Two SFC circulars went out on 30 September, numbered 26EC61 and 26EC60. One is a roadmap for intermediaries to implement the Hong Kong Investor Identification Regime for the exchange-traded derivatives market. The other sets out how those intermediaries should obtain client consent under it.

The roadmap is the half a technology team reads. It is a build plan: what gets done, in what order, by whoever runs the order-routing and reporting systems.

The consent circular is the half a compliance head reads, and it is the harder one. A system change can be scheduled, tested and signed off inside the firm. Consent has to come from the client, one account at a time, and a client who never opens the email has not consented to anything.

So the work for a derivatives desk is a list of every account that trades exchange-traded contracts, a record of which have given consent under the SFC's procedure, and a record of which have not. The second list is the one a supervisor will ask to see.

The news block does not carry a go-live date, and I will not supply one. The first place to look is the roadmap circular, 26EC61, on the SFC's circulars site. A firm that has not yet read that document does not know how long its consent exercise has.