(A) Introduction
Over the past 16 months, Hong Kong Competition Commission (the “Commission”) has intensified its enforcement efforts against bid-rigging in the building maintenance sector.
As discussed in an earlier article,[1] bid-rigging in Hong Kong's building maintenance sector rarely operates in isolation. It often involves complex syndicates comprising consultants, contractors, property managers and incorporated owners. These parties collude and offer bribes to secure favourable treatment, violating both the Competition Ordinance (Cap. 619) (the “Competition Ordinance”) and the Prevention of Bribery Ordinance (Cap. 201) (the “POBO”).
Over the past 16 months, Hong Kong Competition Commission (the “Commission”) has intensified its enforcement efforts against bid-rigging in the building maintenance sector.
As discussed in an earlier article,[1] bid-rigging in Hong Kong's building maintenance sector rarely operates in isolation. It often involves complex syndicates comprising consultants, contractors, property managers and incorporated owners. These parties collude and offer bribes to secure favourable treatment, violating both the Competition Ordinance (Cap. 619) (the “Competition Ordinance”) and the Prevention of Bribery Ordinance (Cap. 201) (the “POBO”).
Given the complexity of such cases, the Commission has deepened inter-agency cooperation, particularly with the Independent Commission Against Corruption (the “ICAC”). This cooperation has been demonstrated by two joint operations conducted in April 2024 [2] and August 2024 [3], the signing of a Memorandum of Understanding in December 2024 [4] as well as the joint participation in the Building Management Summit in June 2025.[5]
The Commission’s solo operation on 5 August 2025 [6] marked a new chapter, uncovering violent intimidation tactics in Kowloon City. The Commission executed search warrants at four premises, including the offices of a building maintenance contractor and a building maintenance consultant, as
well as the residences of the individuals involved. The operation targeted a suspected bid-rigging scheme for a private housing estate maintenance project, in contravention of the First Conduct Rule under the Competition Ordinance.
This article examines the three main operations (April 2024, August 2024, and August 2025), highlighting their similarities, differences, and implications for the evolving enforcement landscape in Hong Kong.
(B) Similarities of the Operations
All the operations share four major similarities:
(1) Sector Focus
Each operation targeted bid-rigging syndicates within Hong Kong's building maintenance sector:
(B) Similarities of the Operations
All the operations share four major similarities:
(1) Sector Focus
Each operation targeted bid-rigging syndicates within Hong Kong's building maintenance sector:
(a) The April 2024 joint operation disrupted a newly-rising syndicate manipulating renovation tenders across six estates on Hong Kong Island and the New Territories.
(b) The August 2024 joint operation uncovered bribery and collusion affecting 38 residential estates / buildings, and industrial buildings in Hong Kong Island, Kowloon and the New Territories.
(c) The August 2025 solo operation addressed tender manipulation at a private housing estate.
(2) Key Actors and Syndicate Composition
Participants were similar across the operations:
(a) The April 2024 operation involved 20 individuals, including the syndicate’s mastermind and core members, for example, project contractors, consultants, middlemen, Incorporated Owners, and property management personnel.
(b) The August 2024 operation involved project contractors, consultants, middlemen, property management staff, and Incorporated Owners.
(c) The August 2025 operation indicated that a building maintenance consultant may have colluded with a contractor to manipulate tenders.
(3) Enforcement Tools
The Commission employed its statutory powers during these operations, including executing search warrants at offices and residences, demanding document production and information disclosure, and summoning witnesses to provide relevant information.
(4) Potential Victims involved
The operations covered building maintenance projects across Hong Kong Island, Kowloon, and the New Territories. The bid-rigging schemes exploited both private and public housing estates, resulting in inflated costs that placed heavy financial burdens on property owners.
(C) Differences of the Operations
The operations differ in four main aspects:
(1) Violations
The April and August 2024 joint operations specifically addressed collusion that violated the First Conduct Rule of the Competition Ordinance and Section 9 of the POBO.
The 5 August 2025 solo operation also focused on bid-rigging that contravened the First Conduct Rule of the Competition Ordinance, but marked an escalation, as it uncovered cases where bid-rigging involved violent intimidation and physical coercion—representing a significant intensification of tactics.
(2) Investigation Scope
The April 2024 joint operation targeted renovation projects across six locations: two residential estates and residential-commercial composite buildings on Hong Kong Island and four residential estates and industrial buildings in the New Territories. Individual contracts for such renovation projects are worth a total of around HK$180 million.
The August 2024 joint operation expanded significantly to renovation projects in 38 residential estates / buildings, and industrial buildings in Hong Kong Island, Kowloon and the New Territories. The value of the relevant renovation contracts totaled over HK$1 billion, with individual contracts worth as much as HK$260 million. This shows exponential scale growth from the previous operation.
In contrast, the August 2025 solo operation focused narrowly on a single private housing estate in the Kowloon City District, with the bid amount reaching HK$40 million approximately.
(3) Agency Roles
The April and August 2024 joint operations involved collaboration between the Commission and the ICAC. In contrast, the 5 August 2025 operation was conducted solely by the Commission.
(4) Enforcement Challenges
During the April 2024 joint operation, the Commission faced obstruction of its investigations, contravening Sections 52 and 54 of the Competition Ordinance.
(D) Key Takeaways
In conclusion, the Commission has significantly stepped up its efforts to combat bid-rigging in the building maintenance sector. It has reiterated its commitment to combat anti-competitive practices that seek profit at the expense of property owners, aiming to maintain a level-playing field in the building maintenance sector.
Further, recent investigations reveal an escalation from traditional collusive tactics to violent intimidation and physical coercion, signaling a new and serious phase of bid-rigging activities.
Given the Commission’s above focus, building maintenance companies should focus on three key pillars:
(1) Staff Training and Awareness: Regularly train staff and management on competition laws, anti-bribery regulations, and the risks associated with bid-rigging.
(2) Strong Internal Policies: Develop and enforce policies that prohibit collusive practices, bribery, and intimidation.
(3) Secure Systems: Implement transparent bidding procedures to minimize opportunities for collusion or manipulation.
By adopting these practices, companies can better safeguard themselves against legal risks, contribute to a fair industry environment, and uphold their reputation in the marketplace.
(3) Enforcement Tools
The Commission employed its statutory powers during these operations, including executing search warrants at offices and residences, demanding document production and information disclosure, and summoning witnesses to provide relevant information.
(4) Potential Victims involved
The operations covered building maintenance projects across Hong Kong Island, Kowloon, and the New Territories. The bid-rigging schemes exploited both private and public housing estates, resulting in inflated costs that placed heavy financial burdens on property owners.
(C) Differences of the Operations
The operations differ in four main aspects:
(1) Violations
The April and August 2024 joint operations specifically addressed collusion that violated the First Conduct Rule of the Competition Ordinance and Section 9 of the POBO.
The 5 August 2025 solo operation also focused on bid-rigging that contravened the First Conduct Rule of the Competition Ordinance, but marked an escalation, as it uncovered cases where bid-rigging involved violent intimidation and physical coercion—representing a significant intensification of tactics.
(2) Investigation Scope
The April 2024 joint operation targeted renovation projects across six locations: two residential estates and residential-commercial composite buildings on Hong Kong Island and four residential estates and industrial buildings in the New Territories. Individual contracts for such renovation projects are worth a total of around HK$180 million.
The August 2024 joint operation expanded significantly to renovation projects in 38 residential estates / buildings, and industrial buildings in Hong Kong Island, Kowloon and the New Territories. The value of the relevant renovation contracts totaled over HK$1 billion, with individual contracts worth as much as HK$260 million. This shows exponential scale growth from the previous operation.
In contrast, the August 2025 solo operation focused narrowly on a single private housing estate in the Kowloon City District, with the bid amount reaching HK$40 million approximately.
(3) Agency Roles
The April and August 2024 joint operations involved collaboration between the Commission and the ICAC. In contrast, the 5 August 2025 operation was conducted solely by the Commission.
(4) Enforcement Challenges
During the April 2024 joint operation, the Commission faced obstruction of its investigations, contravening Sections 52 and 54 of the Competition Ordinance.
(D) Key Takeaways
In conclusion, the Commission has significantly stepped up its efforts to combat bid-rigging in the building maintenance sector. It has reiterated its commitment to combat anti-competitive practices that seek profit at the expense of property owners, aiming to maintain a level-playing field in the building maintenance sector.
Further, recent investigations reveal an escalation from traditional collusive tactics to violent intimidation and physical coercion, signaling a new and serious phase of bid-rigging activities.
Given the Commission’s above focus, building maintenance companies should focus on three key pillars:
(1) Staff Training and Awareness: Regularly train staff and management on competition laws, anti-bribery regulations, and the risks associated with bid-rigging.
(2) Strong Internal Policies: Develop and enforce policies that prohibit collusive practices, bribery, and intimidation.
(3) Secure Systems: Implement transparent bidding procedures to minimize opportunities for collusion or manipulation.
By adopting these practices, companies can better safeguard themselves against legal risks, contribute to a fair industry environment, and uphold their reputation in the marketplace.
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