From RMB Counters to T+1: Four Market-Infrastructure Tracks in the SFC Action Plan

1. RMB counters: a short-term measure with details still to come

The plan lists the introduction of RMB trading counters for southbound Stock Connect as a short-term measure. Its medium- to long-term direction includes widening the range of products denominated, traded and settled in RMB and developing more RMB hedging instruments.

This could extend the role of the renminbi in Hong Kong from product denomination to a broader trading, settlement and risk-management workflow. The plan, however, does not specify eligible securities, a launch date, investor procedures or foreign-exchange arrangements. A stated direction should not be described as an operating service.

Families holding Hong Kong equities and RMB assets can start by checking whether their trading and custody platforms support multiple currency counters, who controls cash accounts and hedging mandates, and how costs and liquidity would be compared across counters for the same security.

2. T+1: faster settlement shortens the funding window

Hong Kong’s cash equities market generally settles on T+2. In April 2026, HKEX consulted on moving to T+1 and indicated the fourth quarter of 2027 as a possible implementation window, subject to market readiness and regulatory approval. The new SFC plan places implementation of T+1 among its short-term measures; it does not turn that indicative window into a confirmed effective date.

T+1 means more than receiving securities or cash sooner. It reduces the time available for foreign-exchange conversion, cross-time-zone funding, securities lending and trade matching. Where funding moves through overseas banks, trusts or layered holding structures, operational cut-offs may become binding before the investment decision itself does.

Family offices should ask brokers, custodians and FX banks how funding deadlines may change, who handles mismatches, how much liquidity is needed when holiday calendars diverge and whether current mandates and exception procedures can support T+1.

3. Uncertificated securities: this initiative has a firm date

Hong Kong’s uncertificated securities market regime will start on 16 November 2026. Its initial scope covers only prescribed securities constituted under the laws of Hong Kong, Bermuda, the Cayman Islands or Mainland China. Within that scope, newly listed issuers must use uncertificated form from listing, while existing issuers must join in phases over five years. Securities constituted elsewhere may still depend on changes to overseas law.

The regime will allow investors to hold and manage securities electronically in their own names and exercise shareholder rights directly. The existing nominee structure in CCASS will remain, so holding models will coexist and investors will not all move on the same day.

Families holding listed securities through companies, trusts or private investment vehicles should review the legal holder name, corporate-action notices, voting arrangements, beneficial-owner records, registrar accounts and custody agreements. Treating dematerialisation as the removal of paper alone would miss changes in the exercise of rights and record-keeping responsibilities.

4. Fixed-income and currency platform: a clear direction, with market design to follow

The plan lists establishing a fixed-income and currency trading platform with HKEX and relevant stakeholders as a short-term measure. Longer-term directions include standards for issuing and trading fixed-income products and consideration of a central counterparty for repo clearing.

These measures point toward broader bond, currency and collateral infrastructure, but the document does not specify a launch date, products, participant eligibility, quote model or fees. The accurate description today is that the regulator has set a direction, not that a completed new platform is available to all investors.

For family portfolios, the eventual questions are market depth, trade transparency, eligible collateral, repo-financing efficiency and custody connectivity. Any new tool should still be assessed within the family’s investment policy, liquidity needs and counterparty-risk framework.

Four checks for family offices

1. Obtain T+1 and uncertificated-securities readiness plans from brokers and custodians.

2. Map RMB, Hong Kong dollar and US dollar cash accounts, FX mandates and cross-time-zone payment cut-offs.

3. Confirm who maintains legal-holder and beneficial-owner records for listed securities held through companies, trusts and funds.

4. Record strategic plans, consultation proposals and rules already in force separately, so unconfirmed functionality is not used to plan trades or funding.

Important notice

This article is for general information and education only. It does not constitute investment, legal, tax or regulated advice. Policy direction, indicative timing and rules in force are different categories; readers should verify their own arrangements with licensed institutions and professional advisers.