Digital infrastructure is often pictured as fiber, data centers, and computing power. That definition is already outdated. Modern trade also depends on digital identity, electronic documents, secure payments, cybersecurity, enforceable contracts, and people who can operate the system locally. Digital infrastructure is no longer just hardware; it is the operating system of trade.
This operating system has four connected layers: connectivity, transactions, trust, and adoption. Cables and cloud services connect machines; digital documents and payments move value; governance makes risks intelligible; local skills turn installed capacity into lasting productivity. If any layer is missing, a project may be technically impressive yet commercially fragile.
China has built a broad foundation for the Digital Silk Road. By the end of 2022, it had signed memorandums of understanding on Digital Silk Road cooperation with 17 countries. The next test is therefore not simply how much infrastructure can be delivered, but whether projects remain locally appropriate, financially viable, and trusted throughout their life cycle. This is where the Hong Kong Special Administrative Region can make a contribution that is difficult to replace.
The city had useful physical foundations, including 13 submarine cable systems and 10 cable landing stations as of July. Its more distinctive asset, however, is institutional. The Protection of Critical Infrastructures (Computer Systems) Ordinance took effect in January. Its code of practice refers operators to recognized risk-management methodologies spanning GB/T 31722, ISO/IEC 27005 and IEC 62443-3-2 — all key international security standards. That combination matters: Hong Kong can translate between national and international technical languages rather than force every partner into one template.
But trust cannot be created by simply branding Hong Kong a hub. It must be demonstrated. Partner economies may require data to remain locally stored. Financiers will examine cyber resilience, contractual enforceability, and dependence on a single vendor. Procurement may also be constrained by competing standards and technology export controls. So Hong Kong’s role should not be to insist on hosting every dataset or supplying every component. It should be to make the architecture auditable, the responsibilities clear, and the exit options workable wherever the infrastructure is located.
That is the real meaning of a “trust layer”. A project becomes investable only when lenders and insurers can price its operational, cyber, and legal risks. It becomes governable only when the parties know who controls the data, how an artificial-intelligence decision can be challenged, and what happens when a supplier fails or withdraws. It becomes sustainable only when local engineers can maintain and improve it.
Hong Kong already possesses parts of this architecture. The Standard Contract for Cross-Boundary Flow of Personal Information within the Guangdong-Hong Kong-Macao Greater Bay Area is voluntary and applies to personal information rather than all industrial data, so it is not a universal template. Its method is nevertheless valuable: Define responsibilities contractually, establish safeguards, file the arrangement, and improve it through practical use. The same logic can support project-specific trusted data corridors that respect each partner’s laws and data-residency requirements.
The city should connect these capabilities rather than create another institution. The Hong Kong Monetary Authority’s (HKMA) Infrastructure Financing Facilitation Office already promotes infrastructure investment, financing, and capacity building, and has issued a Reference Term Sheet for Non-Recourse Infrastructure Loans in Emerging Markets. A digital annex could add provisions on data ownership, cyber resilience, AI accountability, open interfaces, service continuity, local training, and supplier exit. The Digital Policy Office, insurers, technology providers, host-economy partners, the Hong Kong International Arbitration Centre and eBRAM — the online dispute resolution institution based in Central — could contribute their respective expertise. Hong Kong awards are enforceable in more than 170 New York Convention jurisdictions and, separately, on the Chinese mainland under a reciprocal-enforcement arrangement.
The second priority is electronic trade law. In June, the HKSAR government briefed the Legislative Council on proposed amendments to the Electronic Transactions Ordinance aligned with the United Nations Commission on International Trade Law Model Law on Electronic Transferable Records (MLETR). Thirteen jurisdictions have already enacted MLETR-modeled legislation, including some of Hong Kong’s key trading partners. The government plans to introduce the amendment bill within 2026. HKMA research published in March 2025 estimates net savings of up to HK$34.9 billion ($4.45 billion) for the trading community over the next decade if digitalization reaches industry targets.
Hong Kong is not starting from zero. In the Project Ensemble Sandbox, banks and technology participants completed settlement of electronic bill-of-lading transactions using tokenized deposits, with the Global Shipping Business Network (GSBN) participating. The GSBN is incorporated in Hong Kong and structured as an independent, not-for-profit consortium owned by major carriers and terminal operators, including Hapag-Lloyd, Hutchison Ports and PSA International. This was a sandbox demonstration, not yet mass-market infrastructure, but it shows that the legal, financial and technical components can be assembled here.
These capabilities should now be tested through two 24-month demonstration projects: a port-community system in Southeast Asia and an electronic trade-document corridor with Bahrain, the first state to enact MLETR. Both should embed local engineers and require documented procedures, local-language support, open interfaces, and credible supplier-switching plans. Otherwise, connectivity is purchased while dependence is preserved. Progress should be measured by time to financial close, document-processing cost, system uptime, local staff trained, and the ability to change vendors without losing data or continuity.
Financing must also fit the economics of digital infrastructure. Networks and data facilities require substantial upfront investment, while revenue may emerge gradually and in local currency, creating maturity and foreign-exchange mismatches that conventional loans may not comfortably absorb. Hong Kong can structure blended packages combining commercial lending, development finance, export-credit support, and insurance, while linking pricing to resilience, energy efficiency and local capability. Done properly, the trust layer lowers uncertainty and expands the pool of investable projects.
Hong Kong does not need to manufacture every component or host every platform. Its higher-value role is to make projects investable, systems interoperable and partnerships accountable. If the city turns its laws, finance, digital capabilities, and professional services into repeatable project standards, it will earn — rather than merely claim — the role of super value-adder to the Digital Silk Road.
The author is founding chairman of the Hong Kong Innovative Technology Development Association.
The views do not necessarily reflect those of China Daily.
