On 28 November 2025, the Securities and Futures Commission (SFC) published a circular (Circular) and announced various streamlined measures (UCITS Streamlined Measures) for post-authorisation matters for SFC-authorised UCITS funds which took effect on the same day.
Upon implementation of the UCITS Streamlined Measures, the SFC’s prior approval will no longer be required for a number of scheme changes which comply with the UCITS fund’s home jurisdiction requirements. The notice period and content requirements of such scheme changes will generally follow that of the home regulator, save for certain circumstances specified in the Circular. For details of the UCITS Streamlined Measures, please see our Newsletter of 30 December 2025.
However, in respect of certain material scheme changes, and in order to ensure Hong Kong investors are provided with adequate information to make an informed investment decision, the SFC would (in practice) expect the management company to issue a notice to affected Hong Kong investors, even though such notification is not required in the home jurisdiction. For example, if the investment delegation arrangement is disclosed in the Hong Kong offering document of an SFC-authorised UCITS fund in compliance with Appendix C3(c) to the Code on Unit Trusts and Mutual Funds (UT Code), where such information is not covered in the overseas offering document, the SFC would still prefer a notice to be issued to Hong Kong investors in respect of the changes to the investment delegation (although the home regulator does not require issuing a notice to investors).
The SFC will conduct post-vetting of notices issued to Hong Kong investors to monitor compliance with the UT Code, and may require management companies to issue supplemental notices on a case-by-case basis. In case of doubt, early consultation with the SFC on the Hong Kong investors notification requirements is recommended to ensure a smooth implementation of material scheme changes.
