From Connector to Issuer: Positioning Hong Kong as a Green Sukuk Platform under the First Five-year Plan (2026-2030)

Hong Kong built a complete legal and tax framework for sukuk more than a decade ago, and its <br> government issued three US dollar sukuk between 2014 and 2017. Yet no Hong Kong-listed <br> enterprise has issued a sukuk from Hong Kong, and the market has stayed dormant. This paper <br> argues that conditions have now changed in a way that earlier studies could not anticipate. <br> Global sukuk issuance reached a record US$264.8 billion in 2025, and outstanding ESG sukuk are <br> expected to exceed US$70 billion by the end of 2026. Hong Kong has meanwhile assembled a <br> green finance infrastructure that no Islamic finance centre matches: a sustainable finance <br> taxonomy extended to transition activities in January 2026, subsidy schemes for green and digital <br> bond issuance, and three sovereign tokenised green bonds, the latest a record HK$10 billion issue. <br> The paper examines Hong Kong's green sukuk opportunity through the lens of the First Five-Year <br> Plan for Economic and Social Development (2026–2030), whose consultation document promotes <br> green finance and Middle East engagement but does not mention Islamic finance. It identifies three <br> differentiators for Hong Kong: a common law system suited to the true-sale requirement of the <br> forthcoming AAOIFI Shariah Standard No. 62, proven tokenisation infrastructure, and the <br> offshore renminbi market. It then sets out a practical issuance playbook for Hong Kong-listed <br> enterprises and assesses the implications for the Hong Kong banking industry. <br> The paper argues that the convergence of regulatory reform, digital bond infrastructure, growing <br> Gulf connectivity and the First Five-Year Plan creates a policy window that did not previously <br> exist. It concludes with policy recommendations framed as a contribution to the Five-Year Plan <br> consultation.