Author: Shan Ali Hashmi (LLB, Law with Criminology)
How licensing, research and professional services can support the space economy without asking the city to become a launch state.
On 24 May 2026 Shenzhou-23 lifted off from Jiuquan. Among the crew was Dr Lai Ka-ying, a Hong Kong Police Force superintendent and computer forensics specialist selected as a payload expert in the country’s fourth astronaut cohort. She became the first astronaut from Hong Kong to fly to the Tiangong space station.[1] In the weeks that followed she assembled and tested a compact greenhouse-gas observatory designed in Hong Kong. The Multi-Spectral Imaging Carbon Observatory, known as MUSICO, is the first scientific payload from the city to operate on the national space station.[2] The images were moving. The legal and commercial question is quieter. What can Hong Kong actually do next?
The city will not become a launch power overnight. It has no domestic spaceport, and the Outer Space Ordinance was written around a smaller class of geostationary operations, (speculatively: it has great potential and talent to build all of these). Through education or infrastructure or expansionism into science. The more useful observation is that the space economy is already larger than rockets. A 2024 study by the World Economic Forum and McKinsey estimated the global space economy at US$630 billion in 2023 and projected it could reach US$1.8 trillion by 2035, driven as much by satellite data, navigation and communications as by launch itself.[3] That is the market in which Hong Kong’s research base, common law system, insurance market and professional services can do real work.
Policy has given departments a list
The 2025 Policy Address placed commercial aerospace on the official work programme. Under the heading “Promote the Development of Aerospace Science and Technology and Support Space Economy”, the Chief Executive recorded that the country has designated commercial aerospace as a strategic emerging industry, and that Hong Kong has advantages in internationalisation, scientific research and financing.[4] Two numbered paragraphs then named the tools: the Hong Kong Space Robotics and Energy Centre under InnoHK; more than HK$100 million under the Innovation and Technology Support Programme Special Call on Aerospace Technology for six university projects; a Commerce and Economic Development Bureau study on streamlining Low Earth Orbit satellite licensing; work on 6G applications; and a mandate for the Hong Kong Investment Corporation to pursue investment related to commercial aerospace and the space economy.[4]
Author: Shan Ali Hashmi (LLB, Law with Criminology)
Two statutes govern one spacecraft
Anyone advising a satellite operator in Hong Kong starts with two ordinances. The Outer Space Ordinance (Cap. 523) applies to launching or procuring the launch of a space object, operating a space object, and any activity in outer space, whether carried on in Hong Kong or elsewhere. Those activities require a licence, subject to limited exceptions. The Chief Executive may grant an Outer Space Licence to a body corporate incorporated under the laws of Hong Kong, and must be satisfied that the authorised activities will not jeopardise public health or the safety of persons or property and will be consistent with the international obligations of the People’s Republic of China.[5] OFCA’s published guidelines confirm that the ordinary applicant is a Hong Kong incorporated company.[6]
That is only half the pair. Under the Telecommunications Ordinance (Cap. 106), a Space Station Carrier Licence issued by the Communications Authority is required to establish, possess, maintain, use and operate a space station or earth station for telemetry, tracking, control and monitoring, and for space radiocommunications. A February 2026 paper of the Telecommunications Regulatory Affairs Advisory Committee describes current practice in a single sentence: operators obtain one pair of licences for each satellite. No fee is charged for the Outer Space Licence. The Space Station Carrier Licence carries an initial fee of HK$450,000 and an annual renewal of HK$150,000.[7]
The pair was designed around geostationary spacecraft. OFCA’s register records a small group of licensees, including AsiaSat and APT Satellite, which have given Hong Kong a continuous commercial satellite presence for three decades.[8] Low Earth Orbit constellations change the arithmetic. A constellation may comprise tens or thousands of satellites. Requiring a discrete pair of licences for each spacecraft is a bottleneck. By early 2026, CEDB told LegCo that the streamlining study had been primarily completed and that detailed arrangements were being formulated, with findings to be announced within 2026.[9]
The dependencies sit just behind the local file. Satellite filing information is submitted through the Ministry of Industry and Information Technology of the People’s Republic of China, as the national administration for International Telecommunication Union purposes. Export of a Hong Kong-manufactured satellite to the Mainland for launch must satisfy the relevant Mainland requirements. Spectrum, orbits and national security considerations travel with every application.[10] A streamlined LEO regime will only be useful if it remains aligned with those upstream processes, and if an operator can obtain, in one coordinated sequence, the Outer Space Licence, the radiocommunications authority, earth-station permissions, and a workable path to launch and in-orbit insurance.
Author: Shan Ali Hashmi (LLB, Law with Criminology)
Research has produced hardware, not only papers
MUSICO, led by researchers at the Hong Kong University of Science and Technology and supported under the Government’s aerospace technology special call, is a lightweight observatory designed to detect carbon dioxide and methane point sources from about 400 kilometres up. HKUST describes it as combining that pair of gases at high spectral and spatial resolution in a package smaller than a domestic washing machine. It reached Tiangong aboard Tianzhou-10 in May 2026 and was installed and commissioned with Dr Lai’s participation.[11] The project conveys a clear example of what Hong Kong can contribute in such a way including: instrumentation, data and applied science.
The Hong Kong Space Robotics and Energy Centre was established under InnoHK to support the Chang’E-8 mission. Led by HKUST, and involving teams from the University of Hong Kong, the Chinese University of Hong Kong, the Hong Kong Polytechnic University and City University of Hong Kong, the Centre is developing a multifunctional lunar surface operation robot with wireless charging capability. Government papers describe the robot as intended for scientific exploration, instrument deployment and cooperative operations in extreme lunar conditions, in support of later work toward an international lunar research station. A January 2025 government reply described Chang’E-8 as scheduled for launch in 2028, with the China National Space Administration able to adjust mission details as necessary.[12] The Innovation and Technology Commission has estimated that the Centre will train around 20 PhD students and employ over 70 researchers.[13]
On 12 February 2026, CUHK Sat-1 was launched aboard a Smart Dragon-3 rocket from waters off Guangdong. CUHK describes it as the first Earth-observation satellite funded by the Innovation and Technology Commission, the first such mission in which a local university directly led design, development and application, and the first satellite to deploy a large AI language model on board for near-real-time analysis. It carries a one-metre resolution multispectral camera and is intended to work with the earlier (香港青年科創號 ) that focuses on experimental satellite on environmental monitoring, transport and emergency response.[14]
Hong Kong is not a spacefaring city in China, optimistically it may one day be. They show a research system that can design payloads, fly them and return data. That is the first half of a commercial story. The second half is translation: licensing, contracting, insurance, data governance and capital.
Author: Shan Ali Hashmi (LLB, Law with Criminology)
The work that sits on a solicitor’s desk
The Federation of Hong Kong Industries’ report with City University of Hong Kong, Soaring into Space: Exploring the Industrial Opportunities of the New Space Economy for Hong Kong, released in January 2025, put the same point in industrial language. The opportunity sits as much in satellite data services, logistics, environmental monitoring, new materials, insurance, legal services and project financing as in upstream aerospace. The report identified ten priority areas, including satellite-related industries and services; drones; sensors; precision manufacturing; robotics; new materials; precision and urban agriculture; ecological and environmental technology; space law and international dispute resolution; and financing services for space-related enterprises.[15]
In January 2026 the Chief Executive’s Policy Unit hosted a round table on the space economy and described Hong Kong’s intended role as a hub for finance, insurance, legal and arbitration services, and materials application.[16] Insurance is the most immediate commercial gap. Mid-2026 reporting noted that on the Mainland only third-party liability insurance is mandatory for commercial space activities, while cover for research and development, manufacturing, testing, launch and in-orbit operations remains largely optional. The same reporting cited 2023 industry figures of about US$1 billion in claims against roughly US$550 million in premiums, and described conventional launch premiums in the region of 15 per cent of insured value.[17] Hong Kong will not invent underwriting capacity that London and the continental markets do not already hold. It can become a place where policies are placed, wordings are negotiated under Hong Kong law, and Mainland operators meet international brokers and reinsurers; especially as Hong Kong prepares itself to become a center city for international arbitration, mediation and disputes in Asia and the World.
The legal work will look familiar to practitioners who already advise on aviation, shipping, technology and project finance. Launch services and rideshare contracts. Satellite procurement and payload integration. In-orbit delivery and risk transfer at separation. Third-party liability and the relationship between licensing conditions and commercial indemnities. Spectrum and landing rights. Earth-station arrangements. Data licences for remote-sensing products, including classification, cross-border transfer and end-user restrictions. Intellectual property in payloads designed in Hong Kong and manufactured or launched elsewhere.[18]
In late June 2026 the Space Economy Association (Hong Kong) was launched as an independent membership body, evolving from the Orion Astropreneur Space Academy founded in 2020. China Daily Hong Kong reported about 100 co-founders, more than 150 active members and over 40 industry partners. Bernard Chan, a patron of the Association, put the point lawyers should keep in view: the NewSpace economy opens commercial work for bankers, insurers, accountants and lawyers.[19] Calls for a dedicated space industry office remain an advocacy position. The existing work is already spread across ITIB, CEDB, OFCA, the Investment Corporation and the universities.
Author: Shan Ali Hashmi (LLB, Law with Criminology)
The talent pipeline now starts in ordinary science lessons
A sector that cannot hire will not last. In a May 2026 written reply to LegCo, the Government stated that aerospace education is an integral part of innovation and technology learning in primary and secondary schools. The Primary Science curriculum implemented from the 2025/26 school year includes topics on aerospace and innovative technology and on national and world aerospace development. The updated Junior Secondary Science curriculum introduces “Earth and Space” and may be piloted from 2025/26 before full implementation in 2027/28.[20] Education Bureau Circular Memorandum No. 115/2026 issued supporting video resources aligned to those curricula, including materials that move from basic space science through the Shenzhou-23 mission.[21] On 9 September 2026 the Shenzhou-23 crew delivered a Tiangong Classroom session designated for Hong Kong and Macao students. The Secretary for Education described the broadcast as a step from textbook learning toward direct experience.[22]
Some schools have gone further, taking a lead is ELCHK Lutheran Academy which publishes an aerospace curriculum from Year 4 to Year 9, becoming one of the first primary to secondary-level schools to launch a satellite (in Siberia) as part of their curriculum, having been recorded for recognition in 2025 as one of Hong Kong’s first National Aerospace Specialty Schools by the Chinese Society of Astronautics.[23] The Hong Kong Government aims to go further with the Applied Learning offerings for the 2026-28 cohort already including Aviation Studies, UAV and Low-altitude economy technology, gadgets and more.[24] Combined with the system-wide science curriculum, university payload projects and InnoHK doctoral training, the outline of a pipeline for Hong Kong is logical and visible.
Three dependencies, stated plainly
First, launch and most heavy manufacturing will remain outside Hong Kong. The practical industrial model described by FHKI and by government papers is a division of labour: research, design, instrumentation, data and professional services in Hong Kong; engineering and production depth in the Greater Bay Area; national missions and launch infrastructure on the Mainland. That is a dependency. It is also how MUSICO, CUHK Sat-1 and the Chang’E-8 robot project are already being built.[15]
Second, spectrum, filings and export controls are not local only. A Hong Kong licence does not, by itself, place a spacecraft in an internationally coordinated slot or authorise a launch from a Mainland site or a sea platform. Counsel who treat Cap. 523 as a self-contained code will mislead the client. Counsel who treat it as Hong Kong’s chapter in a longer compliance chain will be useful.[10]
Third, LEO licensing reform is necessary and not sufficient. A streamlined pair of licences will lower friction for operators who already have capital, a payload and a launch booking. The cluster still needs earth-station access, insurers willing to write Hong Kong-law
Author: Shan Ali Hashmi (LLB, Law with Criminology)
wordings, listing practice that understands aerospace issuers, and graduates who can read both an orbital brief and a shareholder agreement. The Communications Authority has already trialled LEO communications from Cape D’Aguilar. That is a start, not a finished market.[7]
What the profession can usefully do
Dr Lai’s flight will be remembered as a civic milestone, and it should be. The quieter milestone is that a Hong Kong-designed camera is now looking down from Tiangong, a Hong Kong-led robot is being designed for the Moon, and a Hong Kong university satellite is in orbit. The law that will govern the next decade of that work is already on the statute book. Cap. 523 and Cap. 106 will need updating in practice, especially for constellations. Data, insurance and listing rules will need the same careful attention that shipping and aviation received in earlier generations.
If the city is serious about a space economy, the legal profession’s contribution is not ceremonial, it can be much bigger affecting licensing, contracts and banking matters, expanding to further industries such as the risks insurable and the disputes seatable, benefitting company secretarial, compliance, banking, and the legal sector. However, how a financial centre joins an industry that, on present projections, may be worth US$1.8 trillion by 2035.[3] Hong Kong does not need to leave the ground to take a share of it. It needs to be the place where the paper, the capital and the data come together, before or when others do.
This article explains publicly stated law and policy. It is not advice on any particular transaction. Licensing practice continues to develop. Readers should check the latest OFCA guidelines and CEDB announcements on the LEO regime before relying on any procedural detail. All sources cited were publicly accessible online as at September 2026.
Notes
[1] HKSAR Government, “CE congratulates Hong Kong payload expert on participating in Shenzhou-23 manned spaceflight mission” (23 May 2026),
https://www.info.gov.hk/gia/general/202605/23/P2026052300221.htm.
[2] RTHK, “Lai an ‘ideal candidate for Shenzhou-23 mission'” (25 May 2026), https://news.rthk.hk/rthk/en/component/k2/1855967-20260525.htm; HKUST, “HKUST-Developed MUSICO Begins In-Orbit Operations on the Tiangong Space Station (Chinese Version Only)” (5 July 2026),
Author: Shan Ali Hashmi (LLB, Law with Criminology)
[3] World Economic Forum and McKinsey & Company, Space: The $1.8 Trillion Opportunity for Global Economic Growth (8 April 2024),
[4] The Chief Executive’s 2025 Policy Address, paras 158-159,
https://www.policyaddress.gov.hk/2025/en/p158.html.
[5] Outer Space Ordinance (Cap. 523), ss 3-6, Hong Kong e-Legislation, https://www.elegislation.gov.hk/hk/cap523.
[6] Office of the Communications Authority, Guidelines for the Application for an Outer Space Licence (GN-8/2017),
https://www.ofca.gov.hk/filemanager/ofca/common/Industry/telecom/outer_space/gn082017. pdf.
[7] TRAAC Paper No. 3/2026, licensing of satellite broadband and LEO operations (3 February 2026),
https://www.ofca.gov.hk/filemanager/ofca/en/content_757/traac3_2026_p.pdf.
[8] OFCA, Outer Space Licences register,
https://www.ofca.gov.hk/en/industry_focus/regulations_licensing/outer_space/index.html.
[9] LegCo Panel on Information Technology and Broadcasting, LC Paper No. CB(2)76/2026(02) (January 2026),
https://www.legco.gov.hk/yr2026/english/panels/itb/papers/itb20260128cb2-76-2-e.pdf.
[10] LegCo LC Paper No. CB(2)1910/2025(01) on satellite filings and launch procedures, https://www.legco.gov.hk/yr2025/english/panels/itb/papers/itb20250919cb2-1910-1-e.pdf.
[11] HKUST School of Engineering, “HKUST Pioneers World-Leading Space Observatory for High-Resolution Greenhouse Gas Monitoring”,
[12] HKSAR Government, “LCQ7: Advancing research and development of aerospace science and technology” (8 January 2025),
https://www.innohk.gov.hk/en/r-d-centres/air-innohk/hong-kong-space-robotics-and-energy-c entre/.
[13] news.gov.hk, “HK reaches for the Moon” (16 March 2025),
https://www.news.gov.hk/eng/2025/03/20250314/20250314_105827_303.html.
Author: Shan Ali Hashmi (LLB, Law with Criminology)
[14] The Chinese University of Hong Kong, “CUHK-developed satellite CUHK Sat-1 launches with mission to advance smart city development” (12 March 2026), https://www.focus.cuhk.edu.hk/en/20260312/cuhk-developed-satellite-launches-with-mission -to-advance-smart-city-development/077-environmental-science-en/.
[15] Federation of Hong Kong Industries, “FHKI Releases Report on New Space Economy” (2 January 2025),
https://www.industryhk.org/en/info/press-releases/new-space-economy-research-report.
[16] South China Morning Post, “Hong Kong eyes slice of booming ‘NewSpace’ economy as professional services hub” (19 January 2026),
[17] South China Morning Post, “The final insurance frontier: Hong Kong spots opportunity in mainland China’s space boom” (28 June 2026),
[18] Sam Ip, “HK should secure a place in nation’s LEO strategy”, China Daily Hong Kong (24 April 2026), https://www.chinadailyhk.com/hk/article/632465.
[19] Jessica Chen, “Space Economy Association up to boost HK’s role in NewSpace”, China Daily Hong Kong (29 June 2026), https://www.chinadailyhk.com/hk/article/635662; Space Economy Association (Hong Kong), https://seahk.org/.
[20] HKSAR Government, “LCQ9: Promoting aerospace science and technology education” (6 May 2026), https://www.info.gov.hk/gia/general/202605/06/P2026050600274.htm.
[21] Education Bureau Circular Memorandum No. 115/2026, Promoting Aerospace Science Education in Primary and Secondary Schools,
https://applications.edb.gov.hk/circular/upload/EDBCM/EDBCM26115E.pdf.
[22] Secretary for Education, “Tiangong Classroom: igniting Hong Kong students’ aerospace dreams” (9 September 2026),
https://www.edb.gov.hk/tc/about-edb/press/insiderperspective/insiderperspective20260909.ht ml.
[23] ELCHK Lutheran Academy, curriculum page, https://www.luac.edu.hk/la-curriculum/.
[24] Education Bureau, Prospectus for Applied Learning (2026-28 Cohort), https://www.edb.gov.hk/attachment/en/curriculum-development/cross-kla-studies/applied-lea rning/ref-and-resources/applied-learning-prospectus/ApL%20Prospectus_2026-28_Final.pdf.
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