What Lessons Has Taiwan Drawn from Hong Kong?
Hong Kong has become a central reference point in Taiwan’s debate over whether Beijing’s promise of autonomy under “One Country, Two Systems” could protect Taiwan’s political institutions, civil liberties and democratic choices.
The debate is not simply about whether Beijing would promise Taiwan a high degree of autonomy. It concerns the legal structure of that promise: who would hold ultimate authority over the arrangement, who could interpret its terms, and what remedies would exist if the central government changed how it was applied?
Hong Kong provides a real-world case study because it operated under “One Country, Two Systems” after the 1997 handover, yet experienced major disputes over political autonomy, civil liberties and national security. Taiwan’s political circumstances are different, so the comparison cannot settle Taiwan’s future. It does, however, give Taiwanese voters and policymakers concrete evidence to consider.
What was “One Country, Two Systems” supposed to guarantee?
The framework was developed under Chinese leader Deng Xiaoping and applied to Hong Kong when British sovereignty ended on 1 July 1997.
Under the Sino-British Joint Declaration and Hong Kong’s Basic Law, the territory became a Special Administrative Region of the PRC. The arrangement promised a high degree of autonomy, with exceptions including defence and foreign affairs, and the continuation of its existing capitalist system and way of life for 50 years after the handover.
Beijing later proposed the same broad framework for Taiwan. In its August 2022 white paper, the PRC government said that after peaceful reunification Taiwan could retain its current social system and enjoy a high degree of autonomy, while allowing for differences between the two sides to continue for an extended period.
Beijing presents the proposal as a way to achieve reunification peacefully while accommodating Taiwan’s existing institutions. Critics focus on whether those institutions would remain protected if the central government and Taiwan’s elected authorities disagreed over the meaning of autonomy.
The distinction is fundamental: a promise of autonomy is not the same thing as an independently enforceable guarantee of autonomy.
Hong Kong’s experience: from the 2019 protests to national security legislation
2019 — Protests begin over extradition legislation
The proposed extradition amendments raised fears that people in Hong Kong could be transferred to mainland China’s legal system. The protests grew into a wider movement over democratic representation, police conduct, civil liberties and the future of Hong Kong’s autonomy. The government formally withdrew the bill in September 2019, but demonstrations continued.
2020 — Beijing imposes the National Security Law
On 30 June 2020, the Standing Committee of China’s National People’s Congress adopted the Hong Kong National Security Law. It criminalized secession, subversion, terrorist activities and collusion with foreign forces in ways defined by the law. The legislation was introduced through the central authorities rather than enacted through Hong Kong’s ordinary local legislative process.
2021 onward — Changes to political participation
Beijing introduced electoral reforms that changed the composition and eligibility rules for Hong Kong’s governing institutions. The Chinese government described these changes as necessary to ensure governance by patriots and protect national security. Critics argued that they substantially narrowed the space for opposition politics and meaningful electoral competition.
2024 — Hong Kong enacts additional national security legislation
Hong Kong enacted its Safeguarding National Security Ordinance under Article 23 of the Basic Law. The legislation expanded the local national security framework. Supporters said it addressed security gaps; critics raised concerns about the breadth of offences and their implications for expression, association and public debate.
The events are interpreted differently by the parties involved. Beijing says the measures restored order, addressed national security threats and preserved the conditions necessary for Hong Kong’s stability. Critics—including international human rights observers—argue that the legal and political changes significantly restricted civil liberties and opposition activity.
A balanced assessment should distinguish the documented legal changes from the competing explanations of why they were necessary and whether their effects were proportionate.
The constitutional question: who has the final word?
This is arguably the most important lesson Taiwan can draw from Hong Kong.
Hong Kong's Basic Law establishes local institutions and protects a high degree of autonomy. But it also places the region within the constitutional order of the PRC.
Under Article 158 of the Basic Law, the Standing Committee of the National People's Congress (NPCSC) has the power to interpret the Basic Law. Article 159 gives the National People's Congress the power to amend it, subject to the stated restriction concerning China's established basic policies regarding Hong Kong.
The 2020 National Security Law added another layer. Article 65 assigns interpretation of that law to the NPCSC. The law also gives central authorities specific national security responsibilities and provides for a central-government office in Hong Kong.
The institutional issue can be summarized as follows:
Question | Hong Kong's legal arrangement |
|---|---|
Who administers ordinary local affairs? | Hong Kong's own executive, legislature and courts, within the Basic Law and applicable national laws. |
Who interprets the Basic Law? | The NPCSC holds the ultimate statutory interpretation power, with local courts exercising interpretive authority within the framework of Article 158. |
Who can amend the Basic Law? | The National People's Congress, under Article 159. |
Who has ultimate authority over national sovereignty and central government responsibilities? | The central authorities of the PRC. |
This does not mean that Hong Kong has no legal autonomy or that every local decision is made in Beijing. It means that Hong Kong's autonomy operates within a constitutional hierarchy in which central institutions retain powers that can affect the boundaries of that autonomy.
The lesson for Taiwan is that the scope of autonomy matters, but so does the distribution of authority to interpret, amend and enforce its protections.
Why Taiwan cannot simply assume that a Hong Kong arrangement would be identical
There are important differences between Hong Kong and Taiwan.
Hong Kong was transferred from British to Chinese sovereignty under an international agreement and subsequently governed as a Special Administrative Region of the PRC. Taiwan, by contrast, has its own elected government, armed forces, constitutional institutions and extensive self-government; the PRC has never administered it.
A Taiwan-specific “One Country, Two Systems” arrangement would therefore require negotiations over questions that do not have direct equivalents in Hong Kong's transition.
These would include:
Whether Taiwan would retain its armed forces and how responsibility for defence would be allocated.
Whether Taiwan's elected president and legislature could continue to operate independently of Beijing.
Whether Taiwan's courts could protect constitutional rights against actions by central authorities.
Whether Taiwan could maintain its existing economic and international relationships.
Whether the terms of an agreement could be amended unilaterally by Beijing.
What legal or political remedies would be available if the two sides disagreed about compliance.
Beijing's 2022 white paper offers a broad proposal rather than a complete, mutually negotiated constitutional settlement specifying every one of these matters. It says that the details of implementation would take account of Taiwan's realities and views, but it does not establish an independent enforcement mechanism acceptable to both sides.
Consequently, the Hong Kong experience provides evidence about the existing framework, but it cannot prove in advance precisely how every possible Taiwan arrangement would operate.
What do Taiwanese people think of “One Country, Two Systems”?
Public opinion provides an important measure of the political context.
According to a survey commissioned by Taiwan's Mainland Affairs Council and conducted by National Chengchi University's Election Study Center from 14–18 August 2025, 83.7% of respondents disagreed with the Chinese Communist Party's “One Country, Two Systems” framework. The telephone survey included 1,075 valid samples of adults aged 20 and older, with a reported sampling error of ±2.99 percentage points at a 95% confidence level.
Taiwan public opinion survey · August 2025
83.7%
Disagreed with the PRC's “One Country, Two Systems” framework.
Source: Taiwan Mainland Affairs Council / National Chengchi University Election Study Center. This is a dated survey result, not a measure of every Taiwanese person's views today.
This result indicates substantial opposition to the proposed framework among respondents in that survey. It does not, by itself, establish that all respondents agree on Taiwan's ultimate legal status, the desirability of formal independence, or the best way to maintain peace.
Some people may reject “One Country, Two Systems” while favouring continued dialogue with Beijing. Others may oppose the framework because they favour Taiwan's formal independence. Still others may prioritize security and the preservation of existing institutions without wishing to make a final decision on Taiwan's constitutional future.
These distinctions matter: rejection of one proposed settlement does not necessarily imply agreement on every alternative.
Beijing's counterargument: why it continues to promote the framework
Beijing presents “One Country, Two Systems” as a way to achieve peaceful reunification while allowing Taiwan to retain a different social and economic system.
In its 2022 white paper, the PRC government argued that the arrangement could accommodate Taiwan's circumstances, provide a high degree of autonomy and preserve its existing system after reunification. It also argued that the experience of Hong Kong and Macao demonstrated the framework's capacity to support stability and development.
From Beijing's perspective, national unity and sovereignty establish the boundaries within which autonomy can operate. National security is treated as a responsibility of the central state, and the central authorities argue that the framework must protect the country's territorial integrity.
Critics question whether the central government could use those same powers to narrow autonomy when political disagreement arises. They point to the national security legislation, the changes to Hong Kong's electoral arrangements and the NPCSC's interpretation powers as evidence that local autonomy can be substantially affected by central decisions.
The disagreement is therefore not only about whether Beijing would initially offer Taiwan autonomy. It is about whether the promised autonomy would remain secure when the central authorities and Taiwan's elected institutions disagreed.
What would a credible autonomy guarantee need to address?
A serious evaluation of any future proposal would need to examine its actual legal terms rather than rely on a slogan.
Independent adjudication
Could a court or tribunal resolve disputes between Taiwan's authorities and the central government without either side having unilateral control over the outcome?
Limits on unilateral amendment
Could Beijing change the arrangement without Taiwan's consent? Would any constitutional or treaty-based safeguards make unilateral changes legally contestable?
Democratic consent
What process would allow Taiwan's population to approve or reject the terms? Would its elected institutions retain meaningful authority after implementation?
Civil and political rights
Would freedom of expression, the press, association, peaceful protest and political opposition be protected by enforceable provisions? What limits could be imposed on national security grounds?
Security and external relations
Who would control defence, law enforcement and international economic relations? Could Taiwan preserve the practical arrangements needed to protect its population and economy?
These are analytical tests, not claims that a future agreement would necessarily succeed or fail. Their purpose is to identify the institutional details that determine whether autonomy is durable, how disputes can be resolved, and what happens when political interests diverge.
The central lesson from Hong Kong
Taiwan's debate over “One Country, Two Systems” is shaped by the gap between a promise of autonomy and the legal powers that govern that promise.
Hong Kong demonstrates that a special administrative region can possess its own institutions and a distinct legal system while remaining subject to the constitutional authority of the PRC's central institutions. The events since 2019—especially the 2020 National Security Law and subsequent political and legal changes—have intensified questions about how autonomy is interpreted and protected. Beijing argues that these measures restored order and safeguarded national security; critics argue that they substantially narrowed the space for civil liberties and political opposition.
Taiwan is not Hong Kong, and the two situations should not be treated as identical. Taiwan has its own history of self-government, democratic institutions and unresolved international status. Nevertheless, Hong Kong provides concrete evidence that any autonomy proposal must be assessed in terms of legal authority, enforceability and the ability of local institutions to withstand political disagreement.
The decisive question is therefore:
If Taiwan accepted “One Country, Two Systems,” what would prevent the terms of autonomy from being reinterpreted or changed by the same central authorities that hold ultimate constitutional power?
Until that question is addressed by specific, credible and mutually accepted legal guarantees, assurances about autonomy remain a proposal to be evaluated—not a guarantee whose future operation can simply be assumed.
By Jugo Ikeji Uju
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