Complete guide to Hong Kong Exchange ESG disclosure requirements for listed companies. Covers ESG standards-aligned climate disclosure, mandatory reporting timelines, Scope 1/2/3 emissions, and compliance steps.
Complete guide to Hong Kong Exchange ESG disclosure requirements for listed companies. Covers ESG standards-aligned climate disclosure, mandatory reporting timelines, Scope 1/2/3 emissions, and compliance steps.
Since January 2025, all companies listed on the Hong Kong Stock Exchange (HKEX) must comply with enhanced ESG reporting requirements under the ESG Code (Appendix C2 of the Listing Rules). These requirements represent the most significant overhaul of ESG disclosure in Hong Kong's history.
The key changes include:
The international sustainability standards published global ESG frameworks Climate-related Disclosures in June 2023. HKEX has adopted these standards, meaning listed companies must disclose:
Board oversight of climate-related risks and opportunities. This includes the board's role in reviewing strategy, risk management policies, and progress against targets.
Climate-related risks and opportunities that could affect the company's business model, strategy, and financial planning. Companies must perform scenario analysis, including a 2°C or lower scenario.
Processes for identifying, assessing, and managing climate-related risks. This must include both physical risks (extreme weather, sea level rise) and transition risks (policy changes, technology shifts, market shifts).
Quantitative disclosures including:
| Metric | Requirement |
|---|---|
| Scope 1 emissions | Mandatory — direct emissions from owned/controlled sources |
| Scope 2 emissions | Mandatory — indirect emissions from purchased energy |
| Scope 3 emissions | Mandatory — all other indirect emissions in value chain |
| Climate targets | Mandatory — quantitative targets with timelines |
| Transition plan | Mandatory — strategy to achieve climate targets |
The enhanced ESG Code applies to all HKEX Main Board and GEM-listed companies. There are no exemptions based on size or sector. Key groups affected:
| Financial Year Starting | Requirements |
|---|---|
| On or after 1 Jan 2025 | Full ESG standards-aligned climate disclosure mandatory for all listed companies |
| On or after 1 Jan 2026 | Scope 3 emissions disclosure required (with transitional relief for certain categories) |
| On or after 1 Jan 2027 | Independent assurance of Scope 1 and 2 emissions required |
Many Hong Kong companies lack established systems for collecting emissions data, especially Scope 3. The supply chain data gap is significant for companies with mainland China operations.
Board members often lack ESG expertise. HKEX requires disclosure of board ESG governance, including how directors oversee climate risk management.
Scope 3 — covering the entire value chain — is the most challenging category. It includes emissions from purchased goods, business travel, employee commuting, waste, and investments.
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Yes. Since 2025, all companies listed on HKEX must comply with the enhanced ESG reporting requirements, including mandatory climate-related disclosures aligned with international ESG standards.
HKEX has adopted ESG standards-aligned climate disclosure standards (international disclosure requirements). Listed companies must disclose Scope 1, 2, and 3 greenhouse gas emissions, climate risks and opportunities, and transition plans.
The enhanced ESG Code requirements became effective for financial years starting on or after 1 January 2025. Companies must include climate-related disclosures in their annual ESG reports.
Peak M&S Education Centre offers ESG Sustainable Solutions 4.0, a government-funded courses covering HKEX ESG reporting, international ESG standards, and climate disclosure. Next intake: 25-26 July 2026. WhatsApp +852 4423 7445.
HKEX may impose sanctions including public censure, director liability declarations, and trading suspensions for persistent non-compliance with ESG reporting requirements.
Yes. All Main Board and GEM-listed companies must comply, regardless of market capitalisation. However, there are transitional provisions for Scope 3 emissions disclosure through 2026.
ESG reporting focuses on Environmental, Social, and Governance factors relevant to investors and regulators. Sustainability reporting is broader, covering all impacts. HKEX requires ESG reporting specifically, with climate disclosure as the mandatory core.
Our ESG Sustainable Solutions 4.0 course covers everything you need for HKEX compliance. Government funding available.
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