HKMA Supervisory Policy Manual — Technology Risk Management (TRM)

Why it Matters

The HKMA TRM framework establishes comprehensive standards to help financial institutions effectively manage technology and cybersecurity risks in Hong Kong’s dynamic environment.

Key benefits include:

• Strengthen technology risk governance

Promote consistent risk management practices and leadership oversight to ensure accountability for technology-related decisions across the institution.

• Enhance regulatory compliance

Align technology controls and reporting with HKMA expectations, reducing the likelihood of compliance breaches and associated penalties.

• Improve operational resilience

Minimize service disruptions and maintain essential banking operations even during technology failures or cyber incidents.

• Increase audit readiness

Document risk management activities and controls to support efficient regulatory audits and facilitate timely compliance reviews.

• Enhance incident response capability

Establish structured protocols for detecting, reporting, and mitigating technology incidents to reduce the impact of potential threats.

How it Works

The HKMA Supervisory Policy Manual — Technology Risk Management (TRM) structures expectations into governance domains and risk management processes, outlining supervisory requirements, control families, and lifecycle safeguards for technology operations. It establishes principles for security controls, third-party management, change management, and incident preparedness, with maturity and accountability embedded in supervisory assessments.

Financial institutions apply TRM by conducting technology risk assessments, mapping security controls to supervisory requirements, and integrating TRM into enterprise governance and compliance programs. Teams implement controls, monitor system security, manage vendor risks, test resilience, perform compliance assessments, and maintain incident response and reporting to meet ongoing regulatory monitoring and supervisory reviews.

In SmartSuite, organizations operationalize TRM by creating control libraries mapped to HKMA requirements, maintaining risk registers, and governing policies with approval and version workflows. SmartSuite supports evidence collection, compliance tracking, remediation workflows, audit readiness, and monitoring dashboards to enable consolidated reporting and continuous improvement of security practices and risk management posture.

Key Elements

• Technology Governance Structure

Describes roles, responsibilities, and oversight mechanisms for managing technology risk within authorized institutions.

• Information Security Controls

Organizes protections for confidentiality, integrity, and availability of systems and data assets.

• Cybersecurity Risk Assessment

Provides requirements for identifying, evaluating, and documenting technology and cybersecurity risks.

• System Integrity Standards

Specifies measures for maintaining the reliability and resilience of critical applications and infrastructure.

• Outsourcing and Third-Party Risk

Establishes controls for managing technology risks arising from external service providers and partners.

• Incident Management Processes

Defines procedures for detecting, reporting, and handling cybersecurity and technology-related incidents.

• Compliance Monitoring and Reporting

Outlines documentation and assurance processes to demonstrate ongoing adherence to regulatory requirements.

Framework Scope

The HKMA Supervisory Policy Manual — Technology Risk Management (TRM) is adopted by banks and authorized financial institutions in Hong Kong to govern information systems, cybersecurity controls, and technology operations. Institutions typically apply this framework when fulfilling regulatory technology risk requirements, supporting audit readiness, and enhancing operational resilience within the financial sector.

Framework Objectives

The HKMA Supervisory Policy Manual — Technology Risk Management (TRM) defines standards for effective technology risk management and cybersecurity in Hong Kong’s banking sector.

Safeguard information assets through robust cybersecurity and security controls

Strengthen governance and oversight of technology risk management practices

Support regulatory compliance with HKMA requirements and global best practices

Enhance operational resilience for authorized institutions against technology disruptions

Improve data protection and privacy to minimize unauthorized access and breaches

Demonstrate audit readiness through effective control documentation and monitoring

Framework in Context

HKMA’s TRM and Operational Resilience guidance complements international standards such as ISO/IEC 27001, NIST Cybersecurity Framework, and DORA by aligning technology risk controls, resilience planning, and incident management. Firms implement TRM for regulatory compliance, strengthening operational resilience, aligning security governance with international frameworks, and supporting audits or certification efforts.

Common Framework Mappings

Organizations commonly map TRM to complementary cybersecurity and resilience standards to streamline controls, demonstrate regulatory alignment, and enable integrated risk management across technology, operational resilience, and assurance programs.

Mapped frameworks include:

CIS Critical Security Controls

Digital Operational Resilience Act (DORA)

ISO/IEC 27001

ISO/IEC 27002

MITRE ATT&CK

NIST Cybersecurity Framework

NIST SP 800-53

SOC 2