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Policy Discussion Paper · Macro / FX · March 2026
Institutional Distribution
Icarus Asia · Policy Discussion Paper · March 2026

Assessing Pressures on
Hong Kong's Linked
Exchange Rate System

The HKD peg has held for 40 years. In 2026, two developments demand fresh scrutiny: the first-ever withdrawal from the Exchange Fund for fiscal purposes, and HK$249 billion in Aggregate Balance swings over six weeks that transmitted directly to mortgage and SME funding costs.

CoverageHKMA · Exchange Fund · LERS ClassificationPolicy Discussion Paper DateMarch 2026
The LERS at 40
Key Metrics
The LERS at 40: Four Numbers
Two 2025–2026 developments. One governance question. One market signal.
7.75–7.85
HKD Convertibility Zone
Current band since 2005 · Peg since 1983
HK$150B
Exchange Fund Withdrawal
Feb 2026 Budget · First draw in 40 years
HK$129.4B
Strong-Side AB Injection
May 2025 · US$16.7B equivalent
~50%
Market-Implied Peg Survival
Late 2022 episode · Jermann, Wei, Yue 2025
Source: HKMA; NBER WP 34300 (Jermann, Wei, Yue 2025); Hong Kong Budget 2026-27
Aggregate Balance Cycle
The HK$249B Swing
AB levels at key moments, 2025. Scale: HK$0B – HK$200B.
Pre-intervention baseline
~HK$45B
Early 2025 starting level before strong-side pressure emerged
Strong-side peak (May 2025)
~HK$174B
Post strong-side CU injections · HIBOR fell toward near-zero
Strong-side injection size
HK$129.4B
HKMA sold HKD / bought USD across multiple strong-side CU operations
Post weak-side withdrawal
~HK$55B
Late 2025 stabilisation · HIBOR moved back up materially
Weak-side withdrawal (cumulative)
~HK$120B
Fed-driven USD strength pushed HKD toward weak-side 7.85
HK$0BHK$50BHK$100BHK$150BHK$200B
HK$249B swing. Six weeks. Mortgage holders and SME borrowers felt a significant shift in floating-rate costs. This is the system performing as designed. The question is whether the 1.3% convertibility corridor is still the most appropriate calibration.
Source: HKMA inSight (May 2025); HKMA Analytical Accounts (Feb 2026)
Governance Structure
Exchange Fund: Mandate & Flow
Click any node to expand detail. HK$3,630B in foreign assets.
Exchange Fund · HK$3,630B
Primary Monetary Anchor
Maintain HKD exchange value + financial stability. Secondary: investment return generation.
↓ tap for ordinance detail
Exchange Fund Ordinance (Cap. 66)
The Fund's primary mandate is affecting the exchange value of the HKD. The Feb 2026 transfer is a reclassification of accumulated investment income — the underlying foreign-currency holdings remain intact. The secondary investment function is well-established but subordinate to monetary purposes.
↓
Investment Portfolio · ~4% transferred
Reclassification 2026
HK$150B → Capital Works Reserve Fund · HK$75B/yr · First draw in 40 years
↓ accounting detail
Northern Metropolis · San Tin Technopole
Infrastructure Destination
Technology & innovation infrastructure · Concentration risk question
↓ risk assessment
Accounting Reclassification — Not a Liquidation
The transfer changes beneficial ownership category. The underlying foreign-currency assets remain in place. The concern is institutional coherence, not solvency. Santiago Principles 2 and 4 bear directly on whether the published purpose of the Fund is being maintained.
Concentration Risk Assessment
Targeting the Northern Metropolis creates speculative-return exposure in a single development zone. MPF contribution enhancements, road infrastructure, and housing subsidies would distribute capital more broadly with lower concentration risk and clearer social-return metrics.
↓
Currency Defense Capacity · Intact
Post-Transfer Position
HK$3,480B+ remaining · Fully adequate for peg defense at 7.75–7.85
↓ reserve adequacy
Reserve Adequacy
At HK$3,630B in foreign assets, the HK$150B transfer represents approximately 4% of total holdings. Multiple rounds of 2025-scale interventions (HK$129B strong-side + HK$120B weak-side) remain easily absorbable. The governance question and the solvency question are distinct.
Santiago Principles (2008) — Principles 2 & 4: Sovereign wealth funds are expected to maintain non-correlated external assets that preserve value when the domestic economy deteriorates. Reinvesting surplus returns in domestic infrastructure creates structural correlation between the Fund and the economy it insures.
Source: Exchange Fund Ordinance (Cap. 66); HKMA; IFSWF Santiago Principles (2008); Hong Kong Budget 2026-27
Market-Based Evidence
Option-Implied Peg Credibility
Key structural data points. Bars scaled 0–100% for comparability.
Peg survival probabilityLate 2022, option-implied
~50% risk-neutral

RMB appreciation vs USD12m to Mar 2026
~4.8% annualised
HKD appreciation vs RMBSame period, mechanical
~4–5% implied
Mainland trade shareHK goods/services trade
>50% of total

USD/HKD 25-delta risk-reversal: persistent positive bias — market prices more asymmetric concern about HKD weakness than strength. Widened during 2022 and 2025 stress episodes.
On the Jermann-Wei-Yue model: The authors are not prescribing regime change — they are estimating what the market believes. The skew reflects a tail, not the central expectation. This is how most managed exchange-rate regimes are priced.
Source: NBER WP 34300 (Jermann, Wei, Yue 2025); Bloomberg; HKMA; Icarus Asia estimates for illustrative scaling
Hypothetical Scenario · Strictly Analytical
Four Transmission Channels
If the convertibility zone were widened. No proposal exists.
Interest Rate Channel
↓ Volatility
Wider zone reduces AB management frequency before outer limits hit. HIBOR amplitude would likely be lower — fewer forced overshoots.
REER / Competitiveness
↓ Misalignment
HKD could partially depreciate during RMB appreciation episodes. Would cushion the competitiveness drag that currently accumulates in tourism and services.
Carry Trade Channel
↓ Speculation
Genuine two-way FX risk introduced. The near-guaranteed 7.85 weak-side exit that makes carry positioning attractive would be replaced by a more distant limit.
Credibility Channel
⚠ Uncertain
40 years of unchanged parameters IS the credibility. Modifying a fixed commitment risks signalling weakness. Market perception of motivation matters critically. Most uncertain channel.
Mechanical case for wider band: Each of the first three channels operates through identifiable, testable mechanisms. HIBOR amplitude reduction under a wider zone is the most robust — directly analogous to how the 2005 band expansion operated relative to the pre-2005 one-sided peg. The carry and REER channels are secondary but real.
Hypothetical analysis only. HKMA CE Eddie Yue (Jan 2025): "we have no intention, and we see no need to change the Linked Exchange Rate System." No official proposal exists.
Icarus Asia · House View
Three-Tier Policy Recommendation
Ordered by priority and feasibility. March 2026.
Tier 1 · Maintain

Maintain current LERS architecture. HKMA has demonstrated operational capacity across two-sided intervention cycles. The reserve base (~HK$3,630B) remains adequate after the Feb 2026 transfer. This is the most defensible position and requires no policy action.

Tier 2 · Improve Governance

Improve Exchange Fund governance. Formal published criteria for when draws are appropriate. Minimum reserve adequacy thresholds consistent with Santiago Principles 2 and 4. Legislative Council notification requirements. Explicit guidelines on domestic reinvestment limits. These reforms address the institutional coherence question without touching the peg itself.

Tier 3 · Enhance Communication

Enhance HKMA communication. Build on the inSight commentary model (May 2025). Reduce space for speculation about structural weakness during stress episodes. Transparency is itself a credibility tool — the system's mechanics are well-understood by practitioners but poorly communicated to the public.

Key conclusion: Exchange Fund governance improvements and enhanced HKMA communication represent higher-priority, lower-risk policy actions than structural modification of the peg's parameters. Any such modification would require a level of consensus, sequencing, and communication that current conditions do not support.
Source: Icarus Asia Policy Discussion Paper, March 2026. Submitted to: Journal of International Money and Finance | Pacific-Basin Finance Journal.
Section 1 — Overview

The LERS at 40:
Two Developments That Demand Scrutiny

Hong Kong's Linked Exchange Rate System has maintained HKD/USD convertibility at 7.75–7.85 since 2005 — and the peg itself since 1983. Four decades without structural modification. Two 2025–2026 developments renew analytical interest.

First: the February 2026 Budget announced a transfer of HK$150B from the Exchange Fund to the Capital Works Reserve Fund over two fiscal years — HK$75B per year — to fund Northern Metropolis infrastructure. This is the first such withdrawal in the Fund's 40-year history.

Second: 2025 two-sided FX interventions produced Aggregate Balance swings of approximately HK$249B over six weeks, generating pronounced HIBOR volatility that fed directly through to mortgage and SME funding costs. The system worked exactly as designed. Whether the current design remains optimal is the question this paper examines.

Neither development threatens the peg in the near term. Both raise questions — the governance question and the calibration question — that merit structured analytical treatment now, before the next stress episode.
Section 2 — The 2025 Intervention Cycle

HK$249 Billion.
Six Weeks. As Designed.

May 2025: capital inflows pushed HKD to the strong-side 7.75 convertibility limit. The HKMA executed strong-side Currency Board operations multiple times, selling HK$129.4B (US$16.7B equivalent) and purchasing USD. The Aggregate Balance surged from approximately HK$45B to HK$174B. Overnight HIBOR fell sharply toward near-zero.

Within weeks, the direction reversed. Fed-driven USD strengthening pushed HKD toward the weak-side 7.85 limit. The HKMA executed weak-side CU operations multiple times, cumulatively withdrawing approximately HK$120B by late 2025. The AB stabilised at HK$50–80B. HIBOR moved back up materially.

The combined AB swing across the episode was ~HK$249B — in six weeks. Mortgage holders on floating-rate HIBOR-linked loans and SME borrowers on working-capital facilities experienced a significant shift in their funding costs within the same window.

This is not a failure of the LERS — it is the system performing as designed. The Currency Board mechanism transmits exchange-rate pressures into domestic liquidity. The debate is whether the 1.3% convertibility corridor remains the most appropriate calibration given the structure of the modern HK economy.
Section 3 — The 2026 Exchange Fund Transfer

A Governance Question,
Not a Solvency Question

At approximately HK$3,630B in foreign assets, the HK$150B transfer represents roughly 4% of the Exchange Fund's total holdings. Ample capacity for currency defense remains. The reserve base is not the issue. The institutional coherence question is.

The Santiago Principles (2008) — specifically Principle 2 on policy purpose clarity and Principle 4 on transparency of objectives — expect sovereign wealth funds to maintain non-correlated external assets that preserve value when the domestic economy deteriorates. Reinvesting accumulated investment income into domestic infrastructure creates structural correlation between the Fund's secondary portfolio and the economy it is meant to insure against.

Defenders of the transfer — including LERS architect John Greenwood — argue this is legitimate reallocation from financial to productive assets, and that the underlying foreign-currency holdings remain intact. Click any node in the diagram to examine the structural detail.

Icarus Asia Analytical Note

The accounting classification matters: this is a reclassification of accumulated investment income, not a liquidation of primary reserves. The beneficial ownership category changes; the foreign-currency holdings do not leave the consolidated Exchange Fund position. The debate turns on expected returns to Northern Metropolis infrastructure versus the option value of maintaining the external buffer uncorrelated with local economic conditions.

Section 4 — Market-Based Credibility Evidence

What Options Markets
Imply About Regime Risk

Jermann, Wei, and Yue (2025, NBER Working Paper No. 34300) applied a structural asset-pricing model to HKD FX options to estimate two things: a "shadow" HKD value absent HKMA intervention, and the risk-neutral probability that the peg persists. Their methodology extracts forward-looking market belief from the options surface.

In late 2022 — when aggressive Fed tightening combined with a widening USD-RMB rate gap — the implied survival probability approached ~50%. Roughly equal market-assigned probabilities of regime persistence versus modification. The 2025 two-sided intervention cycle produced qualitatively similar dynamics in the options surface.

The 25-delta risk-reversal on USD/HKD options has maintained a persistent positive bias throughout this period — the market consistently prices more asymmetric concern about HKD weakness than strength. During peak stress in both 2022 and 2025, this skew widened further.

Separately: with Mainland China now accounting for more than 50% of Hong Kong's goods and services trade, and RMB appreciating approximately 4.8% against USD in the 12 months to March 2026, HKD has mechanically appreciated 4–5% against its primary trading partner's currency. This is the REER misalignment argument in its most concrete form.

The Jermann-Wei-Yue model does not prescribe regime change. It estimates what the market believes. A 50% option-implied survival probability during stress is a tail signal, not a central expectation. This is how most managed exchange-rate regimes are priced at the margin.
Section 5 — Hypothetical Analysis

Could a Wider Band
Reduce Volatility?

Note: This is a purely hypothetical analytical exercise. No official proposal exists. HKMA CE Eddie Yue stated January 2025: "we have no intention, and we see no need to change the Linked Exchange Rate System."

A hypothetical wider zone — say 7.70–7.90 or 7.60–8.00 — would transmit through four distinct channels. The interest-rate channel is the most mechanically robust: a wider zone delays the point at which HKMA must intervene, reducing the frequency of AB overshoots and therefore HIBOR amplitude. The 2025 episode is a direct illustration — a wider corridor would have allowed more of the capital-flow pressure to clear before triggering Currency Board operations.

The REER and carry-trade channels are secondary but real. The credibility channel — whether a widening could reduce the binary tail risk the Jermann-Wei-Yue options model captures — is the most analytically uncertain. Use the toggle above the scenario cards to examine both sides of this argument.

Greenwood's counterargument stands on its own terms: the constraint is the point. 40 years of unchanged parameters is a genuine institutional asset. Singapore's managed float is an imperfect precedent — it was designed as a float from inception. Modifying the rules of a 40-year fixed commitment is qualitatively different from operating within a float that was always managed.
Section 6 — Policy Conclusions

Three Tiers.
One Clear Priority Order.

The analytical case resolves into three tiers, ordered by priority and feasibility. Maintaining the current LERS architecture is the most defensible position — HKMA has demonstrated operational capacity across multiple stress episodes, and the reserve base remains adequate after the 2026 transfer. This requires no policy action.

Exchange Fund governance reform is the highest-priority actionable change. Formal published criteria for when draws are appropriate; minimum reserve adequacy thresholds consistent with Santiago Principles 2 and 4; LegCo notification requirements; explicit domestic reinvestment limits. These reforms address the institutional coherence question raised by the 2026 transfer without modifying the peg's structural parameters.

Enhanced HKMA communication — building on the inSight commentary model from May 2025 — reduces the space for speculation about structural weakness during stress episodes. Transparency is itself a credibility tool. The mechanics of the Currency Board are well understood by practitioners; they are poorly communicated to the public and the media, which amplifies perceived volatility.

The key conclusion: governance improvements and communication enhancements are higher-priority, lower-risk actions than any structural modification to the peg's parameters. Any such modification would require a level of consensus, careful sequencing, and communication management that current conditions do not support.

First published by Icarus Asia · Original publish date:

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