Policy Recommendations on Reforming Hong Kong’s Dog Control Regime
Response to Paragraph 413 of the 2026 Policy Address
Date: 20 September 2026
I. Background
Paragraph 413 of the Chief Executive’s 2026 Policy Address stated that the Government will consult the Legislative Council by the end of this year on combating cruelty to animals and prohibited hunting apparatuses, aiming to complete legislative amendments by 2027. Concurrently, the Government will review keeping and control requirements under the Dangerous Dogs Regulation and related legislation, while strengthening public education on the "proper care of animals".
In August 2026, an insufficiently leashed large dog mauled two small pet dogs to death in a public area in Yuen Long. Days later, the person-in-charge of a pet boarding facility in Ta Kwu Ling was fatally mauled by a boarded dog. These tragedies reveal core institutional vulnerabilities: simply expanding the statutory list of prohibited fighting breeds fails to regulate aggressive giant breeds outside the list, operational failures at pet facilities, and dogs smuggled into Hong Kong that circumvent regulation through false breed declarations.
II. Structural Deficiencies in the Current Legal Framework
Regulatory powers are currently fragmented across the Dogs and Cats Ordinance (Cap. 167), its subsidiary legislation the Dangerous Dogs Regulation (Cap. 167D), the Rabies Ordinance (Cap. 421), and the Public Health (Animals and Birds) Ordinance (Cap. 139). Dogs are roughly divided into three tiers:
Fighting Dogs: Prohibited from import and breeding; existing neutered dogs must be muzzled and held on a short lead in public.
Known Dangerous Dogs: Classified by a magistrate only after causing severe human injury, hospitalisation, or repeated attacks. Thresholds are excessively high and post-declaration controls mirror fighting dogs.
Large Dogs (20 kg or above): Must be held on a lead of no more than 2 metres in public (exemptions available upon testing); no muzzle or third-party liability insurance requirements for non-scheduled aggressive giant breeds.
The issue is not an absolute absence of law, but the regulatory gaps between tiers:
1. Absence of Pre-emptive "Amber Light" Controls: No graduated administrative intervention exists between an ordinary dog and a "known dangerous dog". The law only intervenes after severe casualties occur.
2. Focusing on Breed Rather Than Conduct: Current law targets specific breeds rather than real-time "dangerously out of control" behaviour. Fatal attacks by dogs on other pets are treated merely as property damage or minor leash infractions, which fails public expectations.
3. Regulatory Vacuum in Boarding Facilities: Animal boarding licensing conditions lack explicit protocols for handling high-risk dogs and safe staffing ratios.
4. Laundering Smuggled Animals via Registration: Smuggled animals can easily be declared as ordinary cross-breeds or unregulated breeds during local microchipping, bypassing import quarantine and breed restrictions due to the absence of proof-of-origin audits.
III. Policy Recommendations
The guiding legislative principle should be: "Expand statutory powers under primary ordinances; standardise detailed requirements via subsidiary legislation."
1. Introduce a Statutory Offence of "Dangerously Out of Control" in Primary Legislation (Covering Attacks on Other Animals)
Amend the Dogs and Cats Ordinance (Cap. 167) to establish a strict liability offence of a dog being "dangerously out of control" applying to any breed. An offence is committed if a dog attacks a person, kills or seriously injures another companion animal, or behaves in a manner causing reasonable apprehension of imminent harm in a public place (or private premises where visitors/employees are present).
This addresses the loophole where fatal attacks on other pets result only in trivial fines for leash non-compliance or civil disputes.
2. Institute Pre-emptive "Dog Control Orders" (DCOs)
Bridge the gap where intervention is contingent on a court conviction for severe human injury.
Trigger Mechanism: Authorised enforcement officers or official veterinary officers initiate assessments based on objective behavioural evidence (e.g., substantiated complaints of unprovoked aggression, witness statements, or non-fatal attacks on other domestic animals).
Measures and Appeals: Empower the Director of Agriculture, Fisheries and Conservation (DAFC) to issue time-limited, legally binding Dog Control Orders (e.g., mandatory muzzling, shorter leads, confinement conditions, or mandatory behavioural training). Provide an administrative appeal mechanism; breach of an order constitutes a criminal offence and elevates the animal’s classification.
3. Establish an Official Breed Identification Reference Framework
Formulate clear AFCD standards to counter fraudulent breed declarations: publish morphological guidelines and distinguishing phenotypic imagery, and establish an expert panel with anonymised case rulings released periodically.
Mandate proof-of-origin (import permits or licensed breeder documents). Position DNA testing as a supplementary dispute-resolution tool rather than the sole determining criterion.
4. Replace Sole Weight Criteria with a Comprehensive Risk Assessment
Refrain from arbitrarily lowering the 20 kg threshold, which unfairly penalises docile, incident-free large breeds (e.g., Golden Retrievers, Labradors).
Adopt a multi-dimensional assessment matrix combining physical build and bite mechanics, breed-specific propensities, and individual behavioural history to accurately regulate high-risk mastiffs and protection dogs outside the existing fighting dog schedule.
5. Tiered Penalties and Feasibility Study on Compulsory Third-Party Insurance
Differentiate penalties between technical infractions (e.g., minor leash length violations) and gross negligence resulting in injury or death. Articulate legislative intent clearly to guide judicial sentencing.
Mandate third-party liability insurance for high-risk or controlled dogs. The Government should first collaborate with the Insurance Authority to assess underwriting appetite and draft standard terms, preventing a de facto ban resulting from lack of market products.
6. Operational Safety Standards for Boarding and Training Facilities
Introduce mandatory safety standards into boarding licence conditions under Cap. 139B:
Mandatory written intake screening documenting behavioural and bite histories, cross-referenced with microchip records.
Mandatory two-person handling protocols or physical barrier containment when handling, caging, or transferring large or aggressive dogs. Lone workers must not handle high-risk dogs in enclosed spaces.
Provide transitional grace periods for small-scale operators; facilities explicitly declaring not to accept high-risk dogs should maintain current staffing requirements.
7. Humane Muzzle Specifications and Mandatory Handler Education
Implement the Policy Address’s focus on animal welfare: where muzzles are required in public, legislation must specify breathable basket muzzles allowing panting, heat dissipation, and drinking. Include exceptions or guidelines for high-temperature/high-humidity conditions to prevent fatal heatstroke.
Require mandatory approved handler training courses for first-time owners of designated large breeds, high-risk types, or rescue dogs with known behavioural issues.
8. Stem Smuggling at Source and Eliminate Registration Loopholes
Strictly enforce the Public Health (Animals and Birds) Ordinance (Cap. 139) and the Rabies Regulations: any canine entering Hong Kong without an import permit must undergo mandatory quarantine. No local dog licence or rehoming permit shall be issued before quarantine is completed.
Impose mandatory proof-of-origin verifications (e.g., licensed breeder records or legitimate import permits) upon initial microchip and licensing applications, eliminating the loophole of declaring smuggled fighting dogs or aggressive breeds as ordinary cross-breeds to evade scrutiny.
Increase penalties for live-animal smuggling and unauthorised delivery services; establish permanent joint interdiction operations between Hong Kong Customs and AFCD.
9. Data Transparency, Coordinated Enforcement, and Stakeholder Engagement
Transparency: Publish annual statistics on dog bite incidents, facility inspections, prosecutions, and smuggled animal seizures.
Enforcement Capacity: Address after-hours inspection constraints in AFCD Animal Management Centres. The consultation paper should review frontline staffing and quarantine capacity, while providing clearer joint-enforcement powers for Police officers responding to active dog attacks.
Engage veterinary associations, animal welfare NGOs, the insurance sector, boarding operators, and large-dog owners to strike a balance between public safety and animal welfare.
IV. Implementation Roadmap and Legislative Strategy
Phase 1 (Late 2026 Consultation): Publish the draft Breed Identification Reference Framework and enforcement data in the consultation paper. Administratively introduce boarding safety guidelines into licence conditions.
Phase 2 (2027 Legislative Amendments):
Prioritise amendments achievable via subsidiary legislation (e.g., technical definitions and equipment standards under Cap. 167D).
Introduce the "Dangerously Out of Control" primary offence, statutory Dog Control Orders, and enhanced smuggling penalties alongside broader amendments to the primary Dogs and Cats Ordinance (Cap. 167).
V. Conclusion
Public safety remains paramount. However, genuine reform must not rely solely on expanding blacklists. It requires bridging statutory gaps, erecting pre-emptive administrative safeguards, and curbing illegal smuggling and fraudulent registrations at the source. We urge the Government to incorporate these proposals into the forthcoming public consultation.
