On paper, one country, two systems still guarantees Hong Kong a high degree of autonomy and an unchanged social and economic system until 2047. In practice, what it guarantees depends on whom you ask. The British government says China has breached the treaty behind it. Beijing says the arrangement is a success and could outlast its deadline.
What the treaty promised
Britain and the People’s Republic of China signed the Sino-British Joint Declaration on 19 December 1984. Britain handed over sovereignty on 1 July 1997, and Hong Kong became a Special Administrative Region of China.
The declaration does not use the phrase “one country, two systems”, but the House of Commons Library says the idea underpins it. Hong Kong would sit directly under Beijing’s authority, keep a “high degree of autonomy”, and keep its way of life unchanged for fifty years.
The Brookings Institution summarised the “second system” as three things: a market economy, the rule of law, and political and civil rights for every resident. The Basic Law, Hong Kong’s mini-constitution, went further. It set out reform towards electing the chief executive and the whole legislature by universal suffrage.
Who can enforce it
Nobody, in the formal sense. The treaty has no enforcement or dispute clause. It took effect on 27 May 1985 and both governments lodged it with the UN, and the UK government calls it a legally binding treaty still in force.
Since 1997 the Foreign Secretary has reported to Parliament every six months on how China is keeping it. Britain has formally found one “serious breach”: the removal of the British citizen and bookseller Lee Po from Hong Kong to the mainland in 2015.
Chinese officials see it differently. Foreign Ministry officials said in 2017 that the arrangements were “now history”, and in 2019 a spokesman called Hong Kong’s affairs purely China’s internal business.
What has changed since 2014
Brookings dated Beijing’s growing control to the Umbrella Movement of 2014. It cited the booksellers’ disappearance in 2015 and the expulsion of elected pro-democracy legislators over how they took their oaths. In one oath case, the National People’s Congress Standing Committee issued an interpretation of the Basic Law before a Hong Kong court had heard it.
The larger break came later. After mass protests in 2019, Beijing imposed a national security law in 2020 and changed elections so that only “patriots” could run for the city’s leadership. The BBC reported in 2022 that dozens of groups had disbanded since then, and that Apple Daily and Stand News had closed. Hong Kong fell to 148th in that year’s world press freedom ranking, down nearly 70 places.
The two readings of the same deal
“Most Hong Kong people think that ‘one country, two systems’ has already disappeared,” Ted Hui, a former pro-democracy lawmaker who left the city, told the BBC. The UK Parliament’s Foreign Affairs Committee warned in 2019 that China was moving closer to “one country, one system”.
Beijing’s account is the reverse. Chinese officials called the changes “improvements” to the model and said it could continue past 2047. Dominic Lee, a pro-Beijing lawmaker, told the BBC residents can still voice opinions on anything that does not touch national security.
The economic half of the bargain has also shifted. Hong Kong’s economy was nearly a fifth the size of China’s in 1997 and is now about 2%. Between 2018 and 2021, regional headquarters of international firms fell by nearly 10%, while mainland firms setting up in the city rose by nearly 28%.
The fifty years end in 2047. Both sides now argue about whether the second system has already gone, or whether it will outlive the deadline.
