One country, two systems

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One country, two systems
Chinese name
Simplified Chinese
Traditional Chinese
Portuguese name
Portuguese Um país, dois sistemas

"One country, two systems" is a constitutional principle formulated by Deng Xiaoping, the Paramount Leader of the People's Republic of China (PRC), for the reunification of China during the early 1980s. He suggested that there would be only one China, but distinct Chinese regions such as Hong Kong and Macau could retain their own economic and administrative systems, while the rest of China uses the socialism with Chinese characteristics 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.

Background in the context of Hong Kong[edit]

Hong Kong was a colony of the United Kingdom, ruled by a governor for 156 years (except for four years of Japanese occupation during WWII) until 1997, when it was returned to Chinese sovereignty. China had to accept some conditions, stipulated in the Sino-British Joint Declaration, such as the drafting and adoption of Hong Kong's mini-constitution before its return. The Basic Law ensured Hong Kong will retain its capitalist economic system and own currency (the Hong Kong Dollar), legal system, legislative system, and people's rights and freedom for fifty years, as a special administrative region (SAR) of China. Set to expire in 2047, the current arrangement has permitted Hong Kong to function as its own entity in many international settings (e.g., WTO and the Olympics) rather than as a part of China.[1][2][3]

The Chinese renminbi is not legal tender in Hong Kong. Likewise, the Hong Kong Dollar is not accepted in stores in China. With this arrangement, a permit or visa is required when passing the borders of Hong Kong and China, people in Hong Kong generally 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 China distinct from each other, as Cantonese and English are the most widely used languages in Hong Kong while Mandarin is the official language of 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 as promised by the Basic Law, leading to mass demonstrations in 2014.[1][2][3]

Hong Kong and Macau[edit]

Deng Xiaoping proposed to apply the principle to Hong Kong in the negotiation with the British Prime Minister, Margaret Thatcher over the future of Hong Kong when the lease of the New Territories (including New Kowloon) of Hong Kong to the United Kingdom was to expire in 1997. The same principle was proposed in talks with Portugal 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 UK and Portugal respectively, can retain their established system under a high degree of autonomy for at least 50 years after reunification. What will happen after 2047 (Hong Kong) and 2049 (Macau) 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:[4]

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, 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 in light of the specific conditions.

The SARs of Hong Kong and Macau were formally established on 1 July 1997 and 20 December 1999 respectively, immediately after the People's Republic of China (PRC) assumed the sovereignty over the respective regions.


The two SARs of Hong Kong and Macau are responsible for their domestic affairs including, but not limited to, the judiciary and courts of last resort, immigration and customs, public finance, currencies and extradition. Important cultural effects are exemption of the SARs from mainland laws mandating the use of simplified characters in publishing and Mandarin in public education and most broadcasting. The diplomatic relations and regional defence of the two SARs however, is the responsibility of the Central People's Government in Beijing.

Hong Kong continues using English common law and Macau continues using the Portuguese civil law system.


In Hong Kong, the system has been implemented through the Basic Law of Hong Kong, which serves as the "mini-constitution" of the region, and consistent with the Sino-British Joint Declaration. Similar arrangements are in place with Macau. Under the respective basic laws, the SARs have a high degree of autonomy and enjoy executive, legislative and independent judicial power, including that of final adjudication. They formulate their own monetary and financial policies, maintain their own currencies, formulate their own policies on education, culture, sports, social welfare system, etc. within the framework of the basic laws.

As stipulated by the Basic Law, while the Central People's Government of the PRC is responsible for foreign affairs and defence in relation to the SARs, representatives of the Government of the SARs may participate, as members of delegations of the PRC, in diplomatic negotiations that directly affect the Regions, and in other international organisations or conferences limited to states and affecting the region. For those international organisations and conferences not limited to states, the SARs may participate using the names in the form of Hong Kong, China and Macau, China. As separate economic entities, both SARs of Hong Kong and Macau are members of the World Trade Organization. Hong Kong is also one of the member economies of APEC.

The Hong Kong Basic Law also provides constitutional protection on various fundamental human rights and freedoms. Specifically, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and international labour conventions which are implemented under Article 39 of the Hong Kong Basic Law and the Hong Kong Bill of Rights Ordinance.

Nonetheless, the governments of the People's Republic of China and Hong Kong both consider the principle to have been successfully implemented, quoting official reports of both the United Kingdom and the United States.

The Central People's Government in Beijing maintain relations with Hong Kong government through the Liaison Office of the Central People's Government in the Hong Kong Special Administrative Region in Hong Kong. For Macau, Beijing uses the Liaison Office of the Central People's Government in the Macao Special Administrative Region in Macau. While the counterpart offices of the Hong Kong government for the Central People's Government in Beijing is the Office of the Government of the Hong Kong Special Administrative Region in Beijing, and Macau government's office in Beijing is the Office of the Macau Special Administrative Region in Beijing.

Perceptions of autonomy of Hong Kong[edit]

After Britain returned Hong Kong to China in 1997, Beijing promised that the Hong Kong citizens would be free to elect their local government. However, Beijing seemed to have a different idea of these free elections than Hong Kong's democracy movement. Though it seemed as if the Communist Party of China would allow Hong Kong's citizens free elections, but only those candidates, who had been selected by Beijing. One of the reasons for the protests by Hong Kong's citizens and students was because Beijing had broken its promise to grant them open elections by 2017, thus, they demanded "true universal suffrage."[7]

Several incidents have caused portions of the Hong Kong public to call into question the PRC's pledge to allow a high degree of autonomy in Hong Kong. Some international observers and human rights organisations have expressed doubts about the future of the relative political freedoms enjoyed in Hong Kong.

In the year after the Handover, surveys showed high levels of satisfaction with Beijing's hands-off relationship with the former colony. [8]

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 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 knocked the public's confidence in the government, despite the fact that most were in favour of the government's stance over the court's.[8]

The proposals in Article 23 of the Basic Law in 2003 (which were withdrawn due to mass opposition) were claimed to undermine autonomy.

On 10 June 2014, Beijing released a new report[9] asserting its authority over the territory. This 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.[10]

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 during 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.[7] In 2016, Joshua Wong, Alex Chow and Nathan Law, student leaders of the protests, were indicted for their roles in the protests and found guilty.

Alleged breach[edit]

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, one in Thailand, 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.[11] 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.[12][13][14] 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 scurry of counter-accusations and denials from mainland authorities and supporters.[15][16]


This system has also been proposed by the PRC government for Taiwan, but the Government of the Republic of China has refused this suggestion (it has also been claimed that the system was originally designed for Taiwan[citation needed] in order for it to be reunified with the PRC). More specifically, special provisions for the preservation of the military in Taiwan have also been proposed by the Chinese Communist Party (the ruling political party of the PRC), unlike that of Hong Kong and Macau, which are territories protected by the People's Liberation Army (PLA) of the PRC. All of the major political parties in Taiwan, however, including those that lean towards Chinese reunification, have come out strongly against the "One country, Two systems". Some proposed instead "One country, Two governments", which was opposed outright by the PRC government, while some proposed that the "one country" highlighted in the system should be the ROC instead of the PRC. One of the few Taiwanese who have publicly supported the "One country, Two systems" is Li Ao, a Mainland-born novelist.[citation needed]

Although the "one country, two systems" guarantees that Hong Kong's economic and political systems will not be changed for 50 years after the British handover in 1997, Mainland Affairs Council of the Republic of China has cited 169 cases in which they claim the PRC has breached the right of the people of Hong Kong to self-rule and severely intervened in the judicial system as well as freedom of speech.[17]

Since the accession of Hu Jintao as the General Secretary of the Communist Party of China on 15 November 2002, the PRC has stopped promoting immediate unification via "one country, two systems", although it remains official policy. The "one country, two systems" framework was not mentioned in the Anti-Secession Law of the People's Republic of China passed on 14 March 2005 to prevent the growing Taiwan independence movement at that time. A new policy of gradual economic integration and political exchanges is now preferred under the 1992 Consensus:[18] this new policy was emphasised during the 2005 Pan-Blue visits to mainland China in April 2005[19] as well as all subsequent major cross-strait exchanges, especially after Ma Ying-jeou from the pro-reunification Kuomintang party won the 2008 Republic of China presidential election. During his visit to Beijing in March 2012, former Kuomintang (KMT) Chairman Wu Po-hsiung proposed the one country, two areas (simplified Chinese: 一国两区; traditional Chinese: 一國兩區) framework to govern the cross-strait relations.[20] During the 2013 National Day of the Republic of China address on 10 October 2013, President Ma Ying-jeou addressed the public stating that people of both sides of the Taiwan Strait are all Chinese by ethnicity and that cross-strait relations are not international relations.[21]

Due to the growing pressure for the pro-independence Democratic Progressive Party (DPP) to engage in the cross-strait development over the past recent years developed by KMT-CPC, the DPP finally softened its stance on its Taiwan independence movement when the former chairman Frank Hsieh visited Mainland China on 4–8 October 2012, a groundbreaking visit by the highest rank in DPP, although he claimed that this trip was done in his private capacity and as a non-politician.[22] The DPP also established its party China Affairs Committee on 21 November 2012[23] and proposed the Broad One China Framework (simplified Chinese: 大一中原则; traditional Chinese: 大一中原則) on 27 May 2014 led by former chairman Shih Ming-teh.[24]

Comparison to proposals for Tibet[edit]

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".[25]

The 14th Dalai Lama's 2005 proposal for "high-level autonomy" for Tibet, 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.[26]

One country, two systems for other countries[edit]

Muhammad Cohen, writing for Asia Times, suggests the One country, two systems formula is possible solution to the Israeli–Palestinian conflict [27]

North Korea suggests One country, two systems to bring about Korean unification, through a confederation of two systems within one country. [28]

China has also promoted the idea of One country, two systems as possible method for Korean unification. The difference between North Korea's motivation and China's is that North Korea seeks to maintain two separate governments, while China seeks to gradual unification as it brings stability to the Korean peninsula, with one centralised government.[29]

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 after Brexit. The border between EU member Ireland and British-ruled Northern Ireland is becoming an increasing concern in divorce talks with Britain, with Dublin demanding that the frontier remain completely open, or risk endangering the peace process.[30]

Similar One Country, two systems arrangements in other countries[edit]

Country Autonomous Administrative Division Similar Situation Region Flag
 United States Puerto Rico Flag of Puerto Rico.svg
 United Kingdom Northern Ireland 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 after Brexit. The border between EU member Ireland and British-ruled Northern Ireland is becoming an increasing concern in divorce talks with Britain, with Dublin demanding that the frontier remain completely open, or risk endangering the peace process.[31] Flag of Northern Ireland.svg
 Denmark Greenland On 21 June 2009, Greenland gained self-rule with provisions for assuming responsibility for self-government of judicial affairs, policing, and natural resources. Also, Greenlanders were recognized as a separate people under international law.[32] Denmark maintains control of foreign affairs and defence matters. Denmark upholds the annual block grant of 3.2 billion Danish kroner, but as Greenland begins to collect revenues of its natural resources, the grant will gradually be diminished. This is generally considered to be a step toward eventual full independence from Denmark.[33] Greenlandic was declared the sole official language of Greenland at the historic ceremony.[34][35][36][37] Flag of Greenland.svg
 North Korea Sinuiju Special Administrative Region Flag of the Sinŭiju Special Administrative Region.svg
 Tanzania Zanzibar Flag of Zanzibar.svg
 Philippines Autonomous Region in Muslim Mindanao
Moro country
Bangsamoro Plan
On 7 October 2012, President Benigno Aquino III said that the government aimed to have peace in the autonomous region and that it will become known as Bangsamoro Autonomous Region,[38] a compound of bangsa (nation) and Moro.[39] Flag of the Moro Islamic Liberation Front.svg

See also[edit]


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  2. ^ a b "China Resumes Control of Hong Kong, Concluding 156 Years of British Rule". The New York Times. 
  3. ^ a b "1898 and all that—a Brief History of Hong Kong." The Economist, 28 June 1997
  4. ^ "Chapter I : General Principles". Government of the Hong Kong SAR. 17 March 2008. Retrieved 1 November 2009. 
  5. ^ Luo, Jing. Over A Cup of Tea: An Introduction To Chinese Life And Culture. [2004] (2004). University Press of America China. ISBN 0-7618-2937-7
  6. ^ Wong, Yiu-chung. [2004] (2004). One Country, Two Systems in Crisis: Hong Kong's Transformation. Lexington Books. Hong Kong. ISBN 0-7391-0492-6.
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  8. ^ a b Carroll, John M (2007). A Concise History of Hong Kong. Hong Kong University Press. pp. 221–228. ISBN 978-962-209-878-7. 
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  12. ^ "Disappearance of 5 Tied to Publisher Prompts Broader Worries in Hong Kong". The New York Times. 5 January 2016. 
  13. ^ Ilaria Maria Sala (7 January 2016). "Hong Kong bookshops pull politically sensitive titles after publishers vanish". The Guardian. London. 
  14. ^ "Unanswered questions about the missing booksellers". EJ Insight. 5 January 2016. 
  15. ^ "In Pictures: Over 1,000 protesters chant 'no to authority' in support of returned bookseller - Hong Kong Free Press HKFP". 18 June 2016. 
  16. ^ "Returned bookseller says he was detained by 'special unit' in China, TV 'confession' was scripted". 16 June 2016. 
  17. ^ "News Release, MAC Pres Release No. 065". Mainland Affairs Council. 29 June 2006. Retrieved 18 October 2016. 
  18. ^ "The Risk of War Over Taiwan is Real". Financial Times. 1 May 2005. Archived from the original on 31 December 2005. Retrieved 26 July 2006. 
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  20. ^ "'One country, two areas' proposed by Wu Po-hsiung – Taipei Times". Retrieved 12 September 2014. 
  21. ^ Press release: "President Ma Ying-jeou’s National Day Address 10/10/2013" Archived 29 October 2014 at the Wayback Machine.. Taipei Representative Office in Finland, 15 October 2013
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  30. ^ "Irish minister suggests Hong Kong-style deal for post-Brexit Northern Ireland". Hong Kong Free Press. 23 November 2017. 
  31. ^ "Irish minister suggests Hong Kong-style deal for post-Brexit Northern Ireland". Hong Kong Free Press. 23 November 2017. 
  32. ^ Description of the Greenlandic Self-Government Act on the webpage of the Danish Ministry of State Archived 22 September 2014 at the Wayback Machine."The Self-Government Act provides for the Self-Government authorities to assume a number of new fields of responsibility, such as administration of justice, including the establishment of courts of law; the prison and probation service; the police; the field relating to company law, accounting and auditing; mineral resource activities; aviation; law of legal capacity, family law and succession law; aliens and border controls; the working environment; as well as financial regulation and supervision, cf. Schedule I and II in the Annex to the Self-Government Act."
  33. ^ Greenland takes step toward independence from Denmark. The Daily Telegraph (21 June 2009). Retrieved 29 September 2012.
  34. ^ (in Danish) TV 2 Nyhederne – "Grønland går over til selvstyre" TV 2 Nyhederne (TV 2 News) – Ved overgangen til selvstyre, er grønlandsk nu det officielle sprog. Retrieved 22 January 2012.
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  38. ^ "Govt reaches deal with MILF to end rebellion". ABS-CBN News. Retrieved 7 February 2015. 
  39. ^ "The Bangsamoro reframes the Muslim-Filipino identity". Retrieved 13 April 2015.