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"One country, two systems" is a constitutional principle of the
People's Republic of China China, officially the People's Republic of China (PRC), is a country in East Asia. With population of China, a population exceeding 1.4 billion, it is the list of countries by population (United Nations), second-most populous country after ...
(PRC) describing the governance of the special administrative regions of
Hong Kong Hong Kong)., Legally Hong Kong, China in international treaties and organizations. is a special administrative region of China. With 7.5 million residents in a territory, Hong Kong is the fourth most densely populated region in the wor ...
and
Macau Macau or Macao is a special administrative regions of China, special administrative region of the People's Republic of China (PRC). With a population of about people and a land area of , it is the most List of countries and dependencies by p ...
.
Deng Xiaoping Deng Xiaoping also Romanization of Chinese, romanised as Teng Hsiao-p'ing; born Xiansheng (). (22 August 190419 February 1997) was a Chinese statesman, revolutionary, and political theorist who served as the paramount leader of the People's R ...
developed the one country, two systems concept. This constitutional principle was formulated in the early 1980s during negotiations over Hong Kong between
China China, officially the People's Republic of China (PRC), is a country in East Asia. With population of China, a population exceeding 1.4 billion, it is the list of countries by population (United Nations), second-most populous country after ...
and the
United Kingdom The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Northwestern Europe, off the coast of European mainland, the continental mainland. It comprises England, Scotlan ...
. It provided that there would be only
one China ''One China'' is a phrase describing the relationship between the People's Republic of China (PRC) based on mainland China, and the Republic of China (ROC) based on the Taiwan Area. "One China" asserts that there is only one ''de jure'' Ch ...
, 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 Taiwan, officially the Republic of China (ROC), is a country in East Asia. The main geography of Taiwan, island of Taiwan, also known as ''Formosa'', lies between the East China Sea, East and South China Seas in the northwestern Pacific Ocea ...
.


Background

Deng Xiaoping Deng Xiaoping also Romanization of Chinese, romanised as Teng Hsiao-p'ing; born Xiansheng (). (22 August 190419 February 1997) was a Chinese statesman, revolutionary, and political theorist who served as the paramount leader of the People's R ...
developed the principle of one country, two systems in relation to Hong Kong, Macau, and Taiwan.
Hong Kong Hong Kong)., Legally Hong Kong, China in international treaties and organizations. is a special administrative region of China. With 7.5 million residents in a territory, Hong Kong is the fourth most densely populated region in the wor ...
and
Macau Macau or Macao is a special administrative regions of China, special administrative region of the People's Republic of China (PRC). With a population of about people and a land area of , it is the most List of countries and dependencies by p ...
had been colonized by European powers and
Taiwan Taiwan, officially the Republic of China (ROC), is a country in East Asia. The main geography of Taiwan, island of Taiwan, also known as ''Formosa'', lies between the East China Sea, East and South China Seas in the northwestern Pacific Ocea ...
remained under
Kuomintang The Kuomintang (KMT) is a major political party in the Republic of China (Taiwan). It was the one party state, sole ruling party of the country Republic of China (1912-1949), during its rule from 1927 to 1949 in Mainland China until Retreat ...
Control at the end of the
Chinese Civil War The Chinese Civil War was fought between the Kuomintang-led Nationalist government, government of the Republic of China (1912–1949), Republic of China and the forces of the Chinese Communist Party (CCP). Armed conflict continued intermitt ...
.


In the context of Hong Kong

Hong Kong was a
colony A colony is a territory subject to a form of foreign rule, which rules the territory and its indigenous peoples separated from the foreign rulers, the colonizer, and their ''metropole'' (or "mother country"). This separated rule was often orga ...
of the United Kingdom, ruled by a
governor A governor is an politician, administrative leader and head of a polity or Region#Political regions, political region, in some cases, such as governor-general, governors-general, as the head of a state's official representative. Depending on the ...
appointed by the monarch of the United Kingdom, for 156 years from 1841 (except for four years of Japanese occupation during
WWII World War II or the Second World War (1 September 1939 – 2 September 1945) was a World war, global conflict between two coalitions: the Allies of World War II, Allies and the Axis powers. World War II by country, Nearly all of the wo ...
) 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. In Deng's view, these destructive forces might create instability both prior to, and as well as after, Hong Kong's return to China. Deng repeatedly stressed that the central government would need to intervene in Hong Kong affairs from time-to-time. 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. 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. 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 Capitalism is an economic system based on the private ownership of the means of production and their use for the purpose of obtaining profit. This socioeconomic system has developed historically through several stages and is defined by ...
economic system An economic system, or economic order, is a system of production, resource allocation and distribution of goods and services within an economy. It includes the combination of the various institutions, agencies, entities, decision-making proces ...
and own currency (the Hong Kong dollar),
legal system A legal system is a set of legal norms and institutions and processes by which those norms are applied, often within a particular jurisdiction or community. It may also be referred to as a legal order. The comparative study of legal systems is th ...
, 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). During the drafting of the Basic Law, Deng stated that universal suffrage and Western political systems were not appropriate for Hong Kong. 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. The Chinese
renminbi The renminbi ( ; currency symbol, symbol: Yen and yuan sign, ¥; ISO 4217, ISO code: CNY; abbreviation: RMB), also known as the Chinese yuan, is the official currency of the China, People's Republic of China. The renminbi is issued by the Peop ...
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 () 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 Cantonese is the traditional prestige variety of Yue Chinese, a Sinitic language belonging to the Sino-Tibetan language family. It originated in the city of Guangzhou (formerly known as Canton) and its surrounding Pearl River Delta. While th ...
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 Universal suffrage or universal franchise ensures the right to vote for as many people bound by a government's laws as possible, as supported by the " one person, one vote" principle. For many, the term universal suffrage assumes the exclusion ...
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 Macau or Macao is a special administrative regions of China, special administrative region of the People's Republic of China (PRC). With a population of about people and a land area of , it is the most List of countries and dependencies by p ...
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 A legal system is a set of legal norms and institutions and processes by which those norms are applied, often within a particular jurisdiction or community. It may also be referred to as a legal order. The comparative study of legal systems is th ...
(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. 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 passport The Macao Special Administrative Region of the People's Republic of China passport (; ) is a passport issued to Nationality law of the People's Republic of China, Chinese citizens who are permanent residents of the Chinese Special administrative ...
s 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, but the government of Taiwan has consistently rejected the proposal . According to polls conducted by Taiwan's Mainland Affairs Council in 2025, over 80 percent of Taiwan reject "one country, two systems".


Application to Hong Kong and Macau

Chinese
paramount leader Paramount leader () is an informal term for the most important Supreme leader, political figure in the China, People's Republic of China (PRC). The paramount leader typically controls the Chinese Communist Party (CCP) and the People's Liberatio ...
Deng Xiaoping Deng Xiaoping also Romanization of Chinese, romanised as Teng Hsiao-p'ing; born Xiansheng (). (22 August 190419 February 1997) was a Chinese statesman, revolutionary, and political theorist who served as the paramount leader of the People's R ...
proposed the principle during negotiation with British
prime minister A prime minister or chief of cabinet is the head of the cabinet and the leader of the ministers in the executive branch of government, often in a parliamentary or semi-presidential system. A prime minister is not the head of state, but r ...
Margaret Thatcher Margaret Hilda Thatcher, Baroness Thatcher (; 13 October 19258 April 2013), was a British stateswoman who served as Prime Minister of the United Kingdom from 1979 to 1990 and Leader of the Conservative Party (UK), Leader of th ...
over the expiration of the United Kingdom's lease on the
New Territories The New Territories (N.T., Traditional Chinese characters, Chinese: ) is one of the three areas of Hong Kong, alongside Hong Kong Island and Kowloon. It makes up 86.2% of Hong Kong's territory, and contains around half of the population of H ...
(including New Kowloon) of Hong Kong in 1997. The same principle was proposed in talks with
Portugal Portugal, officially the Portuguese Republic, is a country on the Iberian Peninsula in Southwestern Europe. Featuring Cabo da Roca, the westernmost point in continental Europe, Portugal borders Spain to its north and east, with which it share ...
about Macau. 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: 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 The Constitution of the People's Republic of China is the supreme law of the People's Republic of China (PRC). In September 1949, the first plenary session of the Chinese People's Political Consultative Conference adopted the Common Progr ...
, 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 The National People's Congress (NPC) is the highest organ of state power of the People's Republic of China (PRC). The NPC is the only branch of government in China, and per the principle of unified power, all state organs from the Sta ...
in light of the specific conditions. 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.


Framework

The two SARs of Hong Kong and Macau are responsible for their domestic affairs including, but not limited to, the
judiciary The judiciary (also known as the judicial system, judicature, judicial branch, judiciative branch, and court or judiciary system) is the system of courts that adjudicates legal disputes/disagreements and interprets, defends, and applies the law ...
and courts of final appeal, immigration and customs, public finance, currencies and
extradition In an extradition, one Jurisdiction (area), jurisdiction delivers a person Suspect, accused or Conviction, convicted of committing a crime in another jurisdiction, into the custody of the other's law enforcement. It is a cooperative law enforc ...
. 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. Hong Kong continues using English common law while Macau continues using the Portuguese civil law system.


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" instead of "Hong Kong" or "Macau"/"Macao", as stipulated several times under Chapter VII ("External Affairs") of both regions' Basic Laws. 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. 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".


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." 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. 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. 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." 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. In July 2022, Leung Chun-ying, former chief executive, said that he expected the system to be extended past 2047. On 1 July 2022, during a visit to Hong Kong,
General Secretary of the Chinese Communist Party The general secretary of the Central Committee of the Chinese Communist Party ( zh, s=中国共产党中央委员会总书记, p=Zhōngguó Gòngchǎndǎng Zhōngyāng Wěiyuánhuì Zǒngshūjì) is the leader of the Chinese Communist Part ...
Xi Jinping Xi Jinping, pronounced (born 15 June 1953) is a Chinese politician who has been the general secretary of the Chinese Communist Party (CCP) and Chairman of the Central Military Commission (China), chairman of the Central Military Commission ...
made a promise that the system is a long-term policy. In February 2024, Xia Baolong said that the system would be kept permanently.


Implementation in Hong Kong


Degree of autonomy

As a British colony, Hong Kong was neither democratic nor autonomous. 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. In the year after the handover, surveys showed high levels of satisfaction with Beijing's hands-off relationship with the former colony. 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 A white paper is a report or guide that informs readers concisely about a complex issue and presents the issuing body's philosophy on the matter. It is meant to help readers understand an issue, solve a problem, or make a decision. Since the 199 ...
describing its view of comprehensive jurisdiction over Hong Kong. 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. 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. 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" in all non-international primary and secondary schools to strengthen "national identity awareness and nurture patriotism towards China". 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. This announcement led to 10 days of protests, with up to 120,000 protesters each day, due to concerns of Hong Kong losing autonomy. 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". Furthermore, in August 2017, Christine Choi Yuk-Lin was appointed by the government as the under-secretary of the Education Bureau. 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 The Communist Party of China (CPC), also translated into English as Chinese Communist Party (CCP), is the founding and One-party state, sole ruling party of the People's Republic of China (PRC). Founded in 1921, the CCP emerged victorious in the ...
general secretary Secretary is a title often used in organizations to indicate a person having a certain amount of authority, Power (social and political), power, or importance in the organization. Secretaries announce important events and communicate to the org ...
Xi Jinping Xi Jinping, pronounced (born 15 June 1953) is a Chinese politician who has been the general secretary of the Chinese Communist Party (CCP) and Chairman of the Central Military Commission (China), chairman of the Central Military Commission ...
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 "Mainland China", also referred to as "the Chinese mainland", is a Geopolitics, geopolitical term defined as the territory under direct administration of the People's Republic of China (PRC) in the aftermath of the Chinese Civil War. In addit ...
, one in
Thailand Thailand, officially the Kingdom of Thailand and historically known as Siam (the official name until 1939), is a country in Southeast Asia on the Mainland Southeast Asia, Indochinese Peninsula. With a population of almost 66 million, it spa ...
, 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. 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. 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. 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.


Hong Kong National Party ban

On 17 July 2018, the
Hong Kong Police Force The Hong Kong Police Force (HKPF) is the primary law enforcement, investigative agency, and largest Hong Kong Disciplined Services, disciplined service under the Security Bureau (Hong Kong), Security Bureau of Hong Kong. Pursuant to the one c ...
served the party convener a notice under the Societies Ordinance, seeking to ban the Hong Kong National Party (HKNP) for
sedition Sedition is overt conduct, such as speech or organization, that tends toward rebellion against the established order. Sedition often includes subversion of a constitution and incitement of discontent toward, or insurrection against, establ ...
, 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. 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.


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. 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. After a visit to Bangkok, Mallet was denied a working visa by the Hong Kong government. 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. 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".


Extradition bill and Hong Kong 2019–2020 protests

In April 2019, an extradition bill was proposed in Hong Kong inciting mass protests. The new law identifies that those who are suspects of serious crimes could be sent to China. This was initiated due to a murder suspect fleeing from Taiwan to Hong Kong in 2018. 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. 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. Despite this, fear of the loss of Hong Kong autonomy remains. Protests continued until the outbreak of the
COVID-19 pandemic The COVID-19 pandemic (also known as the coronavirus pandemic and COVID pandemic), caused by severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), began with an disease outbreak, outbreak of COVID-19 in Wuhan, China, in December ...
in January 2020, and are predicted to continue once the pandemic is under control in Hong Kong.


2020 national security legislation

A draft national security bill was submitted on 22 May 2020 to China's national parliament, the National People's Congress. 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. 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. 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. On 30 May 2020, the
president of the United States The president of the United States (POTUS) is the head of state and head of government of the United States. The president directs the Federal government of the United States#Executive branch, executive branch of the Federal government of t ...
, Donald J. Trump, in a
White House The White House is the official residence and workplace of the president of the United States. Located at 1600 Pennsylvania Avenue Northwest (Washington, D.C.), NW in Washington, D.C., it has served as the residence of every U.S. president ...
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", 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.


Implementation in Macau


Macau and mainland China relations

Macau has not seen outbreaks of protests and civil unrest that have occurred in Hong Kong. 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. 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 Xi Jinping, pronounced (born 15 June 1953) is a Chinese politician who has been the general secretary of the Chinese Communist Party (CCP) and Chairman of the Central Military Commission (China), chairman of the Central Military Commission ...
'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". 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. 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

The PRC government was also proposed the application of the one country, two systems principle for
Taiwan Taiwan, officially the Republic of China (ROC), is a country in East Asia. The main geography of Taiwan, island of Taiwan, also known as ''Formosa'', lies between the East China Sea, East and South China Seas in the northwestern Pacific Ocea ...
, but the Taiwanese government has refused this suggestion. It has been claimed that the system was originally designed for Taiwan 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. A new policy based on the 1992 Consensus was emphasised during the Pan-Blue visits to mainland China in April 2005 as well as subsequent major cross-strait exchanges under President
Ma Ying-jeou Ma Ying-jeou ( zh, t=馬英九; pinyin: ''Mǎ Yīngjiǔ''; ; born 13 July 1950) is a Taiwanese politician, lawyer, and legal scholar who served as the sixth president of the Republic of China from 2008 to 2016. A member of the Kuomintang (KMT ...
, whose pro-unification
Kuomintang The Kuomintang (KMT) is a major political party in the Republic of China (Taiwan). It was the one party state, sole ruling party of the country Republic of China (1912-1949), during its rule from 1927 to 1949 in Mainland China until Retreat ...
(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" () framework to govern cross-strait relations, though this term did not become widely adopted. In January 2019, CCP General Secretary
Xi Jinping Xi Jinping, pronounced (born 15 June 1953) is a Chinese politician who has been the general secretary of the Chinese Communist Party (CCP) and Chairman of the Central Military Commission (China), chairman of the Central Military Commission ...
announced an open letter to Taiwan proposing a one country, two systems formula for eventual unification. President
Tsai Ing-wen Tsai Ing-wen (; pinyin: ''Cài Yīngwén''; born 31 August 1956) is a Taiwanese politician and legal scholar who served as the seventh president of the Republic of China (Taiwan) from 2016 to 2024. A member of the Democratic Progressive Party ...
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. 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. 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. In 2021, the KMT platform under newly elected chairman Eric Chu also continued to include the 1992 Consensus while rejecting one country, two systems. 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" () in a pun on "one country, two systems" (), 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
"Three Views of Local Consciousness in Hong Kong"
. ''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 Tibet (; ''Böd''; ), or Greater Tibet, is a region in the western part of East Asia, covering much of the Tibetan Plateau and spanning about . It is the homeland of the Tibetan people. Also resident on the plateau are other ethnic groups s ...
, 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. In 2012, Dalai Lama mentioned again that the Seventeen Point Agreement was signed in the spirit of "one country, two systems".


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 The Israeli–Palestinian conflict is an ongoing military and political conflict about Territory, land and self-determination within the territory of the former Mandatory Palestine. Key aspects of the conflict include the Israeli occupation ...
. North Korea suggests the "one country, two systems" formula to bring about
Korean reunification Korean reunification is the hypothetical unification of North Korea and South Korea into a singular Korean sovereign state. The process towards reunification of the peninsula while still maintaining two opposing regimes was started by the Ju ...
, through a confederation of two systems within one country. 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. 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 Northern Ireland ( ; ) is a Countries of the United Kingdom, part of the United Kingdom in the north-east of the island of Ireland. It has been #Descriptions, variously described as a country, province or region. Northern Ireland shares Repub ...
after
Brexit Brexit (, a portmanteau of "Britain" and "Exit") was the Withdrawal from the European Union, withdrawal of the United Kingdom (UK) from the European Union (EU). Brexit officially took place at 23:00 GMT on 31 January 2020 (00:00 1 February ...
. 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 Dublin is the capital and largest city of Republic of Ireland, Ireland. Situated on Dublin Bay at the mouth of the River Liffey, it is in the Provinces of Ireland, province of Leinster, and is bordered on the south by the Dublin Mountains, pa ...
demanding that the frontier remain completely open, to avoid endangering the
peace process A peace process is the set of political sociology, sociopolitical negotiations, agreements and actions that aim to solve a specific armed conflict. Definitions Prior to an armed conflict occurring, peace processes can include the prevention of ...
.Irish minister suggests "Hong Kong solution" for post-Brexit Northern Ireland
, AFP, ''
South China Morning Post The ''South China Morning Post'' (''SCMP''), with its Sunday edition, the ''Sunday Morning Post'', is a Hong Kong-based English-language newspaper owned by Alibaba Group. Founded in 1903 by Tse Tsan-tai and Alfred Cunningham, it has remaine ...
'', 22 November 2017


See also

* 1992 consensus *
Administrative divisions of the People's Republic of China The administrative divisions of China have consisted of several levels since 1412, due to mainland China's large population and geographical area. In the People's Republic of China, the constitution provides for three levels of government. ...
* Autonomous administrative division * Democracy in China * Federacy * Hong Kong–Mainland conflict * Law of Hong Kong * One country, one system * One country, two governments * One Country Two Systems Research Institute * Special Economic Zone


Notes


References


Further reading

* {{Cross-Strait relations Federalism in China Politics of Hong Kong Politics of the People's Republic of China Law of Hong Kong Government of Macau Politics of Macau Government of Hong Kong Law of Macau Ideology of the Chinese Communist Party Chinese unification