In the last ten years or so, the governments in many countries have paid more attention to citizenship education. In fact, citizenship education has become an important element in the primary and secondary schools curriculum of these countries. In Hong Kong the government has paid special attention to citizenship education since the mid-1980s when it was decided that China was to regain the sovereignty of Hong Kong from 1997. In addition, the promotion of citizenship education was also necessary as a result of the start of the process of democratization in the early 1980s. To facilitate the implementation of citizenship education in Hong Kong, two official documents were published to provide guidelines for schools principals and teachers. There are different views regarding the nature and the dimensions of citizenship education. According to Lawton (2000), there are at least two views concerning the definitions of citizenship education. They are (1) passive citizenship view of training for conformity and obedience and (2) educating the future citizenship for active participation in a democratic society. Heater (1990) suggests that citizenship education has three dimensions: elements (identity and loyalty, virtues, legal or civic status, political and social rights), geographical levels (local, nation-state, regional or world) and outcomes of education (knowledge, attitudes and skills). More recently, researchers such as Lee (2004) have also suggested to examine citizenship education from an Asian perspective. The aim of this paper is to examine the problems and controversies related to the implementation of citizenship education in Hong Kong from a comparative education perspective. Examples of these problems include the low status of the subject, the lack of training of teachers and the very crowded curriculum which restricts the inclusion of more subjects such as citizenship education. One further problem is that under the 'one country - two system' there are heated