Punishments for offences under Hong Kong’s new Article 23 bill comparable with penalties in key common law jurisdictions like Australia, UK, Canada and Singapore
- Penalties for offences such as treason, insurrection and sabotage fall largely in line with punishments set out in six other major common law jurisdictions
- Six jurisdictions examined by Post were the US, UK, Australia, Canada, Singapore and New Zealand

Penalties for offences under Hong Kong’s proposed domestic security law are comparable with those of similar jurisdictions around the world, although sedition remains an outlier, data compiled by the Post has found.
Under proposed domestic security legislation presented to the Legislative Council on Friday, penalties for offences such as treason, insurrection and sabotage will fall largely in line with punishments set out in six other major common law jurisdictions.
“The proposed law meets all applicable international conventions and standards, human right protections under national and local laws, and many procedural safeguards,” said Nick Chan Hiu-fung, a lawyer and local delegate to the National People’s Congress.

The six jurisdictions examined were the US, UK, Australia, Canada, Singapore and New Zealand and were among those also cited in a consultation document the government issued ahead of the bill’s publication.
While the specific terms and legislation differed depending on each jurisdiction, the Post compared those of a similar nature or wording.
Under the proposed legislation, those who commit treason, insurrection, sabotage in collusion with an external force or incite a member of the Chinese armed forces to mutiny could face life imprisonment.
Treason carries a penalty of life imprisonment across many jurisdictions, including the United Kingdom, New Zealand, Canada, Australia and Singapore. The latter three also carry the same penalty for crimes similarly defined to insurrection.