HKEX Climate-related Disclosure Rules

HKEX Climate-related Disclosure Rules: ifrs s2-aligned mandatory climate disclosure for hong kong-listed issuers, phased in from fy 2025 starting with large cap companies.

Jurisdiction
Status
active
Category
climate
First deadline
Effective for financial years beginning January 1, 2025; Large Cap mandatory FY 2025
Who must comply
Applies to Hong Kong-listed entities across specified industries (Energy, Financial Services, Healthcare, Manufacturing, Real Estate, Retail, Technology, Transportation). Requirements vary by issuer class, with Large Cap, other Main Board, and GEM issuers on differing mandatory and comply-or-explain timelines.
Penalties
Non-compliance can lead to public censure or reprimand, share suspension or delisting, monetary penalties, and reputational harm under Securities and Futures Commission oversight.

What it is

The HKEX Climate-related Disclosure Rules are issued by Hong Kong Exchanges and Clearing Limited (HKEX) and align with IFRS S2 Climate-related Disclosures and the ESG Listing Rules. They require Hong Kong-listed issuers to disclose climate-related governance, strategy, risk management, and metrics and targets. The rules phase in mandatory reporting by issuer class, starting with Large Cap companies.

Who must comply

Applies to Hong Kong-listed entities across specified industries including Energy, Financial Services, Healthcare, Manufacturing, Real Estate, Retail, Technology, and Transportation. Obligations differ for Large Cap, other Main Board, and GEM issuers, with mandatory, comply-or-explain, and voluntary treatment phased over time.

What you must disclose

Issuers must disclose governance, strategy, risk management, and metrics and targets addressing climate change, including mandatory Scope 1 and 2 GHG emissions, with Scope 3 initially recommended. Reports require board approval and must be filed within four months of fiscal year-end.

Timeline

The rules were introduced via consultation conclusions on April 19, 2024, effective for financial years beginning January 1, 2025. For FY 2025, Large Cap issuers face mandatory reporting, other Main Board issuers report on a comply-or-explain basis, and GEM reporting is voluntary. From FY 2026 onward, all Main Board reporting is mandatory, with GEM voluntary but expected to align progressively.

Stay ahead of this regulation.

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