Quick Guide: Key Sustainability Disclosure Regimes: Hong Kong SAR: Climate disclosure rules under Hong Kong Listing Rules

For issuers listed in Hong Kong, the Hong Kong Exchanges and Clearing Limited (“HKEX”) lifted the climate-related disclosure requirements in April 2024 (the “HKEX New Climate Requirements”) which apply in phases for financial years commencing on or after 1 January 2025. The HKEX New Climate Requirements have been developed based on the International Sustainability Standards Board’s (“ISSB”) IFRS S2 under the “climate-first” approach.

The HKEX New Climate Requirements can be found in Part D of the ESG Code in Appendix C2 to the Hong Kong Listing Rules (the “ESG Code”) issued by HKEX and it sets out ESG disclosure requirements to be reported on an annual basis by Hong Kong primary-Main Board listed issuers. 

The HKEX New Climate Requirements have been implemented in phases, as follows: 

* “LargeCap” issuers refers to Hang Seng Composite LargeCap Index constituents. 

The HKEX New Climate Requirements have been developed based on the ISSB’s IFRS S2 under the “climate-first” approach.

Although the HKEX New Climate Requirements do not include the requirements of IFRS S1, issuers are encouraged to refer to and apply the Implementation Guidance issued by the HKEX which contains relevant principles in IFRS S1 for preparing disclosures under the HKEX New Climate Requirements.

The amended ESG Code permits issuers to apply certain reliefs to address concerns regarding an issuer’s readiness to comply with the new requirements and concerns over data availability when preparing the disclosures to meet the HKEX New Climate Requirements.

For the purpose of the HKEX New Climate Requirements: 

• An issuer must disclose information about climate-related risks and opportunities that could reasonably be expected to affect its cash flows, its access to finance or cost of capital over the short, medium or long term.
• Information determined by an issuer’s board of directors to be sufficiently important to investors and other stakeholders should also be reported.
• Part D of the ESG Code sets out the HKEX New Climate Requirements. Other existing disclosure requirements set out in Parts A to C of the ESG Code continue to apply and all issuers must continue to report on the relevant provisions in their ESG reports.   

An issuer is required to publish the ESG report at the same time as its annual report.

In 2024, the following were published: 

The Hong Kong Institute of Certified Public Accountants (the “HKICPA”) – designated as the sustainability reporting standard setter in Hong Kong - published the HKFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and HKFRS S2 Climate-related Disclosures (the “HKFRS Sustainability Disclosure Standards”) that are fully aligned with the ISSB standards, with an effective date of 1 August 2025 for voluntary use.

The Hong Kong SAR Government published the “Roadmap on Sustainability Disclosures in Hong Kong” (the “Roadmap”) which sets out the approach and proposed timeline for “publicly accountable entities (“PAEs”)” to adopt the HKFRS Sustainability Disclosure Standards.  The Roadmap has indicated that the HKEX New Climate Requirements are intended as an interim step for listed issuers to start climate reporting early in accordance with the ISSB standards. 

HKEX intends to consult the market in 2027 on mandating listed PAEs to report sustainability following the HKFRS Sustainability Disclosure Standards. It is envisaged that this consultation will focus on a few key points as follows: 

• Replacing the current ESG Code with a requirement for listed issuers to publish sustainability reports under the HKFRS Sustainability Disclosure Standards.
• Mandating assurance for sustainability disclosures and the approach in phasing-in these requirements. 

The implementation of the  HKFRS Sustainability Disclosure Standards is expected to be introduced in a proportionate  manner, with the consultation process considering a phasing-in of reporting entities starting with more advanced issuers (e.g. Large Cap Issuers), to ensure proportionality in sustainability-related disclosure requirements. The standards may apply to the first batch of listed issuers for financial years beginning on or after 1 January 2028. 

There are separate rules on climate disclosures for financial institutions and asset managers and asset owners which are administered by the Hong Kong Monetary Authority and the Securities and Futures Commission.

Under the Roadmap, relevant financial regulators will require financial institutions carrying a significant weight (being non-listed PAEs) to apply the HKFRS Sustainability Disclosure Standards no later than 2028. 

On 29 December 2025, the Accounting and Financial Reporting Council (“AFRC”) published a consultation paper on the proposed regulatory framework for sustainability assurance, which proposes (subject to further consultations by HKEX) that entities subject to mandatory reporting using HKFRS Sustainability Disclosure Standards must obtain independent assurance in phases. 

• HKEX Implementation Guidance (April 2024)
• Appendix C2 of the Listing Rules 

• Client briefing - Hong Kong Stock Exchange introduces new climate-related disclosure requirements
• Blog post - Hong Kong SAR publishes HKFRS Sustainability Disclosure Standards
• Blog post - Hong Kong SAR Government publishes roadmap on sustainability disclosures
• Quick Guide on ISSB standards