HKEX Climate-Related Disclosures


On Apr. 14, HKEX proposed climate-related disclosures enhancement.


  • HKEX issued consultation paper on enhancement of climate-related disclosures, to seek views and comments on proposed changes to our ESG reporting framework.
  • HK GVT aims for carbon neutrality by 2050 and launched action plan with initiatives to reduce emissions, driving demand for sustainability disclosures from companies.
  • HKEX is reviewing ESG framework to align with international standards and promote sustainability, based on feedback from issuers and global regulatory developments.
  • Key Proposals
  • Mandate all issuers to make climate-related disclosures in their ESG reports, also introduce new climate-related disclosures based on the ISSB climate standard.
  • Acknowledge readiness of issuers and concerns expressed by issuers and market practitioners, proposing interim provisions for certain disclosures during interim period.
  • Core disclosures pillars: governance, strategy, risk management, metrics and targets.
  • Going Forward
  • Take into account international developments and Hong Kong market circumstances.
  • Interim provisions provided for certain disclosure requirements for first two years.
  • IPO applicants are expected to disclose ESG risks, comply with new rules upon listing.
  • Implementation guidance will be issued to assist issuers in complying with the new rules, with references to external frameworks, and glossary of terms to assist issuers.
  • Ongoing monitoring, guidance, encouragement to utilize ESG educational resources.
  • HKEX, HK SFC Reaction
  • On the same day, HKEX commented on, and HK SFC reacted to, the proposals above.
  • Proposals mark significant milestone in achieving a standing commitment to mandate FSB TCFD-aligned disclosures by 2025 as announced by the steering group (#77084).
  • Acknowledging the readiness of the issuers and their concerns, HKEX proposes interim provisions for certain disclosures for first two reporting years following Jan. 1, 2024.
  • HK SFC supports the proposals, encourages interested parties to submit comments.
  • Said proposals adopt a balanced approach which aims to give appropriate flexibility for listed firms whilst promoting relevant, consistent, comparable disclosures to investors.
  • Effectiveness
  • The consultation is open until Jul. 14, 2023.
  • Nov. 2023 Consultation Update
  • On Nov. 3, 2023, HKEX updated consultation on enhancing climate change disclosure.
  • Follows ISSB Jun. 2023 issued inaugural general and climate standards, see #177221.
  • ISSB will publish ISSB adoption guide to support jurisdictional regulators for implementation considerations; adoption guide will be available by the end of 2023.
  • HKEX will take into account the recommended approaches on the scaling and phasing-in of requirements of the adoption guide when finalizing the listing rule amendments.
  • Listing rule amendments implementation date will be postponed to Jan. 1, 2025.
  • Apr. 2024 Conclusions
  • On Apr. 19, 2024, HKEX issued conclusions to above consultation on climate disclosure.
  • 115 responses were received from a wide range of respondents, showing broad-based support for proposals; in view of this feedback, HKEX will adopt consultation proposals.
  • HKEX will closely align proposals with IFRS S2 Climate-related disclosures (IFRS S2) and provide implementation guidance referencing IFRS S1, to aid issuer compliance.
  • Introduced implementation reliefs, including proportionality and scaling-in measures, to address concerns over the reporting challenges that some issuers may face.
  • HK SFC welcomes HKEX conclusions on enhancing disclosure requirements for listed companies; requirements will be implemented in phases starting from Jan. 1, 2025.
  • In Aug. 2024, HKMA shared practice on climate-related risk governance, see #223488.
  • Dec. 2024 HKEX Review Findings
  • On Dec. 19, 2024, HKEX said it published the review findings of issuers' ESG practice disclosures, finding a 91%+ reporting rate across most aspects except labor standard.
  • Expanded review scope by 522% using AI technology to assess all listed companies' reports as of Jun. 30, 2024; found improved quality in ESG governance disclosures.
  • Large-cap issuers demonstrate understanding of upcoming climate requirements; many reporting re climate scenario analysis, scope 3 emissions, environmental targets.
  • Updated ESG academy guidance with new reg focus, added good practice examples.

Regulators HK SFC; HKEX
Entity Types B/D; Corp; Exch
Reference PR 12/19/2024; PR, Rsp, Gd 4/19/2024; PR 11/3/2023; PR, CP 4/14/2023; ESG
Functions Compliance; Environment; Financial; Operations; Reporting; Treasury
Countries Hong Kong; Cross-Border
Category
State
Products Equity; Issuance/IPO; Securities
Regions AP
Rule Type Final
Rule Date 4/14/2023
Effective Date 1/1/2025
Rule Id 169374
Linked to Rule :177221
Reg. Last Update 12/19/2024
Report Section International

Last substantive update on 12/24/2024