Special Administrative Regions (SARs) are local administrative units of the People's Republic of China established under Article 31 of the 1982 Constitution, which empowers the National People's Congress (NPC) to create such regions and prescribe their systems "in the light of specific conditions." The constitutional formula operationalises Deng Xiaoping's doctrine of "one country, two systems" (一国两制), conceived in the early 1980s to enable the reunification of Hong Kong, Macau, and ultimately Taiwan while preserving their existing capitalist economies and legal traditions. The two existing SARs are Hong Kong (established 1 July 1997, on the expiry of Britain's New Territories lease and pursuant to the 1984 Sino-British Joint Declaration) and Macau (established 20 December 1999, pursuant to the 1987 Sino-Portuguese Joint Declaration). Each is governed by a Basic Law enacted by the NPC functioning as a mini-constitution.
Under their Basic Laws, SARs enjoy a "high degree of autonomy" covering executive, legislative, and independent judicial power, including final adjudication — Hong Kong retains its Court of Final Appeal and common-law system, while Macau follows civil-law tradition. SARs maintain separate currencies (Hong Kong dollar, Macanese pataca), customs territories, and tax systems, and remain members of bodies such as the WTO and APEC under the designation "Hong Kong, China" and "Macau, China." The central government in Beijing retains responsibility for defence and foreign affairs, and the NPC Standing Committee holds the power of interpretation of the Basic Law (Article 158, Hong Kong Basic Law) and constitutional review. The Chief Executive is selected by an Election Committee and appointed by the Central People's Government. Article 23 of the Basic Law obliges each SAR to enact laws against treason, secession, sedition, and subversion.
The autonomy guaranteed to Hong Kong was promised for 50 years (until 2047) under the Joint Declaration and Article 5 of the Basic Law. Following the 2019 anti-extradition-bill protests, Beijing's NPC Standing Committee imposed the Hong Kong National Security Law on 30 June 2020, criminalising secession, subversion, terrorism, and collusion with foreign forces, and in 2021 overhauled the electoral system to ensure "patriots governing Hong Kong." In 2024 Hong Kong enacted its own Article 23 legislation (the Safeguarding National Security Ordinance). As of 2026 these measures have substantially narrowed the practical scope of autonomy, prompting debate over whether "one country, two systems" remains intact. Taiwan, which Beijing claims as a province eligible for SAR status, has firmly rejected the model.
For competitive examinations, SARs appear in the comparative-government and international-relations segments. UPSC GS Paper II and the Polity comparative-constitution sections test the contrast between asymmetric federalism, autonomy, and devolution; candidates should distinguish an SAR from a Chinese autonomous region (e.g. Tibet, Xinjiang under Article 4) and from Indian asymmetric arrangements such as the former Article 370. FSOT and CSS papers probe the geopolitics of the 2019–2020 crackdown, the Sino-British Joint Declaration's status as a registered treaty, and the 2047 deadline. The typical question angle asks candidates to evaluate "one country, two systems" against the principle of unitary sovereignty.
Example
In 2020, China's NPC Standing Committee imposed the Hong Kong National Security Law on the Hong Kong SAR following the 2019 protests, criminalising secession and subversion and reshaping its autonomy under "one country, two systems."
Frequently asked questions
Article 31 of the 1982 Constitution of the People's Republic of China empowers the National People's Congress to establish Special Administrative Regions and to prescribe their systems by law according to specific conditions. This is the legal basis for 'one country, two systems.'