer (e.g., CIO): A senior-level executive must be designated to lead compliance efforts.

  2. Annual statement of assurance (SoA): An annual audit of cybersecurity posture and controls must be submitted.

  3. Defined incident reporting protocols: Serious incidents must be reported within a stipulated timeframe.

  4. Continuous risk management: Ongoing frameworks for risk detection, mitigation, and resolution are required.

  5. Evidence documentation and retention: Logs, assessments, and audit trails must be maintained for inspection.

  6. Real-time monitoring & response: Proactive security systems must be in place for early threat detection.

Penalties for Non-Compliance

Failing to comply with CIL requirements may result in:

  • Heavy fines and sanctions
  • License revocations
  • Forced IT shutdowns
  • Legal exposure
  • Loss of stakeholder trust

Real-World Challenges

Key barriers to meeting these requirements include:

  • Limited internal expertise
  • Fragmented technology environments
  • Siloed operations across teams or vendors
  • Difficulty scaling manual reporting workflows
  • Burden on fractional CISOs and service providers

How to Prepare Today

1. Map Your Systems That Fall Under Critical Infrastructure

Start by identifying the systems, processes, and departments that support critical infrastructure services. These may include:

  • Operational technology (OT) systems
  • Network infrastructure
  • Core IT systems that support essential services (e.g., financial transactions, power distribution, public transport, telecom switching)
  • Third-party integrations or vendor systems

2. Appoint a Compliance Lead (Typically a CIO or CISO)

It is required that each organisation designate a responsible officer, often a Chief Information Officer (CIO) or Chief Information Security Officer (CISO), to oversee compliance efforts.

This person will be responsible for:

  • Coordinating compliance strategy
  • Approving annual Statements of Assurance (SoA)
  • Communicating with regulatory bodies
  • Leading incident response protocols

3. Perform a Gap Analysis  

Use the ordinance’s framework (and any available HK Security Bureau guidelines) to conduct a comprehensive gap assessment. This should include:

  • Policies and procedures review
  • Current incident response capabilities
  • Access controls and data governance
  • Monitoring, logging, and alerting systems
  • Historical audit data and reporting workflows

  1.  Centralise Documentation for Risk and Incident Management

Maintain audit logs, risk records, SoAs, and training documents in a secure, centralised repository. That means you need to securely store and manage:

  • Risk assessments
  • Incident response logs
  • Internal audit reports
  • Staff training records
  • Security control evaluations
  • SoA drafts and final versions

Use a centralised, secure repository (preferably with role-based access) that allows easy retrieval for audits or reporting deadlines.

5. Train Key Staff Based on Roles and Responsibilities

Effective compliance requires more than technology; it needs a culture of awareness and accountability.

Create training plans tailored to specific roles:

  1. Executives and Board: Compliance overview, governance responsibilities
  2. IT & Security Teams: Incident handling, system controls, SoA prep
  3. Department Heads: Risk awareness, reporting lines
  4. All Staff: Data handling, phishing awareness, reporting suspicious activity

6. Explore Automated Tools That Support Ongoing Readiness

Manual compliance processes don’t scale. Look for tools that help you:

  1. Track tasks and deadlines
  2. Auto-generate statutory reports and SoAs
  3. Monitor compliance status across teams
  4. Store and sync evidence securely

The Role of Technology in Compliance

Manual methods, like spreadsheets, shared drives, and reactive communication, simply won’t scale. Organisations need:

  • A secure compliance platform
  • Automated task tracking and reminders
  • Real-time readiness dashboards
  • Built-in templates for SoA generation
  • AI-powered tools for evidence collection and reporting

Our End-to-End Compliance Suite for CIL

We don’t just offer one product. We offer a comprehensive, bundled solution designed for full CIL readiness, scalability, and peace of mind:

ComplyNexus Platform

  • Pre-built templates for Statements of Assurance
  • Real-time dashboards
  • AI-powered document generation
  • Centralised evidence storage
  • Instant alerts & reporting tools

Fractional CISO Services

For companies without in-house cybersecurity leadership, our fractional CISO offering gives you:

  • A dedicated, experienced executive
  • Oversight of risk, strategy, and reporting
  • Liaison with regulators
  • Strategic planning

CIL-Focused Cybersecurity Consulting

Our consulting teams help with:

  • Gap analysis
  • Policy and procedure design
  • Incident response planning
  • Risk assessments and internal audits

Penetration Testing & Threat Simulation

We simulate real-world attacks to:

  • Expose vulnerabilities
  • Assess incident readiness
  • Validate security controls

Offline Deployment of ComplyNexus (Coming Soon)

We’re working on a local/offline version of ComplyNexus for organisations that require complete air-gapped solutions. (Contact us for roadmap access.)

Expanding Beyond Hong Kong

While this law is currently enforced in Hong Kong, similar critical infrastructure laws are expected in other jurisdictions across Asia. 

ComplyNexus and its bundled offerings are built to scale with this regulatory trend, offering a future-ready platform across other countries, including Singapore, Malaysia, and many more.

Built for Hong Kong. Ready for APAC.

As a Hong Kong-based company, we understand local regulatory expectations and offer:

  • Local data residency
  • In-region compliance expertise
  • Virtual compliance desks for foreign entities
  • Scalable solutions for Singapore, Malaysia, and other expanding APAC markets

Preparing for CIL isn’t a one-week job, it takes time to assess, build, and operationalise your compliance program. By starting now, you avoid last-minute scrambles and stay ahead of enforcement deadlines.

Book a Free Demo or Consultation

See how our bundled solutions simplify Critical Infrastructure compliance.

Ready to start your compliance journey? Book a free demo with ComplyNexus and discover how we make end-to-end Critical Infrastructure compliance effortless. 

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