As noted in the previous two articles in this series, the entry into force of the Investment Funds Law (Law 11/2025) marks an important milestone for Macau, as it may also serve as a bridgehead for deeper integration of Macau within the Greater Bay Area (GBA). The GBA project seeks to support regional development through stronger infrastructure, more connected financial markets, and cross-border innovation across Macau, Hong Kong, Guangzhou, Shenzhen, Zhuhai, Foshan, Huizhou, Dongguan, Zhongshan, Jiangmen, and Zhaoqing.
In tandem with Macau’s new tax regime, the enhanced supervisory framework of the Monetary Authority of Macau (AMCM), and GBA-wide initiatives such as the Cross-Boundary Wealth Management Connect scheme, the Investment Funds Law can be viewed as a core building block within the GBA’s financial ecosystem.
That integration case is strengthened by the fact that the Investment Funds Law equips Macau with a structurally familiar framework for institutional and cross-border fund structuring: it accommodates funds constituted by contract, as collective investment companies and as funds established in the form of limited partnerships, while explicitly recognising umbrella funds, master-feeder structures, and funds of funds.
The law further allows the redomiciliation of foreign funds into Macau, which opens a route for existing regional platforms to migrate or replicate structures in Macau, rather than building entirely new fund entities from scratch.
Macau-domiciled vehicles in GBA capital chains
In practical GBA-context terms, the combination of redomiciliation, private fund classification, and the law’s subcontracting regime allows Macau-domiciled vehicles to function as structurally neutral nodes within cross-border capital allocation chains.
For example, a Hong Kong-based private equity house managing a GBA-oriented infrastructure platform could migrate its existing feeder fund into a Macau-domiciled limited partnership fund under the redomiciliation rules in the Investment Funds Law, while retaining Hong Kong-based operations and distribution channels. All while allowing the fund manager to position Macau as its domicile for raising capital from Mainland-connected qualified investors through direct private-placement channels without triggering a full restructuring of the underlying strategy.
From an operational perspective, the Southbound and Northbound axes of the Cross-Boundary Wealth Management Connect scheme present distinct but complementary opportunities for Macau-domiciled structures:
Under the Southbound Scheme, eligible residents of the Mainland GBA cities may remit RMB into Hong Kong and Macau-linked wealth management products through a closed-loop RMB remittance mechanism, typically subject to individual-quota limits reported at around RMB 3 million per investor and a preference for ‘non-complex’, low- to medium-risk funds; and
The Northbound Scheme, in turn, allows residents of Hong Kong and Macau to invest in qualifying wealth management products in the Mainland GBA cities, again under RMB-based, quota-controlled, bank channel-led flows.
This two-way architecture highlights the need for Macau-domiciled investment fund entities to be structured around RMB-denominated or RMB-linked units, foreign exchange (FX) hedging arrangements, and paired ‘dedicated remittance/dedicated investment’ accounts, so that cross-border FX controls and the Chinese capital-account framework are respected even as the underlying fund is governed and supervised under Macau law.
The new legal framework expressly allows units to be denominated in different currencies and to include FX risk hedging mechanisms, giving sponsors flexibility to tailor currency exposure for different investor groups within a single Macau-domiciled vehicle. As a result, currency choices between RMB, MOP, and HKD become a key structuring factor in GBA-linked Macau funds, as investors from different jurisdictions can access the same underlying assets through distinct currency-classed units.
Positioning Macau between the GBA and lusophone markets
From a market-positioning perspective, Macau’s potential to act as a gateway for capital from Portuguese-speaking countries could allow it to compete with Hong Kong’s established fund services ecosystem on narrow-niche grounds. The ‘1+4’ economic diversification strategy, which identifies modern financial services as one of its four priority-industry clusters, provides political support for this direction. The success of that strategy will ultimately depend on whether AMCM-supervised funds can deliver both high-quality, compliant structures and concrete, track record-backed products that appeal to GBA-based and lusophone-sourced investors.
Besides the cooperation abilities of the local monetary authorities (i.e., the People’s Bank of China, the Hong Kong Monetary Authority, and the AMCM), a related challenge is the regulatory-capacity burden that the AMCM will face as a more complex set of cross-border fund structures becomes established in Macau, where its ability to monitor sophisticated, multi-jurisdictional chains of managers, sub-managers, and depositaries will be tested.
Outlook
Going forward, the law’s flexibility, together with Macau’s unique role as a gateway for capital from Portuguese-speaking countries, suggests that Macau-domiciled funds can evolve from local-market vehicles into strategic joints that link regional, Mainland-connected, and lusophone-sourced capital within a single AMCM-supervised framework. In this sense, more than a technical update, Law 11/2025 aims at positioning Macau within the GBA’s capital market architecture as a specialised AMCM-supervised fund hub for regional and lusophone-aligned investors.
