Hong Kong's Trade Union Ordinance: A New Era of Suppression

The Ordinance was gazetted on July 4, 2025, after passing without amendment through Hong Kong’s opposition-free Legislative Council, and will take effect in January 2026. Its passage follows more than two months of speculation since the Trade Union (Amendment) Bill was first introduced on April 17, 2025, with the bill seeking to ban union affiliation with foreign ‘forces’ and expand the government’s powers to prohibit union activities and deregister unions.

Framed as a tool to counter ‘soft resistance,’ the law imposes broad and vague restrictions that weaponise national security rhetoric to dismantle independent labour organising. Under the amended ordinance, trade unions can now be denied registration on undefined national security grounds without the right to appeal beyond an expensive and inaccessible judicial review. It also permanently bars individuals convicted of ‘endangering national security’ from forming or leading unions.

The Registrar of Trade Unions is granted sweeping new investigative powers, including warrantless entry into union premises and seizure of documents. Foreign funding is prohibited without prior approval, and unions must notify Hong Kong’s Chief Executive before affiliating with any overseas organisations.

While authorities argue the NSL has ‘restored stability’ and prevented external interference, with further tightening of regulations is ‘necessary’ through amendments to the Trade Union Ordinance, the international labour movement has condemned the changes, warning they violate fundamental rights protected under international law, severely curtail union autonomy and entrench unchecked executive power.

The law comes amid an ongoing erosion of civil freedoms since the introduction of the NSL on June 30, 2020, which followed the mass anti-government protests of 2019–2020. Since 2020, nearly 250 unions have disbanded and the city’s most prominent unionists have been jailed or forced into exile. Hong Kong’s independent media workforce has also shrunk in recent years, with the legislation criminalising acts such as “separatism, subversion of state power, terrorism and interference.” Since November 2023, seven independent media organisations and 20 individuals, including the Hong Kong Journalists Association (HKJA), been targeted by Hong Kong’s Inland Revenue Department (IRD) via a series of targeted and oppressive tax audits.



The IFJ said, “Denying trade union registration on vague national security grounds without a meaningful right to appeal undermines the rule of law, suppresses grassroots organising, and weakens workers’ collective bargaining power. The IFJ stands in solidarity with Hong Kong’s embattled trade union community and urges the authorities to uphold constitutional commitments to workers’ rights and ensure all unions can operate freely and without fear of reprisal.”

The Trade Union (Amendment) Bill of 2025 significantly impacts the autonomy and operational capabilities of trade unions in Hong Kong by introducing stringent regulations and oversight mechanisms. The bill seeks to amend the Trade Unions Ordinance to strengthen the regulation of trade unions to safeguard national security and improve the trade union regulatory regime. This is done by enhancing the statutory powers of the Registrar of Trade Unions to supervise and regulate trade unions, thereby better fulfilling the duty of safeguarding national security under the National Security Law and the Safeguarding National Security Ordinance.

One of the key provisions of the bill is the requirement for trade unions to seek approval from the Registrar of Trade Unions to receive funds from external forces. This includes declaring the source and use of the money, and if approved, the funds cannot be used in designated local elections. This regulation effectively isolates Hong Kong unions from global labor networks, weakening their ability to advocate at international levels. As stated, "The amendment requires trade unions to seek approval from the Registrar of Trade Unions to receive funds from external forces by declaring the source and use of the money. If the funds are approved, they cannot be used in designated local elections."

Additionally, the bill bars trade union officers from assuming office in a non-affiliated organization in an external place without the approval of the chief executive. This provision further restricts the operational capabilities of trade unions by limiting their international affiliations and collaborations. The bill also requires unions to maintain records such as financial accounts and membership lists for government inspection, which could dissuade workers from organizing around sensitive issues, thereby undermining their freedoms of expression, peaceful assembly, and association.

The potential long-term effects on labor rights and worker protections are significant. The stringent political vetting and surveillance of unions could discourage the formation of new independent unions and create a hostile environment for existing ones. This is evident in the recent pronouncement of the Hong Kong Secretary for Labor and Welfare, Chris Sun, who stated that "freedom of association is not absolute and therefore subject to restrictions." This environment of fear and self-censorship could lead to the silencing of dissent and the curtailment of workers' rights to hold strikes and protests in support of broader sociopolitical causes.

Since the implementation of the National Security Law in 2020, more than 200 unions—many of which were formed during the 2019 protest movement—have disbanded under political pressure. For example, the Hong Kong Information Technology Workers’ Union and the Student Front Union disbanded in 2021 due to safety concerns. In the same year, the Hong Kong Confederation of Trade Unions, the territory’s largest independent trade union, disbanded for the same reason. This trend indicates a broader pattern of suppression and intimidation that could further erode labor rights and worker protections in Hong Kong.

The new law's broad and vague restrictions on union activities and affiliations with foreign organizations deviate significantly from international labor standards and human rights principles. Here are some key points of deviation:

1. Freedom of Association: International labor standards, as outlined by the International Labour Organization (ILO), protect the right of workers to form and join trade unions without interference. The proposed amendments to the Trade Unions Ordinance in Hong Kong, however, impose stringent political vetting and surveillance on unions, which could discourage the formation of new independent unions and create a hostile environment for existing ones. This is evident in the statement by the Hong Kong Secretary for Labor and Welfare, Chris Sun, who said that "freedom of association is not absolute and therefore subject to restrictions." This stance contradicts the ILO's Convention No. 87, which guarantees the right to form and join trade unions without interference.

2. Restrictions on Foreign Funding: The proposed amendments require unions to seek approval from the Registrar of Trade Unions to receive funds from external forces, and such funds cannot be used in local elections. This restriction isolates Hong Kong unions from global labor networks, weakening their ability to advocate at international levels. This is a clear deviation from international human rights principles, which recognize the right of unions to receive foreign funding to support their activities.

3. Broad Definition of "External Force": The Trade Unions Ordinance and National Security Law share the same overly broad definition of "external force," which includes foreign governments as well as political parties and organizations. This broad definition could extend to non-governmental organizations and international union federations critical of Hong Kong and Chinese policies, thereby hindering a union’s right to equal participation in decision-making. This is a deviation from the ILO's Convention No. 98, which protects the right of unions to engage in collective bargaining and participate in decision-making processes.

4. Political Blacklisting: The proposed amendments would ban those convicted of national security offenses from leading or founding new unions, and require union officers charged with such offenses to disclose the charge to the Registrar of Trade Unions. This preemptively assumes guilt and could destabilize union governance by forcing democratically elected leaders to step down. This is a form of political blacklisting, which prevents individuals labeled as "security risks" from participating in civil society through unions and punishes dissent under the guise of "national security." This is a clear deviation from the ILO's Convention No. 87, which protects the right of workers to form and join trade unions without interference.

5. Broad Government Control: The proposed amendments would give the Registrar of Trade Unions broad investigative powers, including the ability to enter union premises to inspect, duplicate, and seize materials without a warrant. This is a deviation from international human rights principles, which protect the right of unions to operate without undue interference from the government.

The Trade Union (Amendment) Bill of 2025 is a stark reminder of the ongoing erosion of civil liberties and labor rights in Hong Kong. The bill's broad and vague restrictions on union activities and affiliations with foreign organizations not only violate international labor standards and human rights principles but also create a climate of fear and self-censorship that undermines the very foundations of a democratic society. As the international community continues to monitor the situation in Hong Kong, it is crucial that we remain vigilant in our defense of workers' rights and the principles of freedom and democracy. The world must choose: cooperation or collapse.