Hong Kong's autonomy: promise and limits

Under the 1984 Sino-British Joint Declaration and the 1990 Basic Law, Hong Kong was promised a ‘high degree of autonomy’ for 50 years after 1997. During this time, the territory would retain its legal, social, and economic systems, as well as its way of life. Hong Kong has its own governing institutions, including a legislature ‘constituted by elections’ and a Chief Executive selected by local ‘consultation or election’. Yet, defence and foreign affairs remain China’s exclusive competences. China’s supreme legislature similarly retains the power to interpret the Basic Law and apply national law directly to Hong Kong. Promises for democracy were framed as long-term aspirations – ‘the ultimate aim’ – rather than enforceable rights.

Why Hong Kong's autonomy still matters

Hong Kong’s autonomy is often cited as a possible model for resolving other territorial disputes such as Western Sahara and Gaza. Compared to other similar examples, the Hong Kong model remains distinctive: (1) It is an autonomy that prioritised separating Hong Kong’s social-economic systems from China, rather than establishing genuine political self-government; (2) It was guaranteed by an elaborate international treaty that provided no mechanism for legal dispute settlement or third-party supervision; (3) Negotiations were conducted bilaterally and in secrecy between two permanent members of the UN Security Council, but acquiesced by both the local and international communities.

Hong Kong, thus, represents a ‘top-down’ autonomy that prioritised state-to-state dispute resolution over freedom of choice for the local population. More broadly, it marked an early moment in a wider shift in the interpretation of self-determination: from an external right to determine political status, to an internal power-sharing arrangement within a state. Sometimes described as ‘palliative self-determination’, this shift illustrates the elasticity of the concept of self-determination. Recent UN Security Council practice reflects this trend. In October 2025, Resolution 2797 endorsed Morocco’s autonomy proposal for Western Sahara as a ‘realistic, serious, and credible’ basis for resolving the conflict, departing from the Council’s earlier insistence on a referendum. Shortly after, Resolution 2803 endorsed elements of Trump’s plan for Gaza, including the establishment of a ‘special economic zone’, but without reference to Palestinians’ right to self-determination.

The Hong Kong lessons: a cautionary tale?

The ambiguity of autonomy in Hong Kong was strategically used to soften the domestic and international divides, while providing the territorial transfer with internal and external legitimacy. Yet, ambiguity cuts both ways. Since Hong Kong’s autonomy was never grounded in meaningful local consent, a legitimacy gap has persisted, particularly among generations born after the handover. Rather than resolving questions of identity and belonging, limited self-government intensified them. As rising political aspirations collided with Beijing’s long-standing suspicion that democracy could lead to secession, Hong Kong has experienced recurring cycles of protest and repression. Autonomy, thus, has postponed rather than resolved the underlying conflict, often at a growing social and economic cost.

Here, the experience in Hong Kong serves as a reminder that a discursive use of autonomy does not automatically generate domestic legitimacy. When autonomy is perceived as a top-down imposition, it struggles to command lasting domestic support. Legal guarantees and economic benefits may buy time, but they do not eliminate underlying political aspirations. Instead, autonomy can sharpen a community’s sense of political distinctiveness, revive demands for self-determination, and demand continuous political and coercive intervention, often at the expense of the state’s resources and international legitimacy.

The second lesson concerns the relationship between power and international law. Hong Kong shows that guarantee by a treaty alone is insufficient. This is because international law merely provides the vocabulary, but power ultimately determines its meaning. What enabled autonomy to function as a diplomatic bridge also made it fragile once political conditions changed internally or externally. ‘Autonomy’ therefore does not guarantee meaningful political self-government. It may become a façade to entrench state and corporate interests to the disadvantage of the local population, particularly when independent supervision and the local rule of law are weak or absent.

None of this, however, makes self-determination meaningless. The final lesson Hong Kong shows us is that legal language matters; so much so that even Great Powers must invoke it to claim domestic and international legitimacy. Thus, self-determination is still a useful discourse to empower excluded communities to mobilise politically, articulate demands, and seek international attention. In this sense, self-determination remains a language that can be used by the weak, as well as the strong.

A fragile structure

Hong Kong shows that territorial autonomy designed for a people, rather than by them, is structurally fragile. When autonomy serves primarily to reconcile the interests of states, it risks becoming a temporal rather than a durable settlement if grounded only on the local community’s implicit consent. With self-determination conflicts on the rise, Hong Kong reminds us that autonomy should be judged not by how elegant it appears in theory or in treaties, but by how effectively it was entrenched within the local community in practice.