The Guangdong-Hong Kong-Macao Greater Bay Area stands as one of China’s most visionary undertakings in integrated regional development, embodying an unprecedented fusion of legal traditions and economic collaboration.
Unlike conventional free trade zones or customs unions, the Greater Bay Area flourishes under the distinctive “one country, two systems, three legal jurisdictions” framework, encompassing Hong Kong’s common law tradition, Macao’s Portuguese-influenced civil law system, and Chinese mainland’s legal system. This arrangement is not a mere administrative convenience but a carefully nurtured ecosystem designed to harness the comparative strengths of each jurisdiction. Doing so cultivates an environment where cross-border commerce, technological innovation, and governance reforms thrive in perfect harmony, reinforcing China’s commitment to regional integration through the rule of law and mutual respect.
At the heart of the Greater Bay Area’s success lies the intricate task of harmonizing fundamentally divergent legal traditions without eroding their distinct identities. A landmark achievement in this regard is the Arrangement on Reciprocal Recognition and Enforcement of Judgments in Civil and Commercial Matters between the mainland and Hong Kong, signed in 2019 and implemented in 2024 through Hong Kong’s Mainland Judgments in Civil and Commercial Matters (Reciprocal Enforcement) Ordinance (Cap. 645). This arrangement enables courts in both jurisdictions to recognize and enforce each other’s civil and commercial judgments, significantly reducing the need for relitigation and enhancing legal predictability. As a result, businesses operating across the Greater Bay Area now benefit from greater certainty, fostering deeper confidence in the region’s rule of law.
Parallel to legal innovation, financial integration has been vigorously advanced through initiatives such as the Wealth Management Connect Scheme, launched in September 2021. This groundbreaking program allows residents of Hong Kong, Macao, and nine cities in Guangdong province to invest across borders via a closed-loop funds flow system. The Southbound and Northbound Schemes facilitate investment in wealth management products, while joint regulatory oversight from all three jurisdictions ensures a consistent and trustworthy regulatory environment. The program’s enhancement measures, introduced in January 2024, have expanded the range of eligible products, increased investor quotas, and refined eligibility criteria, further strengthening the financial interconnectivity that underpins the Greater Bay Area’s economic vitality.
Institutional innovations have played a pivotal role in accelerating the Greater Bay Area’s integration process, with special economic zones serving as laboratories for legal and regulatory advancements. The Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone exemplifies this spirit, operating under a “Hong Kong standards, Qianhai adoption” model that applies Hong Kong’s commercial laws and arbitration rules within designated areas. Offering preferential policies such as a reduced corporate tax rate of 15 percent and streamlined company registration procedures, Qianhai has successfully attracted a wave of Hong Kong enterprises, illustrating the powerful magnetism of an integrated, innovation-driven economy.
Equally transformative has been the development of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone, which has introduced pioneering reforms in intellectual property rights protection. A pilot program launched in January 2023 allows Hong Kong applicants to request prioritized examinations for patents on the mainland, reducing the typical approval timeline to approximately one year. This initiative has led to a notable surge in joint patent applications between Shenzhen and Hong Kong since 2020. Further reinforcing these efforts, the launch of the National Intellectual Property Operation (Hetao Shenzhen) Transformation Pilot Platform in December 2024 has streamlined the conversion and application of IP assets between the two cities, positioning Hetao as a dynamic center for legal and technological innovation.
Establishing a one-stop dispute resolution center in Qianhai has further exemplified the Greater Bay Area’s commitment to procedural efficiency. By integrating litigation, mediation, and arbitration services from both Hong Kong and the mainland, this center has significantly reduced dispute resolution times, providing a model of seamless cross-border legal cooperation that enhances business confidence and operational fluidity across the region.
Recognizing the intricate nature of cross-border legal interactions, the Greater Bay Area has prioritized alternative dispute resolution mechanisms to bolster efficiency and trust. The Hong Kong International Arbitration Centre has solidified its position as the premier forum for Greater Bay Area-related disputes, offering world-class arbitration services that are internationally respected. Complementing this achievement, the Greater Bay Area Mediation Platform, established in 2022, provides standardized mediation procedures recognized across all three jurisdictions, further enhancing legal predictability and investor confidence.
The Greater Bay Area’s legal architecture transcends regional boundaries and offers a compelling global legal-economic integration model. It demonstrates how distinct legal systems can collaborate harmoniously, preserving their unique characteristics while contributing to a greater collective good. Hong Kong’s participation in the Greater Bay Area fortifies its status as a global legal and financial hub. At the same time, the mainland uses it as a powerful conduit for adopting and disseminating international best practices within a framework that remains firmly aligned with national sovereignty and development goals.
As the Greater Bay Area moves into its next development phase, attention will turn to critical areas such as cross-border data governance, digital currency regulation, and the ethical management of artificial intelligence. The Greater Bay Area’s spirit of innovation and adaptability will be tested anew in these fields. However, given the remarkable strides achieved thus far, there is every reason to believe that the Greater Bay Area will continue to flourish, providing a shining example of China’s ability to lead regional integration through vision, legal sophistication, and unwavering commitment to innovation.
In an era characterized by geopolitical tensions and economic fragmentation, the Greater Bay Area is a beacon of structured collaboration, legal ingenuity, and national pride. It illustrates the profound potential of China’s strategy to foster regional prosperity through the rule of law, technological innovation, and strategic governance. It offers an inspiring model for the world to admire and aspire to emulate.
The author is a solicitor, a Guangdong-Hong Kong-Macao Greater Bay Area lawyer, and a China-appointed attesting officer.
The views do not necessarily reflect those of China Daily.
