Hong Kong advertising rules in 2026
Hong Kong’s Personal Data (Privacy) Ordinance sets one of the strictest direct-marketing consent rules in Asia. Under Part 6A a company must get informed consent before using personal data for direct marketing or passing it to a third party for that purpose, and silence never counts as consent. The rule matters to paid media because customer-list audiences, retargeting by email or phone and offline conversion uploads all rely on personal data. Brands that collect consent correctly can use these tools; brands that do not are exposed.
Executive findings
- 1
Part 6A of the PDPO requires informed consent before personal data is used for direct marketing or transferred to a third party for direct marketing; silence cannot constitute consent.
Documented: official source. Scope: Hong Kong; PCPD overview of the Ordinance, as of . [1]
- 2
The data user must tell the person which kinds of data will be used, the classes of marketing subjects, and that they may opt out.
Documented: official source. Scope: Hong Kong; PCPD overview of the Ordinance, as of . [1]
- 3
Google Ads offline conversion imports let advertisers attribute sales recorded outside the ad platform.
Documented: official source. Scope: Global; Google Ads Help, as of . [2]
- 4
Apple documents privacy-preserving ad attribution for app campaigns.
Documented: official source. Scope: Global; Apple Developer, as of . [3]
Method and limitations
- Question
- What changed in advertising rules and platform options in Hong Kong during 2025 and 2026, and what should an advertiser do about it?
- Written for
- Marketing leads and founders planning paid media in Hong Kong.
- Decision at stake
- Which compliance steps to complete before launch, and which channels deserve a test budget this year.
- Sources
- The PCPD’s overview of the Ordinance, Google’s offline conversion import documentation and Apple’s ad attribution documentation.
- Period
- Official and professional sources as published on 18 October 2026.
- Markets
- Hong Kong, national rules and the platform policies that apply there
- Definitions
- Direct marketing: offering goods or services, or soliciting donations, by sending information or calling specific people using their personal data.
- Limitations
- This briefing is not legal or tax advice. Confirm obligations with qualified local counsel before acting.
- Rules and platform terms change; each source shows the date we read it.
Direct marketing consent under the PDPO
Documented: official source
The 2012 amendments introduced the direct-marketing provisions, and they still govern how brands may use customer data in 2026. Consent must be an explicit indication and covers an indication of no objection, but doing nothing is never enough. Data processors are not regulated directly; the brand must make sure its agencies and platforms handle data in line with the Ordinance through contracts.
What it means for ad audiences
FOCUSADS view
Uploading a customer list to an ad platform to target or exclude people is a use of personal data. Where the list was collected for marketing with proper notice and consent, it can feed customer-match audiences and offline conversion imports. Lists without that basis should stay out of ad platforms. Aggregate measurement, such as platform conversion modelling or Apple’s attribution framework for apps, fills part of the gap.
Opportunities this year
FOCUSADS view
Hong Kong advertisers often run bilingual campaigns in English and Traditional Chinese across Google, Meta and local publishers. A clean consent record is a competitive advantage: it keeps first-party audiences usable and makes measurement more complete. FOCUSADS checks the consent basis of any list before it is used in a Hong Kong plan.
How this connects to our method: How market rules enter the plan
References
- The Personal Data (Privacy) Ordinance, Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD), accessed
- About offline conversion imports, Google Ads Help, accessed
- Ad attribution, Apple Developer, accessed