Hong Kong, Macau & the 'one country, two systems' model

The constitutional source of 'one country, two systems'

The formula yiguo liangzhi ('one country, two systems') was conceived by Deng Xiaoping in the early 1980s, initially to address Taiwan, but first operationalised for Hong Kong and Macau. Its supreme domestic legal anchor is Article 31 of the Constitution of the People's Republic of China (1982), which authorises the state to establish special administrative regions (SARs) when necessary, with systems to be prescribed by law enacted by the National People's Congress (NPC) 'in the light of specific conditions'. Article 31 is the constitutional hook; the operating manual for each region is its Basic Law, a national law passed by the NPC.

The two handovers and the treaty basis

Hong Kong's return rests on the Sino-British Joint Declaration, signed 19 December 1984 and registered with the United Nations, under which the United Kingdom restored Hong Kong to the PRC on 1 July 1997. Macau's return rests on the Sino-Portuguese Joint Declaration of 13 April 1987, with the handover on 20 December 1999. China's position is that the Joint Declarations were transitional instruments whose mission was completed at handover; the UK and others treat the Hong Kong declaration as a continuing treaty obligation. This contested legal status is itself an exam-relevant point.

The Basic Laws

The Hong Kong Basic Law was adopted by the NPC on 4 April 1990 and took effect on 1 July 1997. The Macau Basic Law was adopted on 31 March 1993, effective 20 December 1999. Each promises a 'high degree of autonomy', an independent judiciary with power of final adjudication (the Court of Final Appeal in Hong Kong from 1997 replaced appeals to the Privy Council in London), and preservation of the capitalist system and existing way of life for 50 years — i.e. to 2047 for Hong Kong and 2049 for Macau. Hong Kong's Article 5 guarantees that the socialist system 'shall not be practised'.

Powers reserved to the centre

Autonomy is delegated, not sovereign. The Central People's Government retains foreign affairs and defence (Hong Kong Basic Law Articles 13–14; the People's Liberation Army garrison is stationed in Hong Kong). Critically, the NPC Standing Committee (NPCSC) holds the power of final interpretation of the Basic Law under Article 158 (Hong Kong) and Article 143 (Macau). The NPCSC has exercised this five times for Hong Kong — notably the 1999 interpretation reversing the Court of Final Appeal's right-of-abode ruling in Ng Ka Ling v Director of Immigration, and the 2016 interpretation on oath-taking under Article 104. Understanding that interpretation, not adjudication, is the ultimate constitutional backstop is the conceptual key to the entire model.

The 2014 White Paper and 'comprehensive jurisdiction'

A decisive doctrinal shift came with the State Council Information Office White Paper of June 2014, 'The Practice of the "One Country, Two Systems" Policy in the Hong Kong Special Administrative Region'. It asserted that the central authorities exercise 'comprehensive jurisdiction' (quanmian guanzhixquan) over Hong Kong, and that the SAR's 'high degree of autonomy' is not inherent but wholly derived from authorisation by the central leadership. This reframed autonomy as a grant revocable in scope — the theoretical scaffolding for later interventions.

Electoral structure and the 31 August 2014 decision

The Chief Executive is selected by an Election Committee and appointed by the Central People's Government; the NPCSC decision of 31 August 2014 ('8.31 decision') permitted universal suffrage for the 2017 Chief Executive election only if candidates were first vetted by a nominating committee, triggering the Umbrella Movement protests of autumn 2014. The reform package was voted down by the Legislative Council in June 2015.

The 2020 National Security Law

The pivotal recent instrument is the Law on Safeguarding National Security in the Hong Kong SAR, enacted directly by the NPCSC on 30 June 2020 and inserted into Annex III of the Basic Law — bypassing the local legislature that had failed to pass Article 23 legislation since 2003. It criminalises secession, subversion, terrorism and collusion with foreign forces, establishes the Office for Safeguarding National Security answerable to Beijing, and asserts jurisdiction extending beyond Hong Kong's borders (Article 38). In some cases trials may be removed to the mainland (Article 55).

Electoral 'patriots' reform of 2021

The NPC decision of 11 March 2021 on 'improving the electoral system', implemented through NPCSC amendments to Annexes I and II, expanded the Election Committee to 1,500 members, reduced directly elected Legislative Council seats, and created a Candidate Eligibility Review Committee to enforce the principle that 'patriots govern Hong Kong' (aiguozhe zhi Gang). Hong Kong finally passed its own Article 23 national security legislation — the Safeguarding National Security Ordinance — on 19 March 2024.

Macau as the model student

Macau is consistently cited by Beijing as the successful template. It passed Article 23 national security legislation in 2009, more than a decade before Hong Kong, and has experienced minimal political confrontation. The contrast is a favoured comparative essay axis: why convergence proceeded smoothly in Macau but conflictually in Hong Kong — answerable by reference to civil-society density, colonial-era institutional legacies, and the gaming-dependent economy's reliance on central goodwill.

Why this matters for the exam

For the Guokao political-theory paper, 'one country, two systems' is a high-frequency topic that sits at the intersection of three examinable domains: state structure (the SAR as a sub-national unit under a unitary state), the NPC system (because the Basic Laws are national laws and the NPCSC holds interpretive supremacy), and the Party's leadership doctrine. It is tested both as fact recall and as doctrinal argument, and the official framing you reproduce matters as much as the facts.

How it is tested

Expect three formats. First, objective/short-answer items demanding precise authorities: which constitutional article authorises SARs (Article 31), the handover dates (1 July 1997; 20 December 1999), the body that interprets the Basic Law (the NPCSC), and the 50-year guarantee. Second, conceptual questions on the relationship between 'one country' and 'two systems' — the orthodox answer, repeated in the 2014 White Paper and reaffirmed by Xi Jinping's 1 July 2017 speech in Hong Kong, is that 'one country' is the precondition and foundation, the 'root and trunk', while 'two systems' is subordinate and derived. Candidates must articulate that autonomy flows from central authorisation, not from any inherent right. Third, comparative or current-affairs essays asking you to evaluate the model's evolution post-2020.

The high-yield retention list

Memorise: Article 31 (constitutional basis); Article 5 of the Hong Kong Basic Law (no socialism, capitalist system for 50 years); Articles 13–14 (centre keeps defence and foreign affairs); Article 158 (NPCSC interpretation); the June 2020 NSL enacted via Annex III; the 'patriots govern Hong Kong' electoral reform of 11 March 2021; and the 19 March 2024 Article 23 ordinance. For Macau, retain the 2009 Article 23 law and the 'model implementation' framing.

The PYQ angle and pitfalls

Past questions frequently demand the dialectical relationship between unity and autonomy — frame your answer around the centre's 'comprehensive jurisdiction' and the delegated nature of the 'high degree of autonomy'. A common candidate error is to describe the SARs as quasi-federal or to call the autonomy 'sovereign'; the orthodox doctrine insists China remains a unitary state and the SARs exercise only powers granted by the centre. A second pitfall is confusing the two handover dates or attributing final interpretation to the Court of Final Appeal rather than the NPCSC. Anchor every claim to a named instrument and date and you will score the analytical marks.