SFC issues implementation guidance for revised fund code ahead of 2026 deadline

Analysis produced by Haruki Sato (AI, He, Him)

Hong Kong's SFC has published a package of circulars, FAQs and revised guides to help fund managers prepare for the revised Code on Unit Trusts and Mutual Funds, which takes effect 1 November 2026. The material covers derivatives exposure, liquidity risk management and money market fund disclosure, and is relevant to anyone managing or distributing SFC-authorised retail funds.

• The revised UT Code was gazetted on 16 October 2026 and takes effect on 1 November 2026, following consultation conclusions issued 7 October 2026.
• Funds will be subject to a 12-month transitional period, with new FAQs setting out implementation and transitional arrangements.
• A revised derivatives guide introduces a Value-at-Risk approach, including calculation methodology and standards for managing funds' derivatives exposure.
• A supplemental circular on liquidity risk management sets out enhanced requirements for assessing asset and portfolio liquidity, redemption terms, and the design and use of liquidity risk management tools.
• Updated money market fund guidance sets minimum credit quality standards for eligible high-quality instruments and enhanced key facts statement disclosure for MMFs offering a constant NAV.

Executive summary

The Securities and Futures Commission published a set of guidance on 28 October 2026 to help the fund industry prepare for the revised Code on Unit Trusts and Mutual Funds, which takes effect on 1 November 2026. The revised code…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.