Two Platforms, No One Page: Forty-Nine Days Before Full Portability, the Trustee Comparison Legislators Asked For Still Is Not There

Forty-nine days to launch. On 21 December 2026, Phase One of MPF full portability begins, and about one million employees who entered the workforce or changed jobs on or after 1 May 2025 will be able, once in every calendar year, to move the whole of their employer mandatory-contribution balance to a personal account in a scheme of their own choice. The decision is a trustee decision: which scheme should hold the entire balance? The information system Hong Kong has built answers a different question. It compares funds, one at a time, and services, one scheme at a time — on two separate platforms, in two different units, with fees and performance deliberately kept apart. The one page that joins them up does not exist.

The core proposition: the legislator specified three axes; no single page carries all three

On 26 October, on radio, lawmaker Chau Siu-chung set out what members need: the MPFA should consolidate the different trustees’ information into simple comparisons that employees can take in at a glance, covering trustees’ and funds’ fees and services. In the same day’s reporting he framed the choice itself the way members frame it: move to a trustee you judge to have lower administration fees, better service or higher returns. Three axes — fees, service, returns.

That is a precise specification, and it is testable. A member page passes only if one screen shows, scheme by scheme: what the scheme charges on average, what its funds have returned on a like-for-like basis, and what service it provides. This audit checked the two official platforms and the trustees’ current scheme documents against that specification. Neither platform passes, and the failure is structural, not a missing update: each platform was designed to exclude what the other holds.

The data: two platforms, two units, and the join that nobody publishes

The Fund Platform compares funds, not trustees. With data as of 30 September 2026 it lists all 382 constituent funds, with a median risk indicator of 9.86%. Its “My Selection” tool places up to 10 funds side by side on performance, fees and risk — a powerful instrument for choosing between two Hong Kong equity funds. A full-portability transfer, however, does not buy a fund; it moves an entire balance into a scheme’s whole menu, most of which the member has not yet selected. There is no scheme-average FER on the platform, no scheme-level return, and no service information at all. Ten funds side by side is not a trustee comparison; it is one-tenth of one, repeated 38 times.

The Trustee Service Comparative Platform compared services — and, on audit day, it was not even reachable. The MPFA launched it on 28 September 2012, for the Employee Choice Arrangement era, grouping dozens of services under three headings: fund choices (types and counts), account administration (processing times for transfers, withdrawals and contribution settlement), and customer services (statement frequency, enquiry channels, online services). Its own user guide performs the separation in plain language: for fees and charges, go to the separate fee platform (whose functions now sit inside the Fund Platform); for past performance, it offers no comparison at all. The data were supplied by each scheme’s trustee, the MPFA stated that it did not warrant their accuracy, and the processing times shown were those to be achieved “under general circumstances only”. Fees: excluded by design. Returns: excluded by design. And on 1 November 2026, repeated attempts to open the platform returned a DNS failure — its host name no longer resolves — while the MPFA’s main site and the Fund Platform loaded normally in the same check, and the MPFA’s current Useful Tools page (last reviewed 30 April 2026) no longer lists it. Yet current scheme documents still send members there: Bank of East Asia’s current Key Scheme Information Document directs members to that platform to check which schemes offer TVC and SVC accounts. A member who follows the direction today reaches a dead address.

The eMPF era has quietly hollowed out the service axis. In 2012 administration genuinely differed by trustee, because every trustee ran its own paperwork. The MPFA’s own milestone record now states that, with the last scheme onboarded at the end of April 2026, the eMPF Platform is in full operation handling scheme administration for all MPF schemes, and the platform fee charged to schemes fell from 0.37% to 0.29% of assets in April 2026. What still differs by trustee is precisely what neither platform aggregates: the fee level of the menu, its breadth, the performance of the funds on it, and the commercial terms attached to moving in. The page members need in 2026 is not the 2012 page with fresher data; it is a different page.

The missing number exists — just not on an official page. A scheme-average FER is computable, and this site computed it: the mpf.hk fee-history database (22 October 2026) puts the cheapest trustee sample average at Bank of East Asia, 1.0738%, and the dearest at Manulife, 1.4188% — a gap of 0.345 percentage points. The market-average FER is about 1.36%, against an actual average of about 0.77% for Default Investment Strategy funds, a gap of 0.59 points. None of those four numbers appears on either official platform in scheme form. What does appear, prominently, on trustee pages is the transfer incentive: Manulife’s HK$6,300 for a transfer-in of HK$1–2 million, Bank of East Asia’s HK$88,888 for HK$5 million or more. In the absence of a comparison page, the incentive table is the comparison page — the only scheme-level, dollar-denominated document most members will ever see, and it is written by the sellers.

The compounding cost: a 0.345-point gap nobody is shown

Price the invisible gap. At 0.345 percentage points, a HK$250,000 balance pays about HK$863 more a year in the dearest-average scheme than in the cheapest-average one; on the average member balance of about HK$339,000 (MPF Ratings, end-September 2026), about HK$1,169 a year. On this series’ standard illustrative model — HK$5,000 a month, a 7% gross return, monthly compounding — the 0.345-point gap is worth about HK$15,000 over 10 years, about HK$92,000 over 20 years and about HK$318,000 over 30 years. The wider 0.59-point gap between the market average and the DIS average runs to about HK$26,000, HK$160,000 and HK$559,000 over the same horizons. These are sample averages across funds, not a quote for any individual member’s portfolio — but that qualification is itself the finding: the only scheme-level fee averages in public are a news site’s, because the regulator’s platforms publish the ingredients and not the dish.

The timing compounds the information gap. GUM’s survey (13–15 August 2026, 808 members, published 21 October) found only 18.2% fully understood full portability. Members who cannot assemble the comparison in November will face the 2026 window — 21 to 31 December, across the Christmas holidays — with the incentive pages as their default guide, while a transfer executes on forward pricing at T+1/T+2 values nobody can lock in, with the balance out of the market for about one to two weeks in transit (a ±2% move on HK$250,000 is ±HK$5,000). None of that argues against moving. It argues that a million people should not be asked to make a trustee-level decision with fund-level tools.

The fix: a five-column standard, and a do-it-yourself version until it exists

The page legislators asked for needs five columns per scheme, no more: (1) scheme-average FER and its range; (2) the menu — number of funds, how many are index trackers, and the scheme’s DIS fund FERs; (3) like-for-like anchor performance — every scheme’s Core Accumulation Fund, Age 65 Plus Fund and Hang Seng Index tracker over identical 5- and 10-year windows; (4) the transfer terms — current incentives and their forfeiture clauses, and the scheme’s bid-offer spread wording; (5) the service items that still genuinely differ in the eMPF era, such as whether TVC and SVC accounts are offered. Every input already exists in official data; only the join is missing.

Until it exists, a member can approximate it in three sittings. First, on the Fund Platform, filter by trustee and compare the same three anchor categories in each candidate scheme — Core Accumulation Fund, index tracker, and the fund type you actually hold — on FER and 5-/10-year returns. Second, for the service layer there is currently no live official home: check each candidate scheme’s Key Scheme Information Document and brochure directly for account types offered (including TVC and SVC) and statement services, and treat any processing time quoted from the old service platform as pre-eMPF reference, not a promise. Third, read the candidate scheme brochure’s fee table and the incentive terms themselves — the forfeiture clause and the bid-offer line — before any number in an advertisement. Describe, compare, then decide: this article recommends no trustee and no transfer. It records that, 49 days before the largest trustee choice Hong Kong members have ever been offered, the one page that would let them make it at a glance still has not been built — by anyone official.

Sources and basis: launch date, eligibility and mechanics, MPFA full-portability pages and the Chairman’s Blog of 25 October 2026; the legislator’s request, RTHK reporting of 26 October 2026 (via on.cc) and SCMP reporting of the same programme; Fund Platform scope and figures, MPFA MPF Fund Platform (data as of 30 September 2026: 382 funds, median risk indicator 9.86%, “My Selection” up to 10 funds); service platform scope, exclusions and disclaimers, MPFA press release of 28 September 2012 and the platform’s user guide (September 2012); its reachability and omission from the MPFA’s current Useful Tools page (last reviewed 30 April 2026), checked live on 1 November 2026 (repeated DNS failures for the platform host while the MPFA main site and Fund Platform loaded normally); its continued citation, Bank of East Asia (MPF) Master Trust Scheme Key Scheme Information Document (current version, directing members to the platform for TVC/SVC availability); eMPF full operation and the 0.37% to 0.29% platform fee, MPFA Annual Report 2025-26 milestones; scheme-average FERs, mpf.hk fee-history database, 22 October 2026 (sample averages across each trustee’s funds); average balance and system figures, MPF Ratings September 2026; awareness figures, GUM MPF confidence survey, August 2026; incentives, trustee published terms as tracked on 23 October 2026. Compounding figures are illustrative calculations with assumptions stated in the text, not return forecasts. This article is information and analysis, not personal investment advice or a recommendation of any trustee, scheme or fund.