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HKISPA's response to Consultation Paper on Cyber-Dependent Crimes and Jurisdictional Issues

HKISPA filed its submission in response to Consultation Paper on Cyber-Dependent Crimes and Jurisdictional Issues.

 (i) On “possession of ransomware or viruses”, the HKISPA strongly requests further clarity on “reasonable excuse”, and recommends amendments to require actual criminal acts as conditions for conviction rather than simply by mere possession.

(ii) On “intentional interference”, HKISPA requests that ISPs be explicitly exempted, unless dishonest or criminal acts were found.

(iii) On “interception”, HKISPA requests that ISPs should be explicitly exempted, unless dishonest or criminal acts were found.

(iv) We also suggest a framework to qualify what is legitimate “cyber security operations/purposes”.

Full document


HKISPA's comments on the Draft Code of Practice Pursuant to Section 88I of the Copyright Ordinance (Cap. 528))

26 Sep 2022

HKISPA provided comments on the Draft Code of Practice pursuant to Section 88I of the Copyright Ordinance (Cap. 528)) prepared by the Intelletual Property Department. Please click links below for the relevent documents.

HKISPA's comments to the Draft Code of Practice


Reference: Copyright (Amendment) Bill 2022

Reference: Draft Code of Practice (March 2012)

HKISPA Responds to Secretary for Justice on Interim Injunction

Today, HKISPA has written to Secretary for Justice, spelling out concerns of Internet Service Providers about the Interim Injunction, and demand that Operators who act only as a conduit for data transmission be exempted from liability.


Letter (English Only)


Urgent Statement of HKISPA on Selective Blocking of Internet Services

To: The Executive Council, HKSAR

28 August 2019

Urgent Statement of HKISPA on Selective Blocking of Internet Services

News media reported today that the government has plans to impose executive orders on Internet Service Providers to selectively stop some Internet applications.

The HKISPA therefore would like to issue this urgent statement.

Technically speaking, given the complexity of the modern Internet including technologies like VPN, cloud and cryptographies, it is impossible to effectively and meaningfully block any services, unless we put the whole Internet of Hong Kong behind large scale surveillance firewall.

By the above token, HKISPA would like to warn that, imposing any insensible restrictions on the open Internet would only result in more restrictions, as the original restrictions wouldn’t be effective, and ultimately the result is putting Hong Kong’s Internet behind a big firewall. Therefore, any such restrictions, however slight originally, would start the end of the open Internet of Hong Kong, and would immediately and permanently deter international businesses from positing their businesses and investments in Hong Kong.

It is very worth noting that such restrictions, which would cost the society huge business opportunities and social costs, would not deter nor stop determined users from accessing their desired services. They can still access these services through numerous VPN services available on the Internet, until we finally put the whole Hong Kong behind a large scale surveillance firewall.

The lifeline of Hong Kong’s Internet industry relies in large part on the open network. Hong Kong is the largest core node of Asia’s optical fiber network and hosts the biggest Internet exchange in the region, and it is now home to 100+ data centers operated by local and International companies, and it transits 80%+ of traffic for mainland China. All these successes rely on the openness of Hong Kong’s network. Such restrictions imposed by executive orders would completely ruin the uniqueness and value of Hong Kong as a telecommunications hub, a pillar of success as an international financial centre.

ISPs in Hong Kong are all law abiding, but they may not circumvent technical and financial constraints of the business which may make executive orders to impose network restrictions not easily implementable. We request that the government consult the industry in resolving these constraints, and consult the society at large before imposing any such restrictions.

Therefore, the HKISPA strongly opposes selective blocking of Internet Services without consensus of the community.


Hong Kong Internet Service Providers Association
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The open network policy of Hong Kong has attracted 18 international cable systems to have landed or going to land in HKSAR. This made HK a telecommunications hub, benefiting mainland China directly. Reducing the attraction of HK as a telecommunications hub will hurt HK as well as mainland China.

Internet applications are in itself productive and has its own legitimate use. When we attempt to block one application, its users will shift to another application, which in turn we may have to block. The chase will never end, the users will still be able to communicate, but the open network of HK will be sacrificed along the way. For instance, if we block telegram, we may have to block whatsapp later, and Facebook later. The users will still find their means to communicate, until we put the whole Hong Kong in totality behind firewall.

Hong Kong recently loss 1+ Billion of initial investments as Facebook and its Libra blockchain venture decided not to choose HK but a more accomodating Singapore as landing point. Network censorship will only accelerate the loss of HK to competing cities.

- ENDS -



HKISPA's response to Public Consultation on the Review of the Telecommunications Regulatory Framework

HKISPA 回應 "電訊規管架構檢討第二階段公眾諮詢" 提出了以下的意見。

1. 支持5G及物聯網裝置的電訊功能應由《電訊條例》規管;但要求規管不應窒礙市場,裝置入口及發售無需送檢。 

2. 支持提高保護地下電訊基建設施的刑事罰則;但要求釐清工程的法律責任人,避免前線工人負上不合理的刑責。 

3. 支持簡化發出非傳送者牌照;要求機制容許業界主動提出申請任何牌照,通訊管理局的決定及原因要公開透明,以及提供上訴機制。

4. 支持通訊管理局提供額外上訴機制;要求機制容許任何人包括公眾就通訊事務管理局的決定提出上訴。

5. 要求全面檢視電訊規管法例,刪除過時及不必要的要求。

6. 要求檢討電訊規管法例有關建築物准入的機制,現時的條文不清晰。

7. 另外就 "保護地下電訊基建設施" 的罰則提高,考慮建立地下電訊基建設施共用資料庫,方便電訊工程進行。

HKISPA's response to Public Consultation on the Review of the Telecommunications Regulatory Framework [ PDF ]

Special Interest Groups

Hong Kong Network Operators Group

16 August 2018

HKNOG is now an Special Interest Group of HKISPA

HKNOG was formed in 2013, and is a platform for network operators having presence in Hong Kong to exchange technical and operational knowledge and information. HKNOG has been an operating partner of HKISPA since its establishment, and have become an SIG of HKISPA on 16 August 2018.

For details of HKNOG and for future participation to events, please visit www.hknog.net.