Start by checking which law, supervisory expectation, proposal, or guidance applies to your organization. The table identifies each instrument, its status, and who it addresses. The contribution section then explains what AAES Govern records can help a reviewer examine.
These pages describe the product and cite public instruments. They are not legal advice, not a certification, and not a statement that any instrument applies to your organization. The official source is authoritative; applicability questions belong to your advisers.
Instruments, by status
| Instrument | Status | What it addresses |
|---|---|---|
| Personal Data (Privacy) Ordinance (Cap. 486) | Binding law. | Personal data handling, including by AI systems. Using AAES does not discharge the data user's duties; other parties' obligations depend on their roles. |
| Artificial Intelligence: Model Personal Data Protection Framework · PCPD | Voluntary framework, published 11 June 2024. The Model Framework is voluntary and is not an approved code of practice under the PDPO. | AI strategy and governance with named accountability, risk assessment and human oversight, model lifecycle management, stakeholder engagement. |
| 2026 compliance checks · PCPD | Supervisory activity, not an instrument creating new duties. Findings published 19 May 2026 reported no PDPO contraventions in checks of 60 organizations across 15 sectors. | Examined AI use and personal-data privacy in practice, including implementation of the Model Framework and the GenAI employee checklist. The checks were not agentic-AI-specific tests. |
| Protecting Personal Data Privacy in the Use of Agentic AI · PCPD | Guidance, published 25 August 2026. Supplements the 2024 Model Framework; not law. | Five privacy risks of AI agents with system access (extensive access, system vulnerabilities, vulnerable plugins, function creep, multi-agent risks), with nine recommendations and a security checklist under the PDPO. |
| Circular on use of generative AI language models · SFC, 12 November 2024 | Supervisory circular addressed to SFC-licensed corporations; not legislation. It does not address organizations outside SFC supervision. | Four areas: senior-management responsibility, AI model risk management, cybersecurity and data risk management, third-party provider risk management. |
What AAES Govern records may contribute
| Expectation | AAES contribution | Capability status |
|---|---|---|
| Named accountability (PCPD Model Framework; SFC senior-management responsibility) | Each registered agent has an accountable manager whose chain of managers ends at a person. AAES Govern records the approver for human approval decisions; those assignments do not establish statutory appointments. | Implemented. |
| Human oversight of consequential actions (PCPD guidance; SFC circular) | Capabilities registered as irreversible require human approval bound to the exact request, with expiry. The operator classifies the action and must ensure reviewers have the information and authority to decide. | Implemented. |
| Records an internal audit can review (PCPD internal-audit recommendation) | Decision records are linked by cryptographic fingerprints to help detect changes. The client's own reviewer can check an export offline. | Implemented. An independently controlled witness can be configured separately; that is not an external assessment, and the default deployment has none. |
AAES Govern decision records may support review of access and approval controls. They do not establish lawful processing, model fairness, suitability, or compliance with any instrument as a whole.
Export checks do not establish complete capture, downstream success, or meaningful human oversight. Enforcement requires a credential path the agent cannot bypass. See the verification checks and their limits.
Your responsibilities
- The client remains the regulated entity. Ask your advisers whether the SFC circular or a PCPD instrument applies to you.
- Activity outside AAES Govern is visible only where telemetry is supplied. Decision records cover routed requests; reported telemetry may describe other activity without establishing complete coverage.
- AAES has no independent certification or assessment. No SOC 2 report exists, and no penetration test has been performed yet; an independent test is planned for Q4 2026.
- Status changes. Instruments are updated; re-check the primary source before relying on the status shown here.
Bring the instruments your risk team cites to a scoped evaluation.