Chinese Foreign Ministry Spokesperson Mao Ning declared earlier this week that the “Taiwan issue is purely an internal affair of China, and how to resolve the Taiwan issue is a matter for the Chinese people.” She added that “we will do our utmost to strive for the prospect of peaceful reunification. But we will never allow anyone or any force to separate Taiwan from China in any way.” 

What Mao did not say is how Beijing expects to achieve this goal. 

For decades, the centerpiece of its unification pitch has been the “one country, two systems” framework. Originally conceived to reassure Taiwan by offering autonomy under Chinese sovereignty, it now stands as one of Beijing’s least credible promises.

Its application in Hong Kong and Macao has produced two radically different outcomes: one marked by mass protest and repression, the other by quiet compliance. The contrast reveals not flexibility, but the fundamental impossibility of applying the “one country, two systems” to Taiwan.

When the UK handed Hong Kong back to China in 1997, it did so under the Sino-British Joint Declaration of 1984. The declaration promised that Hong Kong would retain its own executive, legislative, and judicial powers — excluding foreign affairs and defense — for 50 years. 

To support this promise, Beijing added Article 31 to its Constitution, establishing the legal basis for Special Administrative Regions like Hong Kong and Macao. In principle, Hong Kong would continue to enjoy a “high degree of autonomy” under the “one country, two systems” model.

For a decade, that promise seemed intact. But the 2003 attempt to pass an anti-subversion bill triggered half a million protesters, exposing Beijing’s fear of a politically assertive society. From then on, the trajectory shifted: tighter central control, manipulation of the Basic Law, and growing assimilationist pressure.

‘One country, one system’

What followed was a steady erosion of autonomy. The 2014 Umbrella Movement, demanding universal suffrage, met with repression. The 2019 protests against the extradition bill escalated into a broader democratic movement and Beijing’s response was to crush it. 

The imposition of the National Security Law, mass arrests, and the silencing of civil society made clear that one country, two systems had in fact become “one country, one system.”

These developments not only shattered Beijing’s credibility in Hong Kong but also sent a chilling message to Taiwan: the “one country, two systems” is a promise in name only.

At first glance, Macao seems to prove the opposite. Since its handover from Portugal in 1999, Macao has remained politically stable, with elites loyal to Beijing and little social unrest. In 2019, Chinese leader Xi Jinping even saluted Macao as the model for “one country, two systems.”

But Macao’s calm is misleading. Its Basic Law never promised democratization or universal suffrage. Its judiciary defers readily to Beijing. 

The political elite is dominated by casino and construction interests dependent on the central government. National education programs emphasizing obedience and patriotism faced no resistance, unlike in Hong Kong.

In reality, Macao’s compliance reflects weak democratic traditions, elite capture, and a population more integrated into Chinese identity. “One country, two systems” works in Macao because there was never space for real contestation. That is precisely why it cannot work in Taiwan

Unacceptable formula

Taiwan has long been the ultimate target of the “one country, two systems” formula. Article 31 was originally included in China’s Constitution with Taiwan in mind. 

The idea was that Special Administrative Regions like Hong Kong and Macao would serve as showcase models to promote peaceful unification. Instead, they have become warning signs.

Taiwanese society has drawn the lesson. Former President Tsai Ing-wen (蔡英文) publicly rejected the “one country, two systems” framework on multiple occasions during her tenure, emphasizing that Taiwan’s democratic institutions and way of life are fundamentally incompatible with the model. 

This rejection is widely shared across Taiwan’s political landscape and civil society. A poll released by Taiwan’s Mainland Affairs Council in April found that 84.4% of Taiwanese respondents oppose the “one country, two systems” formula proposed by Beijing.

Polls show that Taiwan’s distrust toward the Chinese government has deepened in recent years, in no small part due to events in Hong Kong. The erosion of freedoms in Hong Kong, from press liberty to judicial independence, has confirmed that unification on Beijing’s terms means the end of Taiwan’s democracy.

Unlike Hong Kong or Macao, Taiwan is a consolidated democracy with independent courts, a competitive press, a vibrant civil society, and a strong national identity. The majority identify as “Taiwanese,” not “Chinese.” Any settlement would require popular consent, and no democratic electorate will vote for a model that has failed so visibly elsewhere.

‘Two systems’ in one

Hong Kong has shown that “one country, two systems” is not a guarantee but a conditional offer: it survives only as long as citizens do not challenge Beijing’s authority. When they do, “two systems” collapse into one. Macao shows the other side of the coin: if there is no challenge, autonomy quietly erodes into irrelevance.

Either way, the outcome is the same: “one country, two systems” provides no real protection. It is less a path to peaceful coexistence than a blueprint for authoritarian expansion under the facade of constitutional compromise.

Mao Ning’s words about peaceful unification cannot erase the record. Hong Kong resisted and was repressed. Macao complied and was absorbed. Taiwan is neither — and that is why “one country, two systems” has no future there.

If China genuinely seeks a peaceful political settlement with Taiwan, it must confront a basic reality: integration cannot be imposed. The failure of the “one country, two systems” model in Hong Kong, and its hollow implementation in Macao, demonstrate that unification will require more than constitutional provisions and vague assurances. It will require a fundamental transformation in how Beijing relates to autonomy, democracy, and the will of the people.

Until then, “one country, two systems” will remain not a bridge to peace but a warning to Taiwan of what is at stake.