one country, two systems

{{Infobox Chinese

| image = 厦门市思明区环岛公路景色_-_panoramio_(1).jpg

| caption = Sign in Xiamen reading "{{lang|zh-Hans-CN|一国两制统一中国}}" ({{transliteration|zh|Yīguó liǎngzhì tǒngyī Zhōngguó}}, {{translation|One country, two systems unites China}})

| picsize = 266px

| s = 一国两制

| t = 一國兩制

| p = Yīguó liǎngzhì

| tp = Yi-guó liǎng-jhìh

| w = {{Tone superscript|I1-kuo2 liang3-chih4}}

| mi = {{IPAc-cmn|yi|1|.|g|uo|2|-|l|iang|3|.|zhi|4}}

| bpmf = ㄧㄍㄨㄛˊ ㄌㄧㄤˇ ㄓˋ

| j = jat1 gwok3 loeng5 zai3

| y = Yātgwok léuhngjai

| ci = {{IPAc-yue|j|at|1|-|gw|ok|3|-|l|oeng|5|-|z|ai|3}}

| showflag =

| por = Um país, dois sistemas{{IPA|pt|ũ pɐˈiʒ ˈðojʃ siʃˈtemɐʃ}}

| order = st

}}

"One country, two systems" is a constitutional principle of the People's Republic of China (PRC) describing the governance of the special administrative regions of Hong Kong and Macau.

Deng Xiaoping developed the one country, two systems concept. This constitutional principle was formulated in the early 1980s during negotiations over Hong Kong between China and the United Kingdom. It provided that there would be only one China, but that each region would retain its own economic and administrative system. Under the principle, each of the two regions could continue to have its own governmental system, legal, economic and financial affairs, including trade relations with foreign countries, all of which are independent from those of the mainland. The PRC has also proposed to apply the principle in the unification it aims for with Taiwan.

Background

Deng Xiaoping developed the principle of one country, two systems in relation to Hong Kong, Macau, and Taiwan.{{Cite book |last=Hu |first=Richard |title=Reinventing the Chinese City |date=2023 |publisher=Columbia University Press |isbn=978-0-231-21101-7 |location=New York}}{{Rp|page=176}} Hong Kong and Macau had been colonized by European powers and Taiwan remained under Kuomintang Control at the end of the Chinese Civil War.{{Rp|page=176}}

=In the context of Hong Kong=

Hong Kong was a colony of the United Kingdom, ruled by a governor appointed by the monarch of the United Kingdom, for 156 years from 1841 (except for four years of Japanese occupation during WWII) until 1997, when it was handed over to the Chinese government.

In discussing Hong Kong's future, Deng described the risk of possible instability which might be caused by what he termed as destructive forces both inside and outside Hong Kong.{{Rp|page=177}} In Deng's view, these destructive forces might create instability both prior to, and as well as after, Hong Kong's return to China.{{Rp|page=177}} Deng repeatedly stressed that the central government would need to intervene in Hong Kong affairs from time-to-time.{{Rp|pages=177–178}} Among other occasions, Deng told Hong Kong delegates to Beijing in 1984 that certain interventions would be necessary, that when turmoil occurs in Hong Kong the central government should intervene, and that it would be necessary to see if interventions would be in the interests of Hong Kongers and Hong Kong's stability and prosperity.{{Rp|page=178}} In 1988, Deng stated that Hong Kong's political system was neither the British nor American systems and Hong Kong should not import Western political systems in the future.{{Rp|page=179}}

As part of Hong Kong's return to China, China agreed to accept some conditions, as stipulated in the Sino-British Joint Declaration, such as the drafting and adoption of Hong Kong's "mini-constitution" Basic Law before its return. The Hong Kong Basic Law ensured that Hong Kong will retain its capitalist economic system and own currency (the Hong Kong dollar), legal system, legislative system, and same human rights and freedoms, as a special administrative region (SAR) of China for 50 years. Set to expire in 2047, the current arrangement has permitted Hong Kong to function as its own entity under the name "Hong Kong, China" in many international settings (e.g. the WTO and the Olympics).{{cite web|url=http://gohongkong.about.com/od/travelplanner/a/hongkongcountry.htm|title=What Country Is Hong Kong in? China or Not?|first=Rory|last=Boland|work=About.com Travel|access-date=2 December 2014|archive-url=https://web.archive.org/web/20141009134239/http://gohongkong.about.com/od/travelplanner/a/hongkongcountry.htm|archive-date=9 October 2014|url-status=live}}{{cite news |last=Gargan |first=Edward A. |date=July 1, 1997 |title=China Resumes Control of Hong Kong, Concluding 156 Years of British Rule |work=The New York Times |url=https://www.nytimes.com/1997/07/01/world/china-resumes-control-of-hong-kong-concluding-156-years-of-british-rule.html |url-status=live |url-access=limited |access-date=3 March 2017 |archive-url=https://web.archive.org/web/20160620182610/http://www.nytimes.com/learning/general/onthisday/big/0630.html |archive-date=20 June 2016}}{{Cite news |title=1898 and all that—a brief history of Hong Kong |newspaper=The Economist |url=https://www.economist.com/special/1997/06/26/1898-and-all-that-a-brief-history-of-hong-kong |access-date=2023-06-11 |issn=0013-0613}}

During the drafting of the Basic Law, Deng stated that universal suffrage and Western political systems were not appropriate for Hong Kong.{{Rp|pages=178–179}} Deng also stated that if Hong Kong became a base for anti-mainland China sentiment under the guise of democracy then China's central government should intervene.{{Rp|page=179}}

The Chinese renminbi is not legal tender in Hong Kong. Likewise, the Hong Kong dollar is not accepted in stores in mainland China. With this arrangement, a permit or special visa ({{zh|links=no|c=簽注}}) is required when passing between the borders of Hong Kong and mainland China, and people in Hong Kong hold Hong Kong SAR passports rather than Chinese passports. The official languages are a major factor besides the history of the former colony that has made Hong Kong and mainland China distinct from each other, as Cantonese and English are the most widely used languages in Hong Kong, while Mandarin is the official language of mainland China. The central government in Beijing maintains control over Hong Kong's foreign affairs as well as the legal interpretation of the Basic Law. The latter has led democracy advocates and some Hong Kong residents to argue that the territory has yet to achieve universal suffrage as promised by the Basic Law, leading to mass demonstrations in 2014.

=In the context of Macau=

A colony of Portugal for 442 years from 1557, Macau was returned to the Chinese government in 1999. In the Joint Declaration on the Question of Macau, the drafting and adoption of Macau's mini-constitution before its return was foreseen. Like Hong Kong, a basic law would ensure that Macau retained its economic system, currency (the Macanese pataca), legal system (which is based on Portuguese civil law), legislative system, and people's rights and freedom for 50 years, as a special administrative region (SAR) of China. Set to expire in 2049, the agreement has permitted Macau to function as its own entity in many international settings (e.g. WTO) rather than as a part of China.

As Macau has its own currency, the Chinese renminbi is not legal tender in Macau; the pataca is also not accepted in stores in China.{{cite web |title=人民币是澳门特别行政区的法定货币吗？ |url=https://www.chinanews.com.cn/zhuanti/aomen/lawabc/part6-7.html |website=China News Service |access-date=6 April 2025}} With this agreement, a permit or visa is required when crossing between the borders of Macau and China, and people in Macau generally hold Macau SAR passports rather than mainland Chinese passports. Like Hong Kong, the official languages are a major factor that has made Macau and China distinct from each other besides the history of the former colony, as Cantonese and Portuguese are the official languages in Macau, while Mandarin is the official language of China. The central government in Beijing also maintains control over Macau's foreign affairs as well as the legal interpretation of the Basic Law.

=In the context of Taiwan=

In addition to the Hong Kong and Macau contexts, Deng proposed the principle's applicability to Chinese unification,{{Rp|page=176}} but the government of Taiwan has consistently rejected the proposal {{As of|alt=as recently as December 2023|2023|12}}.{{Cite web |last=Hioe |first=Brian |date=2023-12-22 |title=Lai and Hou Focus on Cross-Strait Relations, Ko on Appeals to Youth in First Presidential Policy Presentation |url=https://newbloommag.net/2023/12/23/2024-first-policy-presentation/ |access-date=2024-01-13 |website=New Bloom Magazine |language=en-US}} According to polls conducted by Taiwan's Mainland Affairs Council in 2025, over 80 percent of Taiwan reject "one country, two systems".{{Cite web |date=2025-04-25 |title=Huge majority of Taiwanese reject 'one country, two systems': Poll |url=https://focustaiwan.tw/cross-strait/202504250008 |access-date=2025-04-25 |website=Focus Taiwan |language=en-US}}

Application to Hong Kong and Macau

{{See also|Sino-British Joint Declaration|Sino-Portuguese Joint Declaration}}

File:Hong SAR office in Beijing.jpg]]

File:HK SYP OCMFAPRC 1.jpg]]

File:Beijing 北京 Macau Center 澳門中心 Mar-2017.jpg]]

File:Liaison Office of the Central People's Government in the Macao SAR.JPG]]

Chinese paramount leader Deng Xiaoping proposed the principle during negotiation with British prime minister Margaret Thatcher over the expiration of the United Kingdom's lease on the New Territories (including New Kowloon) of Hong Kong in 1997. The same principle was proposed in talks with Portugal about Macau.{{cite web |title=中葡两国关于澳门回归时间问题的外交博弈及其历史经验 |url=http://www.hprc.org.cn/gsyj/dfsz/amdds/202206/P020220621348265568704.pdf |website=National History Network |access-date=6 April 2025 |language=zh}}

The principle is that, upon reunification, despite the practice of socialism in mainland China, both Hong Kong and Macau, which were colonies of the United Kingdom and Portugal respectively, could retain their established system under a high degree of autonomy for up to 50 years after reunification. However, what would happen after 2047 and 2049 for Hong Kong and Macau respectively has never been publicly stated.

Chapter 1, Article 5 of the Hong Kong Basic Law, the constitutional document of the Hong Kong Special Administrative Region, reads:{{cite web|url=http://www.basiclaw.gov.hk/en/basiclawtext/chapter_1.html|title=Chapter I : General Principles|publisher=Government of the Hong Kong SAR|date=17 March 2008|access-date=1 November 2009|archive-url=https://web.archive.org/web/20171123110932/http://www.basiclaw.gov.hk/en/basiclawtext/chapter_1.html|archive-date=23 November 2017|url-status=live}}

{{blockquote|The socialist system and policies shall not be practiced in the Hong Kong Special Administrative Region, and the previous capitalist system and way of life shall remain unchanged for 50 years.Luo, Jing. Over A Cup of Tea: An Introduction To Chinese Life And Culture. [2004] (2004). University Press of America China. {{ISBN|0-7618-2937-7}}Wong, Yiu-chung. [2004] (2004). One Country, Two Systems in Crisis: Hong Kong's Transformation. Lexington Books. Hong Kong. {{ISBN|0-7391-0492-6}}.}}

The establishment of these regions, called "special administrative regions" (SARs), is authorised by Article 31 of the Constitution of the People's Republic of China, which states that the state may establish SARs when necessary, and that the systems to be instituted in them shall be prescribed by law enacted by the National People's Congress in light of the specific conditions.{{cite web |title=《“一国两制”在香港特别行政区的实践》白皮书(全文) |url=http://hochiminhcity.china-consulate.gov.cn/xwdt/201406/t20140610_5515908.html |website=Consulate General of the People's Republic of China in Ho Chi Minh City |access-date=6 April 2025 |language=zh |date=10 June 2014}}

The SARs of Hong Kong and Macau were formally established on the 1 July 1997 and the 20 December 1999 respectively, immediately after the People's Republic of China (PRC) assumed sovereignty over these respective regions.{{cite web |title=历史大势不可挡——“一国两制”重要制度为什么完全行得通？ |url=http://www.xinhuanet.com/politics/2020-08/17/c_1126374689.htm |website=Xinhua News Agency |access-date=6 April 2025 |date=17 August 2020}}

=Framework=

The two SARs of Hong Kong and Macau are responsible for their domestic affairs including, but not limited to, the judiciary and courts of final appeal, immigration and customs, public finance, currencies and extradition. The SARs are also exempt from mainland laws mandating the use of simplified characters in publishing and Mandarin in public education and most broadcasting. The diplomatic relations and military defence of the two SARs however, is the responsibility of the Central People's Government in Beijing.{{cite web |title=中国的国防 |url=https://www.gov.cn/zwgk/2005-05/26/content_1107.htm |website=The Central People's Government of the People's Republic of China |access-date=6 April 2025}}

Hong Kong continues using English common law while Macau continues using the Portuguese civil law system.{{cite web |title=論對港澳原有法律的採用 |url=https://www.macaudata.mo/macaubook/book155/html/02601.htm |website=Macau Data |access-date=6 April 2025}}

=Names=

When the two regions have their own membership in international organisations (such as the WTO and the Paralympics), both regions are mandated to use the name "Hong Kong, China" or "Macao, China"{{efn|In practice, Macau sometimes instead uses "Macau, China".{{cite web |title=Sports Olympic Committee of Macau, China |url=http://www.macauolympic.org/ |website=Macau Olympic Committee |access-date=6 April 2025}}}} instead of "Hong Kong" or "Macau"/"Macao", as stipulated several times under Chapter VII ("External Affairs") of both regions' Basic Laws.{{cite web |title=编校工作中如何正确把握涉港澳台用语（下） |url=https://pub.bnu.edu.cn/jzyg1/07faf61fce2c41b0a8ac056d283efcd8.html |website=Beijing Normal University |access-date=6 April 2025 |date=29 December 2023}}

For example, in Trade Policy Review documents between Hong Kong and the WTO, the documents use "Hong Kong, China" throughout even in prose. When a short name is used, it uses the acronym "HKC" and never "Hong Kong" or "HK" standalone.{{cite web |title=Trade Policy Review Body (23-6814) |url=https://www.wto.org/english/tratop_e/tpr_e/s450_e.pdf |website=World Trade Organization |access-date=6 April 2025 |date=11 October 2023}}{{cite web |title=Trade Policy Review Body (23-6781) |url=https://www.wto.org/english/tratop_e/tpr_e/g450_e.pdf |website=World Trade Organization |access-date=6 April 2025 |date=11 October 2023}} Similarly, in Trade Policy Review documents between Macau and the WTO, "Macao, China" is used in prose throughout and the only short name used is the acronym "MSAR".{{cite web |title=Trade Policy Review Body (20-8007) |url=https://www.wto.org/english/tratop_e/tpr_e/g402_e.pdf |website=World Trade Organization |access-date=6 April 2025 |date=10 November 2020}}

= Potential extension =

Several high level members of the government have expressed a potential extension of the system beyond 2047 for Hong Kong. In January 2020, Carrie Lam stated that "My view is this: as long as we persist with the "One Country, Two Systems" principle, push forward the implementation of 'One Country, Two Systems' and have a full understanding and implementation of the principle... then we have adequate reason to believe that 'One Country, Two Systems' will be implemented smoothly and in the long term, and it will not change after 2047."{{Cite web |last=Cheng |first=Kris |date=2020-01-16 |title='One Country, Two Systems' could remain unchanged after 2047, says Hong Kong's Carrie Lam |url=https://hongkongfp.com/2020/01/16/one-country-two-systems-remain-unchanged-2047-says-hong-kongs-carrie-lam/ |url-status=live |archive-url=https://web.archive.org/web/20230413184706/https://hongkongfp.com/2020/01/16/one-country-two-systems-remain-unchanged-2047-says-hong-kongs-carrie-lam/ |archive-date=13 April 2023 |access-date=2020-10-28 |website=Hong Kong Free Press HKFP |language=en-GB}}

Additionally, in a June 2020 online webinar to campaign for the National Security Law, Zhang Xiaoming said that the National Security Law would ensure that the freedoms granted to the city can be extended beyond 2047.{{Cite web |last1=Cheung |first1=Tony |last2=Wong |first2=Natalie |date=2020-06-08 |title=Security law to extend, not erode Hong Kong freedoms beyond 2047 |url=https://www.scmp.com/news/hong-kong/politics/article/3088031/deng-xiaoping-always-believed-mainland-could-step-if |url-access=subscription |url-status=live |archive-url=https://web.archive.org/web/20201102160244/https://www.scmp.com/news/hong-kong/politics/article/3088031/deng-xiaoping-always-believed-mainland-could-step-if |archive-date=2 November 2020 |access-date=2020-10-28 |website=South China Morning Post |language=en}} However, neither Carrie Lam or Zhang Xiaoming have promised such an extension or laid out concrete steps or goals in order for it to happen.{{cite web |title=大国崛起准备的理论启示 |url=https://www.siis.org.cn/updates/cms/old/shgjwt201512107417/UploadFiles/file/20161229/%E5%9B%BD%E9%99%85%E5%B1%95%E6%9C%9B2013%E5%B9%B4%E7%AC%AC6%E6%9C%9F%20%E6%AD%A3%E6%96%87.pdf |website=siis.org |access-date=6 April 2025}}

In October 2021, Carrie Lam reiterated that she believed the system would be extended beyond 2047, stating "Anybody would seriously ask: why do we have to change it? But of course, something more concrete will have to come out later on to give the needed assurance about the continuation of the common law system, the monetary system, the professional recognition system, maybe some land leases."{{Cite web |title=One Country, Two Systems to last beyond 2047: CE |url=https://news.rthk.hk/rthk/en/component/k2/1614128-20211008.htm |url-status=dead |archive-url=https://web.archive.org/web/20211008061807/https://news.rthk.hk/rthk/en/component/k2/1614128-20211008.htm |archive-date=8 October 2021 |access-date=2021-10-08 |website=RTHK |language=en-gb}}

In March 2022, Xia Baolong, head of the Hong Kong and Macau Affairs Office, said that after 2047, the "one country, two systems" could be extended by another 50 years, until 2097.{{Cite web |last= |first= |title=City's autonomy could last beyond 2047 |url=https://www.thestandard.com.hk/breaking-news/section/4/187936/City%27s-autonomy-could-last-beyond-2047 |url-status=live |archive-url=https://web.archive.org/web/20220309125007/https://www.thestandard.com.hk/breaking-news/section/4/187936/City%27s-autonomy-could-last-beyond-2047 |archive-date=9 March 2022 |access-date=2022-03-09 |website=The Standard |language=en}}

In July 2022, Leung Chun-ying, former chief executive, said that he expected the system to be extended past 2047.{{Cite web |last= |first= |title=CY Leung expects "one country, two systems" to go beyond 2047 |url=https://www.thestandard.com.hk/breaking-news/section/4/191845/CY-Leung-expects-%E2%80%98one-country,-two-systems%E2%80%99-to-go-beyond-2047 |url-status=live |archive-url=https://web.archive.org/web/20220702173220/https://www.thestandard.com.hk/breaking-news/section/4/191845/CY-Leung-expects-%E2%80%98one-country,-two-systems%E2%80%99-to-go-beyond-2047 |archive-date=2 July 2022 |access-date=2022-07-03 |website=The Standard |language=en}}

On 1 July 2022, during a visit to Hong Kong, General Secretary of the Chinese Communist Party Xi Jinping made a promise that the system is a long-term policy.{{Cite web |title=Hong Kong will stay a common law jurisdiction: SJ |url=https://news.rthk.hk/rthk/en/component/k2/1674682-20221108.htm |url-status=live |archive-url=https://web.archive.org/web/20221108190615/https://news.rthk.hk/rthk/en/component/k2/1674682-20221108.htm |archive-date=8 November 2022 |access-date=2022-11-08 |website=RTHK |language=en-gb}}

In February 2024, Xia Baolong said that the system would be kept permanently.{{Cite web |last=Cheung |first=Ezra |last2=Lo |first2=Hoi-ying |last3=Wu |first3=Willa |date=2024-02-26 |title=Hong Kong governing principle to be permanent feature, top Beijing official says |url=https://www.scmp.com/news/hong-kong/politics/article/3253216/beijing-attaches-great-importance-hong-kong-countrys-global-finance-hub-xia-baolong-tells-local |url-access=subscription |url-status=live |archive-url=https://archive.today/20240226191728/https://www.scmp.com/news/hong-kong/politics/article/3253216/beijing-attaches-great-importance-hong-kong-countrys-global-finance-hub-xia-baolong-tells-local |archive-date=26 February 2024 |access-date=2024-03-27 |website=South China Morning Post |language=en}}

Implementation in Hong Kong

= Degree of autonomy =

As a British colony, Hong Kong was neither democratic nor autonomous.{{Rp|page=177}} After Britain returned Hong Kong to China in 1997, Beijing promised that Hong Kong citizens would be free to elect their local government. However, the Basic Law does not have a clear timetable for when universal suffrage is to be achieved, ultimately stating that a full vote by the populace and universal suffrage must be reached before the end of the 50-year transition according to Article 45.{{Cite web |date=16 December 2014 |title=Fact check: Was Hong Kong ever promised democracy? – Fact Check |url=https://mobile.abc.net.au/news/2014-12-16/was-hong-kong-ever-promised-democracy-fact-check/5809964 |url-status=live |archive-url=https://web.archive.org/web/20191103144602/https://mobile.abc.net.au/news/2014-12-16/was-hong-kong-ever-promised-democracy-fact-check/5809964 |archive-date=3 November 2019 |access-date=19 November 2019 |website=ABC News}}{{Cite web |last=Koo |first=George |date=2 October 2019 |title=An alternative view of HK protests {{!}} Opinion |url=https://www.asiatimes.com/2019/10/opinion/an-alternative-view-of-hong-kong/ |url-status=live |archive-url=https://web.archive.org/web/20191012003920/https://www.asiatimes.com/2019/10/opinion/an-alternative-view-of-hong-kong/ |archive-date=12 October 2019 |access-date=19 November 2019 |website=Asia Times |language=en}}

In the year after the handover, surveys showed high levels of satisfaction with Beijing's hands-off relationship with the former colony.{{cite book |last1=Carroll |first1=John Mark |url=https://www.worldcat.org/title/184965072?oclcNum=184965072 |title=A Concise History of Hong Kong |date=2007 |publisher=Hong Kong University Press |isbn=978-962-209-878-7 |pages=221–228 |oclc=184965072}}

The year before, the Provisional Legislative Council passed laws restricting the right of abode, leading to a case brought against the government, which ended in a loss for the government in the Hong Kong Court of Final Appeal in 1999. The government then took its case to the National People's Congress. The legal establishment expressed its disapproval of the act Martin Lee described as "giving away" Hong Kong's autonomy with a silent march. Polls showed the events had depressed the public's confidence in the government, despite the fact that most were in favour of the government's stance over that of the court's.

On 10 June 2014, China's central government released a white paper{{cite news|url=http://news.xinhuanet.com/english/china/2014-06/10/c_133396891.htm|title=Full Text: The Practice of the "One Country, Two Systems" Policy in the Hong Kong Special Administrative Region|agency=Xinhua News Agency|url-status=dead|archive-url=https://web.archive.org/web/20141008210149/http://news.xinhuanet.com/english/china/2014-06/10/c_133396891.htm|archive-date=8 October 2014}} describing its view of comprehensive jurisdiction over Hong Kong.{{Rp|page=180}} The white paper stated that Hong Kong's high degree of autonomy is not an inherent power, but rather one which exists solely through the authorization of the central government.{{Rp|page=180}} The white paper's release ignited criticism from many people in Hong Kong, who said that the Communist leadership was reneging on its pledges to abide by the "one country, two systems" policy that allows for a democratic, autonomous Hong Kong under Beijing's rule.{{cite web | url = http://mobile.nytimes.com/blogs/sinosphere/2014/06/11/beijings-white-paper-sets-off-a-firestorm-in-hong-kong/ | title = Beijing's "White Paper" Sets Off a Firestorm in Hong Kong | work = The New York Times | date = 11 June 2014 | access-date = 23 June 2014 | archive-url = https://web.archive.org/web/20140618000943/http://mobile.nytimes.com/blogs/sinosphere/2014/06/11/beijings-white-paper-sets-off-a-firestorm-in-hong-kong/ |author-last1=Wong|author-first1=Alan| archive-date = 18 June 2014 | url-status = dead | df = dmy-all }}

During the 2014 Hong Kong protests, students demanded more political freedom in direct response to the "831 decision" of the NPCSC. The participants demanded freedom of choice, electoral freedom, democracy and, in particular, they wanted to participate in the elections of the head of the administration of Hong Kong. The name "umbrella movement" originated because the students protected themselves with umbrellas from the pepper spray of the police. Thus, umbrellas became the symbol of this movement. In 2016, Joshua Wong, Alex Chow and Nathan Law, student leaders of the protests, were charged for their roles in the protests and found guilty. https://cn.nytimes.com/china/20160721/c21hongkong/

= Moral and National Education controversy =

It was officially announced in September 2012 that the Hong Kong government would introduce compulsory "national, moral and civic education"{{Cite web|title=Moral, Civic and National Education|url=https://www.edb.gov.hk/en/curriculum-development/4-key-tasks/moral-civic/index.html|website=www.edb.gov.hk|access-date=14 May 2020|archive-url=https://web.archive.org/web/20191022115906/https://www.edb.gov.hk/en/curriculum-development/4-key-tasks/moral-civic/index.html|archive-date=22 October 2019|url-status=live}} in all non-international primary and secondary schools to strengthen "national identity awareness and nurture patriotism towards China".{{Cite web|title=National education in Hong Kong|url=https://www.scmp.com/topics/national-education-hong-kong|website=South China Morning Post|language=en|access-date=14 May 2020|archive-url=https://web.archive.org/web/20200419170006/https://www.scmp.com/topics/national-education-hong-kong|archive-date=19 April 2020|url-status=live}}{{Cite journal |last1=Morris |first1=Paul |last2=Vickers |first2=Edward |date=3 July 2015 |title=Schooling, politics and the construction of identity in Hong Kong: the 2012 "Moral and National Education" crisis in historical context |url=https://discovery.ucl.ac.uk/id/eprint/1488620/1/Morris_Vickers%20untracked%20-%20EV%20March%2013%202015.pdf |url-status=live |journal=Comparative Education |language=en |volume=51 |issue=3 |pages=305–326 |doi=10.1080/03050068.2015.1033169 |issn=0305-0068 |oclc=6001098933 |s2cid=142915161 |archive-url=https://web.archive.org/web/20201205125022/https://discovery.ucl.ac.uk/id/eprint/1488620/1/Morris_Vickers%20untracked%20-%20EV%20March%2013%202015.pdf |archive-date=5 December 2020 |access-date=29 August 2020}} According to an academic research paper, the current school curriculum in Hong Kong projects a "dual sense of identity": "Chineseness" and "Hongkongesness" and notably, this has created strong public activism by Hong Kong pre- and post-1997. However, the new curriculum includes "general civic education" and lessons meant to increase students' appreciation of China.{{Cite news|last=Liu|first=Juliana|date=1 September 2012|title=Hong Kong debates "national education" classes|language=en-GB|work=BBC News|url=https://www.bbc.com/news/world-asia-china-19407425|access-date=14 May 2020|archive-url=https://web.archive.org/web/20191208174530/https://www.bbc.com/news/world-asia-china-19407425|archive-date=8 December 2019|url-status=live}} This announcement led to 10 days of protests, with up to 120,000 protesters each day, due to concerns of Hong Kong losing autonomy.{{Cite web |last1=Lau |first1=Stuart |last2=Nip |first2=Amy |last3=Wan |first3=Adrian |date=9 September 2012 |title=Protest against national education to end after government climbdown |url=https://www.scmp.com/news/hong-kong/article/1032535/protest-against-national-education-end-after-government-climbdown |url-access=subscription |url-status=live |archive-url=https://web.archive.org/web/20200519031556/https://www.scmp.com/news/hong-kong/article/1032535/protest-against-national-education-end-after-government-climbdown |archive-date=19 May 2020 |access-date=14 May 2020 |website=South China Morning Post |language=en}} In response, the chief executive at the time, CY Leung, chose to remove the idea of compulsory teaching, meaning that schools could freely decide if they would teach the subject. Despite CY Leung's decision, new chief executive Carrie Lam, who took over on 1 July 2017, has prioritised the topic of national education, by placing importance on "instilling patriotism in pupils".{{Cite web |last=Chiu |first=Peace |date=4 August 2017 |title=Is national education set to make a comeback in Hong Kong? |url=https://www.scmp.com/news/hong-kong/politics/article/2105343/chinese-national-education-set-make-comeback-hong-kong-its |url-access=subscription |url-status=live |archive-url=https://web.archive.org/web/20200226180558/https://www.scmp.com/news/hong-kong/politics/article/2105343/chinese-national-education-set-make-comeback-hong-kong-its |archive-date=26 February 2020 |access-date=14 May 2020 |website=South China Morning Post |language=en}} Furthermore, in August 2017, Christine Choi Yuk-Lin was appointed by the government as the under-secretary of the Education Bureau.{{Cite web |last1=Lam |first1=Jeffie |last2=Chiu |first2=Peace |date=1 August 2017 |title=Pro-Beijing school principal named Hong Kong's new education undersecretary despite national education fears |url=https://www.scmp.com/news/hong-kong/politics/article/2104961/pro-beijing-school-principal-named-hong-kongs-new-education |url-access=subscription |url-status=live |archive-url=https://web.archive.org/web/20171002172610/http://www.scmp.com/news/hong-kong/politics/article/2104961/pro-beijing-school-principal-named-hong-kongs-new-education |archive-date=2 October 2017 |access-date=14 May 2020 |website=South China Morning Post |language=en}} She "has former connections with the pro-Beijing Federation of Education Workers" (SCMP article A). This led to more than 17,000 people signing a petition opposing Yuk-lin having the position. Chinese Communist Party general secretary Xi Jinping also announced during his visit to Hong Kong in July 2017 the need for an enhancement and boost of "national history and culture" in Hong Kong education.

= Causeway Bay booksellers case =

The disappearances of five staff at Causeway Bay Books – an independent publisher and bookstore – in October to December 2015 precipitated an international outcry as cross-border abductions were widely suspected. Although at least two of them disappeared in mainland China, one in Thailand, one member was last seen in Hong Kong, but apparently had found his way across the Chinese land border in Shenzhen without the necessary travel documents.{{cite web |url=http://bigstory.ap.org/urn:publicid:ap.org:acf943c14a5049e99aa1ab61bb9965dd |title=Hong Kong unsettled by case of 5 missing booksellers |agency=Associated Press |work=The Big Story |date=3 January 2016 |access-date=10 January 2016 |archive-url=https://web.archive.org/web/20160304114649/http://bigstory.ap.org/urn:publicid:ap.org:acf943c14a5049e99aa1ab61bb9965dd |archive-date=4 March 2016 |url-status=live }} The unprecedented disappearance of a person in Hong Kong, and the bizarre events surrounding it, shocked the city and crystallised international concern over the suspected abduction of Hong Kong citizens by Chinese public security bureau officials and their likely rendition, in violation of several articles of the Basic Law and the one country, two systems principle.{{cite news |url=https://www.nytimes.com/2016/01/05/world/asia/mighty-current-media-hong-kong-lee-bo.html?_r=0 |title=Disappearance of 5 Tied to Publisher Prompts Broader Worries in Hong Kong |date=5 January 2016 |work=The New York Times |access-date=3 March 2017 |archive-url=https://web.archive.org/web/20170321220848/https://www.nytimes.com/2016/01/05/world/asia/mighty-current-media-hong-kong-lee-bo.html?_r=0 |archive-date=21 March 2017 |url-status=live }}{{cite news|url=https://www.theguardian.com/world/2016/jan/07/hong-kong-bookshops-pull-politically-sensitive-titles-after-publishers-vanish|title=Hong Kong bookshops pull politically sensitive titles after publishers vanish|author=Ilaria Maria Sala|work=The Guardian|location=London|date=7 January 2016|access-date=17 December 2016|archive-url=https://web.archive.org/web/20170202140935/https://www.theguardian.com/world/2016/jan/07/hong-kong-bookshops-pull-politically-sensitive-titles-after-publishers-vanish|archive-date=2 February 2017|url-status=live}}{{cite web|url=http://www.ejinsight.com/20160105-unanswered-questions-about-the-missing-booksellers/|title=Unanswered questions about the missing booksellers|work=EJ Insight|date=5 January 2016|access-date=10 January 2016|archive-url=https://web.archive.org/web/20160111214122/http://www.ejinsight.com/20160105-unanswered-questions-about-the-missing-booksellers/|archive-date=11 January 2016|url-status=live}} It was later confirmed that they are under detention in mainland China although most had reappeared in Hong Kong and cancelled their missing persons' reports with the police.{{cn|date=February 2025}}

On 16 June 2016, shortly after he returned to Hong Kong, Lam Wing-kee gave a long press conference in which he detailed the circumstances surrounding his eight-month detention, and describing how his confession and those of his associates had been scripted and stage-managed. Lam implicated the involvement of the Central Investigation Team, which is under direct control of the highest level of the Beijing leadership. His revelations stunned Hong Kong and made headlines worldwide, prompting a flurry of counter-accusations and denials from mainland authorities and supporters.{{cite web|url=https://www.hongkongfp.com/2016/06/18/1000-protesters-chant-no-authority-support-returned-bookseller/|title=In Pictures: Over 1,000 protesters chant "no to authority" in support of returned bookseller – Hong Kong Free Press HKFP|date=18 June 2016|access-date=17 September 2016}}{{cite web|url=https://www.hongkongfp.com/2016/06/16/breaking-returned-bookseller-says-he-was-detained-by-a-special-unit-in-china-confession-was-scripted/|title=Returned bookseller says he was detained by "special unit" in China, TV "confession" was scripted|date=16 June 2016|work=hongkongfp.com|access-date=17 September 2016}}

= Hong Kong National Party ban =

On 17 July 2018, the Hong Kong Police Force served the party convener a notice under the Societies Ordinance, seeking to ban the Hong Kong National Party (HKNP) for sedition, on grounds of national security with respect to Chinese territorial integrity. The party and its convener Andy Chan submitted their case against being outlawed. Ten days later, in an unprecedented move, Secretary for Security John Lee on 24 September 2018 officially banned the party on national security grounds.{{cite news|title=Hong Kong National Party's call for "armed revolution" no mere political slogan but a threat to safety and order, security minister John Lee says|date=24 September 2018|newspaper=South China Morning Post|url=https://www.scmp.com/news/hong-kong/politics/article/2165439/hong-kong-issues-unprecedented-ban-separatist-party|access-date=15 November 2018|archive-url=https://web.archive.org/web/20180926062421/https://www.scmp.com/news/hong-kong/politics/article/2165439/hong-kong-issues-unprecedented-ban-separatist-party|archive-date=26 September 2018|url-status=live}}

The ban prohibited anyone who claims to be a HKNP member, or is found to provide aid to the party in any way, under the threat of being fined and jailed for up to two years. The definition of "providing aid" to the party and the two leaders were not made clear. Chan's lawyers wrote to the Department of Justice seeking an assurance that providing legal assistance to him would not be regarded as providing assistance to the HKNP, but that assurance was not forthcoming.{{cite news|last1=Lum|first1=Alvin|title=Hong Kong National Party founders lodge separate appeals against ban in effort to avoid legal action|url=https://www.scmp.com/news/hong-kong/politics/article/2170054/hong-kong-separatist-party-founders-andy-chan-and-chow-ho|access-date=24 October 2018|work=South China Morning Post|date=24 October 2018|archive-url=https://web.archive.org/web/20181024125720/https://www.scmp.com/news/hong-kong/politics/article/2170054/hong-kong-separatist-party-founders-andy-chan-and-chow-ho|archive-date=24 October 2018|url-status=live}}

= Victor Mallet controversy =

In August, a controversy erupted in 2018 when the Foreign Correspondents' Club of Hong Kong (FCC) hosted a lunchtime talk with Andy Chan, convener of the Hong Kong Independence Party (HKIP) to take place on 14 August. Victor Mallet, vice-chairman of the press organisation, chaired the session.{{cite news|url=https://time.com/5450061/hong-kong-financial-times-journalist-barred/|title=Financial Times Editor Barred Entry Into Hong Kong|magazine=Time|date=8 October 2018|access-date=15 November 2018|archive-url=https://web.archive.org/web/20181116065156/http://time.com/5450061/hong-kong-financial-times-journalist-barred/|archive-date=16 November 2018|url-status=live}} The governments of China and Hong Kong had called for the cancellation of the talk, because the issue of independence supposedly crossed one of the "bottom lines" on national sovereignty.{{cite web|url=https://www.bbc.com/news/world-asia-china-45769811|title=Hong Kong rejects visa for FT editor|date=6 October 2018|publisher=BBC|access-date=15 November 2018|archive-url=https://web.archive.org/web/20181116000813/https://www.bbc.com/news/world-asia-china-45769811|archive-date=16 November 2018|url-status=live}}{{cite web|url=https://www.scmp.com/news/hong-kong/politics/article/2168041/hong-kong-denied-journalist-victor-mallets-visa-influence|title=Ex-British foreign minister, US senator urge action on Hong Kong visa refusal|work=South China Morning Post|date=9 November 2018|access-date=15 November 2018|archive-url=https://web.archive.org/web/20181115195108/https://www.scmp.com/news/hong-kong/politics/article/2168041/hong-kong-denied-journalist-victor-mallets-visa-influence|archive-date=15 November 2018|url-status=live}} After a visit to Bangkok, Mallet was denied a working visa by the Hong Kong government.{{Cite web| url=https://www.scmp.com/news/hong-kong/politics/article/2167429/financial-times-journalist-victor-mallet-re-enters-hong-kong| title=Journalist Victor Mallet allowed back into Hong Kong – for seven days only| date=8 October 2018| access-date=15 November 2018| archive-url=https://web.archive.org/web/20181116023642/https://www.scmp.com/news/hong-kong/politics/article/2167429/financial-times-journalist-victor-mallet-re-enters-hong-kong| archive-date=16 November 2018| url-status=live}} Mallet was subjected to a four-hour interrogation by immigration officers on his return from Thailand on Sunday 7 October before he was finally allowed to enter Hong Kong on a seven-day tourist visa.{{cite web|url=https://www.scmp.com/news/hong-kong/politics/article/2172430/refusal-let-british-financial-times-journalist-enter-hong|title=Ban on journalist risks undermining business confidence, UK minister warns|work=South China Morning Post|date=9 November 2018|access-date=16 November 2018|archive-url=https://web.archive.org/web/20181115195057/https://www.scmp.com/news/hong-kong/politics/article/2172430/refusal-let-british-financial-times-journalist-enter-hong|archive-date=15 November 2018|url-status=live}}

In the absence of an official explanation, Mallet's visa rejection was widely seen to be retribution for his role in chairing the Andy Chan talk which the FCC refused to call off. Secretary for Security John Lee insisted the ban on Mallet was unrelated to press freedom, but declined to explain the decision. The incident caused a furious debate over restrictions to freedoms that were supposedly protected by the Sino-British Joint Declaration under "one country, two systems".{{cite web|url=https://www.dw.com/en/financial-times-editor-given-one-week-to-leave-hong-kong/a-45796550|title=Financial Times editor given one week to leave Hong Kong|date=8 October 2018|publisher=Deutsche Welle|access-date=15 November 2018|archive-url=https://web.archive.org/web/20181116000836/https://www.dw.com/en/financial-times-editor-given-one-week-to-leave-hong-kong/a-45796550|archive-date=16 November 2018|url-status=live}}

= Extradition bill and Hong Kong 2019–2020 protests =

{{main|2019–20 Hong Kong protests|2019 Hong Kong extradition bill}}

In April 2019, an extradition bill was proposed in Hong Kong inciting mass protests.{{Cite news|last1=Ives|first1=Mike|last2=May|first2=Tiffany|date=11 June 2019|title=Hong Kong Residents Block Roads to Protest Extradition Bill|language=en-US|work=The New York Times|url=https://www.nytimes.com/2019/06/11/world/asia/hong-kong-protest.html|access-date=14 May 2020|issn=0362-4331|archive-url=https://web.archive.org/web/20190612020123/https://www.nytimes.com/2019/06/11/world/asia/hong-kong-protest.html|archive-date=12 June 2019|url-status=live}} The new law identifies that those who are suspects of serious crimes could be sent to China.{{Cite web|title=Hong Kong's controversial extradition bill explained|url=https://www.aljazeera.com/news/2019/06/explainer-hong-kong-controversial-extradition-bill-190610101120416.html|last=Mayberry|first=Kate|date=11 June 2019|website=www.aljazeera.com|access-date=14 May 2020|archive-url=https://web.archive.org/web/20200516052238/https://www.aljazeera.com/news/2019/06/explainer-hong-kong-controversial-extradition-bill-190610101120416.html|archive-date=16 May 2020|url-status=live}} This was initiated due to a murder suspect fleeing from Taiwan to Hong Kong in 2018.{{Cite news|last=Li|first=Jeff|date=13 December 2019|title=Hong Kong-China extradition plans explained|language=en-GB|work=BBC News|url=https://www.bbc.com/news/world-asia-china-47810723|access-date=14 May 2020|archive-url=https://web.archive.org/web/20190614142519/https://www.bbc.com/news/world-asia-china-47810723|archive-date=14 June 2019|url-status=live}} He was accused of murdering his pregnant 20 year old girlfriend, thus Hong Kong authorities were asked by Taiwan to extradite the man. Hong Kong, however, did not concur with this demand and could not prosecute him as Hong Kong does not have any form of an extradition agreement with Taiwan.{{Cite web|title=Murder suspect whose alleged crime sparked Hong Kong protests walks free|url=https://www.cnn.com/2019/10/23/asia/hong-kong-taiwan-murder-intl-hnk/index.html|first=James|last=Griffiths|website=CNN|date=23 October 2019|access-date=14 May 2020|archive-url=https://web.archive.org/web/20191105163912/https://www.cnn.com/2019/10/23/asia/hong-kong-taiwan-murder-intl-hnk/index.html|archive-date=5 November 2019|url-status=live}} In terms of the Extradition Law, it was claimed that decisions would be made on a "case-by-case basis by the Chief Executive", in addition to Hong Kong courts making final decisions on extradition requests. For this reason, those accused of crimes based on politics or religion would not be extradited, and the new law would purely be "dealing with cross border crimes and transnational crimes" that carries a minimum seven-years sentence, as Carrie Lam stated in her speech on Monday 10 June. However, many Hong Kong people claim that this is another example of Hong Kong losing its autonomy. There has been criticism that this law would mean that suspects would be susceptible to many practices under the Chinese judicial system that is not present in the Hong Kong judicial system: arbitrary detention, unfair trial and torture. Michael DeGolyer, a researcher at Baptist University of Hong Kong, told Al Jazeera that Hong Kong people fear lack of judicial independence as the current judiciary system "is seen as guaranteeing a measure of protection from the government on the mainland".

There has been a widespread response opposing the law: nationally and internationally. Criticism, petitions and protests have incorporated many parts of society, including doctors, lawyers, teachers and housewives. On 9 June there were an estimated one million people protesting across Hong Kong, making it the biggest protest since the handover. Additionally, concern was displayed internationally: in Britain, Canada, the European Union and the United States. The US congressional commission argued in May 2019 that the extradition bill makes "Hong Kong more susceptible to China's political coercion and further erodes Hong Kong's autonomy". China's foreign ministry has rebutted these concerns by claiming them "attempts to politicise the Hong Kong government proposal and interference in China's internal affairs".

Due to this negative response nationally and internationally, on 4 September 2019, Carrie Lam formally announced that the extradition bill would be withdrawn.{{Cite web|title=Hong Kong leader withdraws extradition bill, sets up platform to examine protest causes|url=https://www.scmp.com/news/hong-kong/politics/article/3025641/hong-kong-leader-carrie-lam-announce-formal-withdrawal|date=4 September 2019|website=South China Morning Post|language=en|access-date=14 May 2020|archive-url=https://web.archive.org/web/20190904112228/https://www.scmp.com/news/hong-kong/politics/article/3025641/hong-kong-leader-carrie-lam-announce-formal-withdrawal|archive-date=4 September 2019|url-status=live}} Despite this, fear of the loss of Hong Kong autonomy remains. Protests continued until the outbreak of the COVID-19 pandemic in January 2020, and are predicted to continue once the pandemic is under control in Hong Kong.{{Cite web|title=As coronavirus crisis starts to pass, Hong Kong may be set for another summer of discontent|url=https://www.cnn.com/2020/04/20/asia/hong-kong-protests-coronavirus-intl-hnk/index.html|first=James|last=Griffiths|website=CNN|date=21 April 2020 |access-date=14 May 2020|archive-url=https://web.archive.org/web/20200422124907/https://www.cnn.com/2020/04/20/asia/hong-kong-protests-coronavirus-intl-hnk/index.html|archive-date=22 April 2020|url-status=live}}{{Needs update|date=July 2024}}

= 2020 national security legislation =

{{Main|National People's Congress Decision on Hong Kong national security legislation}}

A draft national security bill was submitted on 22 May 2020 to China's national parliament, the National People's Congress.{{Cite web|title='The end of Hong Kong': Experts say China's push to pass strict national security laws further erodes the city's autonomy|url=https://www.businessinsider.com/china-national-security-laws-hong-kong-article-23-explainer-2020-5|last=Perper|first=Rosie|date=23 May 2020|website=Business Insider Australia|language=en|access-date=23 May 2020|archive-date=26 January 2022|archive-url=https://web.archive.org/web/20220126050951/https://www.businessinsider.com.au/china-national-security-laws-hong-kong-article-23-explainer-2020-5|url-status=live}} In accordance with the one country, two systems formula, Hong Kong's basic law requires the Hong Kong legislature to ratify national security to prevent sedition, secession and foreign interference. The Chinese central government is now bypassing the HKSAR to directly legislate.{{Cite news|url=https://www.theguardian.com/world/2020/may/22/why-reassertion-of-xi-jinping-authority-spells-violence-in-hong-kong-sedition-legislation|title=Why reassertion of Xi Jinping's authority spells violence in Hong Kong|first=Lily|last=Kuo|newspaper=The Guardian|date=22 May 2020|via=www.theguardian.com|access-date=23 May 2020|archive-date=23 May 2020|archive-url=https://web.archive.org/web/20200523183112/https://www.theguardian.com/world/2020/may/22/why-reassertion-of-xi-jinping-authority-spells-violence-in-hong-kong-sedition-legislation|url-status=live}} A National People's Congress official reported as saying it was exercising "constitutional power" to create a new legal framework and enforcement mechanism to guarantee national security in Hong Kong.{{Cite web|title='Knockout blow': China plans controversial new national security legislation for Hong Kong|url=https://www.abc.net.au/news/2020-05-22/china-to-propose-national-security-legislation-for-hong-kong/12274202|date=21 May 2020|website=www.abc.net.au|language=en-AU|access-date=23 May 2020|archive-date=23 May 2020|archive-url=https://web.archive.org/web/20200523070610/https://www.abc.net.au/news/2020-05-22/china-to-propose-national-security-legislation-for-hong-kong/12274202|url-status=live}} On 30 June 2020, the Standing Committee of the National People's Congress (NPCSC) passed the national security law for Hong Kong unanimously and listed it under Annex III of the Basic Law, bypassing Hong Kong approval. The Hong Kong Bar Association (HKBA) disputed the constitutionality of enacting the law through inclusion in Annex III of the Basic Law in May 2020.{{Cite web|date=25 May 2020|title=Statement of the Hong Kong Bar Association on proposal of National People's Congress to enact National Security Law in Hong Kong|url=https://www.hkba.org/sites/default/files/20200525%20-%20Proposal%20of%20National%20People%27s%20Congress%20to%20enact%20National%20Security%20Law%20in%20Hong%20Kong%20%28E%29.pdf|url-status=live|archive-url=https://web.archive.org/web/20200525134948/https://www.hkba.org/sites/default/files/20200525%20-%20Proposal%20of%20National%20People%27s%20Congress%20to%20enact%20National%20Security%20Law%20in%20Hong%20Kong%20%28E%29.pdf|archive-date=25 May 2020|access-date=25 May 2020|website=Hong Kong Bar Association}}

On 30 May 2020, the president of the United States, Donald J. Trump, in a White House press conference, officially declared that the United States would be ending special treatments afforded to Hong Kong as outlined in the United States-Hong Kong Policy Act, due to China replacing the promised formula of "one country, two systems" with "one country, one system",{{Cite web|title=Remarks by President Trump on Actions Against China|url=https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-actions-china/|last=Trump|first=Donald John|date=30 May 2020|website=WH.gov|language=en|access-date=30 May 2020|archive-date=20 January 2021|archive-url=https://web.archive.org/web/20210120200626/https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-actions-china/|url-status=live}} and threatened that the United States would take further actions on Hong Kong in response to the national security law. On 14 July 2020, President Trump signed Executive Order 13936, pursuant to the Hong Kong Autonomy Act passed by the US Congress, ending Hong Kong's special trade privileges.

According to Victoria Tin-bor Hui, writing in The Diplomat, the national security legislation is being used to erode civil and legal protections on the way to "establishing a police state" in Hong Kong.{{cite web |last1=Tin-bor Hui |first1=Victoria |title=Hong Kong's New Police State |url=https://thediplomat.com/2021/05/hong-kongs-new-police-state/ |website=thediplomat.com |publisher=The Diplomat |access-date=20 July 2021 |archive-date=9 July 2021 |archive-url=https://web.archive.org/web/20210709184905/https://thediplomat.com/2021/05/hong-kongs-new-police-state/ |url-status=live }}

Implementation in Macau

= Macau and mainland China relations =

Macau has not seen outbreaks of protests and civil unrest that have occurred in Hong Kong.{{Cite news|last=Williams|first=Sophie|date=20 December 2019|title=HK's model neighbour that stays loyal to China|language=en-GB|work=BBC News|url=https://www.bbc.com/news/world-asia-china-50832919|access-date=14 May 2020|archive-url=https://web.archive.org/web/20200401134925/https://www.bbc.com/news/world-asia-china-50832919|archive-date=1 April 2020|url-status=live}} According to Jason Chao, a former president of the New Macau Association (a pro-democracy party), Macau differed from Hong Kong as Macau does not wish for freedom and autonomy. Instead, the majority of Macau's population are pro-China.{{Cite news|last1=Master|first1=Farah|last2=Zhai|first2=Keith|date=12 December 2019|title=Exclusive: Protest-free Macau to win financial policy rewards from China|language=en|work=Reuters|url=https://www.reuters.com/article/us-macau-politics-exclusive-idUSKBN1YG0EJ|access-date=14 May 2020|archive-url=https://web.archive.org/web/20200219040926/https://www.reuters.com/article/us-macau-politics-exclusive-idUSKBN1YG0EJ|archive-date=19 February 2020|url-status=live}} A reason for this is because approximately half of the 600,000 people living in Macau are Chinese immigrants. In December 2019, Li Zhanshu, chairman of the NPCSC, claimed that there is a "strong sense of international identity" in Macau. In Chinese Communist Party general secretary Xi Jinping's first official speech in Macau in December 2019 marking the 20th anniversary, he proclaimed Macau as "a gorgeous chapter in the short history of the one country, two systems experiment".{{Cite web|title=Where Does China's "One Country, Two Systems" Stand in 2020?|url=https://thediplomat.com/2020/02/where-does-chinas-one-country-two-systems-stand-in-2020/|last=Grossman|first=Derek|website=thediplomat.com|language=en-US|access-date=14 May 2020|archive-url=https://web.archive.org/web/20200509145409/https://thediplomat.com/2020/02/where-does-chinas-one-country-two-systems-stand-in-2020/|archive-date=9 May 2020|url-status=live}} Chief executive of Macau, Ho Iat Seng, said: "Macau will be an example of China's reunification," and Xi has agreed, by placing emphasis on the "Macau Model" as Macau has correctly followed the "one country, two system" agreement. As a reward for Macau's peaceful behaviour and lack of anti-government protests, Xi Jinping has given Macau more Chinese land from Hengqin Island. This is to enable Macau to further develop their education and healthcare system, in addition to physically integrating Macau more with China.{{Cite web|title=EXCLUSIVE-Protest-free Macau to win financial policy rewards from China|url=https://www.cnbc.com/2019/12/12/reuters-america-exclusive-protest-free-macau-to-win-financial-policy-rewards-from-china.html|last1=Zhai|first1=Keith|first2=Farah|last2=Master|date=12 December 2019|publisher=CNBC|language=en|access-date=14 May 2020|archive-url=https://web.archive.org/web/20191212083354/https://www.cnbc.com/2019/12/12/reuters-america-exclusive-protest-free-macau-to-win-financial-policy-rewards-from-china.html|archive-date=12 December 2019|url-status=live}} Under the "One Country, Two Systems" policy, Macau has an independent legal and financial system, allowing the legal development of the gambling industry and opening up to the international market, which has led to its rapid rise as a global gambling hub and significant economic growth and international influence.

Proposed application onto Taiwan

{{expand section|with=Proposal being made in different parts of the history, as well as reaction from different fractions inside and outside Taiwan in each respective times|small=no|date=March 2022}}

The PRC government was also proposed the application of the one country, two systems principle for Taiwan, but the Taiwanese government has refused this suggestion. It has been claimed that the system was originally designed for Taiwan{{cite journal |last1=Cooney |first1=Sean |url=https://digitalcommons.law.uw.edu/wilj/vol6/iss3/2/ |title=Why Taiwan is not Hong Kong: A Review of the PRC's "One Country Two Systems" Model for Reunification for Taiwan |journal=Pacific Rim Law & Policy Association |date=1997 |volume=6 |issue=3 |pages=497–548 |access-date=16 May 2022 |archive-date=11 August 2022 |archive-url=https://web.archive.org/web/20220811174723/https://digitalcommons.law.uw.edu/wilj/vol6/iss3/2/ |url-status=live }} in order for it to be unified with the PRC.

While China had guaranteed that Hong Kong's economic and political systems would not be changed for 50 years following the British handover, the Mainland Affairs Council of the Republic of China has cited 218 cases between 1997 and 2007 that they claim to be breaches of the Hong Kong peoples' rights to self-rule or freedom of speech, as well as severe interventions in the judicial system.{{clarify|date=August 2024}}{{cite web|url=https://ws.mac.gov.tw/001/Upload/297/relfile/8478/72053/14f46a7e-e74d-4df7-8995-cca469878019.pdf|title=Analysis Report: 20 Years After Hong Kong's Handover|date=29 June 2006|work=Mainland Affairs Council|access-date=3 February 2018|archive-url=https://web.archive.org/web/20180203180939/https://ws.mac.gov.tw/001/Upload/297/relfile/8478/72053/14f46a7e-e74d-4df7-8995-cca469878019.pdf|archive-date=3 February 2018|url-status=live}}

A new policy based on the 1992 Consensus was emphasised during the Pan-Blue visits to mainland China in April 2005{{cite news|url=http://www.theage.com.au/news/World/Hopes-grow-as-second-Taiwan-leader-visits-China/2005/05/12/1115843308418.html|title=Hopes grow as second Taiwan leader visits China|date=13 May 2005|access-date=26 July 2006|location=Melbourne|work=The Age|archive-url=https://web.archive.org/web/20060506022258/http://www.theage.com.au/news/World/Hopes-grow-as-second-Taiwan-leader-visits-China/2005/05/12/1115843308418.html|archive-date=6 May 2006|url-status=live}} as well as subsequent major cross-strait exchanges under President Ma Ying-jeou, whose pro-unification Kuomintang (KMT) party won the 2008 Taiwanese presidential election. During his visit to Beijing in March 2012, former KMT Chairman Wu Po-hsiung proposed a "one country, two areas" ({{zhi|s=一国两区|t=一國兩區|p=yīguóliǎngqū}}) framework to govern cross-strait relations,{{cite web |first=Mo |last=Yan-chih |url=http://www.taipeitimes.com/News/taiwan/archives/2012/03/23/2003528495|title='One country, two areas' proposed by Wu Po-hsiung |publisher=Taipei Times|date=23 March 2012|access-date=12 September 2014|archive-url=https://web.archive.org/web/20140904210514/http://www.taipeitimes.com/News/taiwan/archives/2012/03/23/2003528495|archive-date=4 September 2014|url-status=live}} though this term did not become widely adopted.

In January 2019, CCP General Secretary Xi Jinping announced an open letter to Taiwan proposing a one country, two systems formula for eventual unification. President Tsai Ing-wen responded to Xi in a January 2019 speech by stating that Taiwan rejected one country, two systems, and that because Beijing equated the 1992 Consensus with one country, two systems, Taiwan rejected it as well.{{cite news|url=https://www.nytimes.com/2019/01/05/world/asia/taiwan-xi-jinping-tsai-ing-wen.html|work=The New York Times|date=January 5, 2019|last=Horton|first=Chris|title=Taiwan's President, Defying Xi Jinping, Calls Unification Offer 'Impossible'|access-date=January 18, 2019|archive-date=4 July 2021|archive-url=https://web.archive.org/web/20210704104654/https://www.nytimes.com/2019/01/05/world/asia/taiwan-xi-jinping-tsai-ing-wen.html|url-status=live}} Tsai expressed her solidarity with Hong Kong protesters, remarking that Taiwan's democracy was hard-earned and had to be guarded and renewed. Pledging that as long as she was Taiwan's president, she would never accept one country, two systems, Tsai cited what she considered to be the constant and rapid deterioration of democracy in Hong Kong over the previous 20 years.{{cite web |url=https://focustaiwan.tw/politics/201906100017 |first1=Wang |last1=Cheng-chung |first2=Chang |last2=Ming-hsuan |first3=Liang |last3=Pei-chi |first4=Yeh |last4=Tze-kung |first5=Wang |last5=Hung-guo |first6=Wang |last6=Shwu-fen |first7=Chung |last7=Yu-chen |title=Tsai, Lai voice support for Hong Kong extradition bill protesters |date=10 June 2019 |website=Focus Taiwan |publisher=The Central News Agency |archive-url=https://web.archive.org/web/20200701070905/https://focustaiwan.tw/politics/201906100017 |archive-date=1 July 2020 |url-status=dead}} Following the landslide defeat of the KMT in the 2020 Taiwanese presidential election, KMT chairman Johnny Chiang rejected the one country, two systems as a feasible model for Taiwan.{{cite news |last=Blanchard |first=Ben |last2=Lee |first2=Yimou |title=Taiwan opposition chief in no rush for China meeting |date=March 21, 2021 |url=https://www.reuters.com/article/us-taiwan-politics/taiwan-opposition-chief-in-no-rush-for-china-meeting-idUSKCN2AU0IV |access-date=11 March 2021 |archive-date=9 March 2021 |archive-url=https://web.archive.org/web/20210309071434/https://www.reuters.com/article/us-taiwan-politics/taiwan-opposition-chief-in-no-rush-for-china-meeting-idUSKCN2AU0IV |url-status=live}} In 2021, the KMT platform under newly elected chairman Eric Chu also continued to include the 1992 Consensus while rejecting one country, two systems.{{cite news |last=Wang |first=Cheng-chung |last2=Liu |first2=Kuan-ting |last3=Liu |first3=Kay |title=KMT vows to "defend Taiwan, protect democracy, fight for future" |date=October 30, 2021 |url=https://focustaiwan.tw/cross-strait/202110300015 |access-date=31 October 2021 |work=Central News Agency (Taiwan) |archive-date=31 October 2021 |archive-url=https://web.archive.org/web/20211031020237/https://focustaiwan.tw/cross-strait/202110300015 |url-status=live }}

In 1987, the president of the Republic of China at the time, Chiang Ching-kuo, counter-proposed with the alternative of "one country, better system" ({{zh|s=一国良制|t=一國良制|p=Yīguó liángzhì|labels=no}}){{cite news |author=海基會首任秘書長陳長文 |title=辜汪會談23週年：放下兩國論，追求一國良制 |url=http://www.ettoday.net/news/20160502/690431.htm |agency=Ettoday東森新聞雲 |date=2016-05-02 |access-date=2016-11-03 |archive-url=https://web.archive.org/web/20161129223048/http://www.ettoday.net/news/20160502/690431.htm |archive-date=2016-11-29 |url-status=live }}{{cite news |author1=徐晓全 |title=邓小平对台和平统一构想回顾：立足两岸现实推进和平统一 |url=https://news.sina.cn/2019-08-29/detail-ihytcitn2779745.d.html |access-date=2021-02-10 |archive-date=2021-05-07 |archive-url=https://web.archive.org/web/20210507173007/https://news.sina.cn/2019-08-29/detail-ihytcitn2779745.d.html |url-status=live }} in a pun on "one country, two systems" ({{zh|s=一国两制|t=一國兩制|p=Yīguó liǎngzhì|labels=no}}), proposing that the PRC and ROC could be unified after the PRC adopts the democratic system of the ROC.

Comparison to status of Tibet

Jiang (2008) notes that the concept of "one country, two systems" is based on the Seventeen Point Agreement for the Peaceful Liberation of Tibet signed in 1951, and that its mechanism is similar to how the Qing emperor integrated new territories it had conquered by permitting local elites in these regions to continue to enjoy power for a time and to exercise autonomy without apparently threatening distinct local customs. As the concept was merely a "tactical and transitional arrangement", a point of view argues that the territory of Hong Kong will gradually experience the same fate as Tibet since 1959 – forced assimilation and tight direct control by the central government. Over time, full assimilation, and abolition of local autonomy, would take place in a manner "illustrative of a similar Chinese imperial expansionist mentalité".Hung, Ho-fung. [http://japanfocus.org/site/view/4207 "Three Views of Local Consciousness in Hong Kong"] {{Webarchive|url=https://web.archive.org/web/20150224071023/http://japanfocus.org/site/view/4207 |date=24 February 2015 }}. The Asia-Pacific Journal, Vol. 12; Issue 44, No. 1; 3 November 2014.

The 14th Dalai Lama's 2005 proposal for "high-level autonomy" for Tibet, evolved from a position of advocating Tibetan independence, has been compared to "one country, two systems". He has said that his proposals should be acceptable to China because "one country, two systems" is accommodated for in the Chinese Constitution. State media rejected this claim, pointing out that "one country, two systems" was designed for the capitalist social systems of Hong Kong and Macau, which had never existed in Tibet.{{Cite news|url=http://www.china-embassy.org/eng/zt/zgxz/t265334.htm|title="One country, two systems" not possible for Tibet|date=28 July 2006|access-date=24 August 2010|work=China Tibet Information Center|publisher=Embassy of the People's Republic of China in the United States|archive-url=https://web.archive.org/web/20100710091113/http://www.china-embassy.org/eng/zt/zgxz/t265334.htm|archive-date=10 July 2010|url-status=live}} In 2012, Dalai Lama mentioned again that the Seventeen Point Agreement was signed in the spirit of "one country, two systems".[https://www.dalailama.com/news/2012/his-holiness-speaks-to-chinese-students-in-rochester-mn/amp His Holiness speaks to Chinese students in Rochester, MN] {{Webarchive|url=https://web.archive.org/web/20210205141532/https://www.dalailama.com/news/2012/his-holiness-speaks-to-chinese-students-in-rochester-mn/amp |date=5 February 2021 }} April 23, 2012[https://www.youtube.com/watch?v=NrXhE0RFtXg?t=698 Dalai Lama Speaks to Chinese Students in MN (1 of 3)] {{Webarchive|url=https://web.archive.org/web/20220619101806/https://www.youtube.com/watch?v=NrXhE0RFtXg%3Ft%3D698 |date=19 June 2022 }} May 5, 2012

One country, two systems proposals for other countries

Muhammad Cohen, writing for Asia Times, suggests the "one country, two systems" formula is a possible solution to the Israeli–Palestinian conflict.{{cite web|title=Try "one country, two systems" where it might work|url=http://www.asiatimes.com/try-one-country-two-systems-might-work/|date=26 June 2017|work=Asia Times|access-date=18 September 2017|archive-date=18 September 2017|archive-url=https://web.archive.org/web/20170918062622/http://www.asiatimes.com/try-one-country-two-systems-might-work//|url-status=live}}

North Korea suggests the "one country, two systems" formula to bring about Korean reunification, through a confederation of two systems within one country.{{cite web|url=http://www.thesundaily.my/news/1183722|title=N. Korea proposes "one country, two systems" reunification|website=The Sun Daily|access-date=18 September 2017|archive-url=https://web.archive.org/web/20170909133142/http://www.thesundaily.my/news/1183722|archive-date=9 September 2017|url-status=live}} China has also promoted the idea; the difference between North Korea's motivation and China's is that North Korea seeks to maintain two separate governments, while China seeks gradual unification as it wishes to bring stability to the Korean peninsula with one centralised government.{{cite web|url=http://english.yonhapnews.co.kr/northkorea/2013/01/22/59/0401000000AEN20130122004300315F.HTML|title=China backs "one country, two systems" in Korean unification effort|website=english.yonhapnews.co.kr|date=22 January 2013|access-date=18 September 2017|archive-url=https://web.archive.org/web/20171025132351/http://english.yonhapnews.co.kr/northkorea/2013/01/22/59/0401000000AEN20130122004300315F.HTML|archive-date=25 October 2017|url-status=live}}

Irish Foreign Minister Simon Coveney said the arrangement linking Hong Kong with China could be a possible solution for addressing the fate of Northern Ireland after Brexit. The border between the EU member state Republic of Ireland and British-ruled Northern Ireland is becoming an increasing concern in talks with the United Kingdom, with Dublin demanding that the frontier remain completely open, to avoid endangering the peace process.[https://www.scmp.com/news/world/europe/article/2121157/irish-minister-suggests-hong-kong-solution-post-brexit-northern Irish minister suggests "Hong Kong solution" for post-Brexit Northern Ireland] {{Webarchive|url=https://web.archive.org/web/20181006114628/https://www.scmp.com/news/world/europe/article/2121157/irish-minister-suggests-hong-kong-solution-post-brexit-northern |date=6 October 2018 }}, AFP, South China Morning Post, 22 November 2017

Notes

References

{{Cite news |last=Kaiman |first=Jonathan |author-link=Jonathan Kaiman |date=2014-09-30 |title=Hong Kong's umbrella revolution – the Guardian briefing |language=en-GB |work=The Guardian |url=https://www.theguardian.com/world/2014/sep/30/-sp-hong-kong-umbrella-revolution-pro-democracy-protests |url-status=live |access-date=2023-06-11 |archive-url=https://web.archive.org/web/20170801161153/https://www.theguardian.com/world/2014/sep/30/-sp-hong-kong-umbrella-revolution-pro-democracy-protests |archive-date=1 August 2017 |issn=0261-3077}}