HKEX ESG reporting requirements, by issuer type
Hong Kong's climate disclosure rules phase in according to what kind of issuer you are. This page sets out what applies, when it applies, and what we would do first in each case.
Find your obligations
Select your issuer type. Each panel shows the current position, the timing, and the work that usually comes first.
Mandatory · FY beginning on or after 1 Jan 2026
Full Part D climate disclosure, including Scope 3
LargeCap issuers move from comply-or-explain to fully mandatory climate reporting under Part D of the HKEX ESG Reporting Code. That means Scope 3 emissions, scenario analysis, transition planning and the financial effects of climate risk — at a standard investors and auditors will test.
If your Scope 3 boundary, supplier data and scenario assumptions are not documented yet, this is the year that gap becomes visible.
Mandatory Scope 1 & 2 · comply-or-explain for the rest
Scope 1 and 2 are already required. The rest is coming.
For financial years beginning on or after 1 January 2025, every Main Board issuer must disclose Scope 1 and Scope 2 greenhouse gas emissions. The wider Part D climate disclosures apply on a comply-or-explain basis — and Hong Kong's published roadmap points toward full HKFRS S1 and S2 adoption for listed entities by 2028.
The companies that fare best treat this window as preparation, not a reprieve: build the emissions inventory properly once, then layer governance and strategy disclosure on top.
Mandatory Scope 1 & 2 · wider climate disclosure voluntary
Proportionate reporting, without over-building
GEM issuers must disclose Scope 1 and Scope 2 emissions for financial years beginning on or after 1 January 2025. The remaining Part D climate requirements are voluntary — so the question is how much to do, not whether to report.
We keep GEM engagements tight: a clean, compliant ESG report, a working emissions inventory, and a team that understands what it signed off on.
No listing rule — but customers, banks and buyers are asking
ESG as a commercial requirement, not a compliance one
Private Hong Kong companies are increasingly asked for carbon data by listed customers building their Scope 3 inventories, by banks pricing sustainability-linked facilities, and by acquirers running diligence. HKFRS S1 and S2 are available for voluntary use, and Hong Kong's roadmap points toward wider adoption over time.
For pre-IPO companies, getting this in place early removes a familiar last-minute scramble before listing.
The framework in one paragraph
ESG reporting for Hong Kong primary-listed companies sits in Appendix C2 to the Listing Rules, renamed the Environmental, Social and Governance Reporting Code. Disclosure of your ESG governance structure, reporting boundary and reporting principles is mandatory. Environmental and social aspects under Part C are comply-or-explain. Part D, added with effect for financial years beginning on or after 1 January 2025, introduces climate-related disclosures aligned with IFRS S2 across four pillars: governance, strategy, risk management, and metrics and targets.
The phase-in that matters most
- Scope 1 and Scope 2 greenhouse gas emissions: mandatory for all listed issuers for financial years beginning on or after 1 January 2025.
- Other Part D climate disclosures, including Scope 3: mandatory for Hang Seng Composite LargeCap Index constituents for financial years beginning on or after 1 January 2026.
- Other Main Board issuers: comply-or-explain for financial years beginning on or after 1 January 2025.
- GEM issuers: voluntary for the wider Part D climate disclosures.
A LargeCap issuer, for this purpose, is a company that was a Hang Seng Composite LargeCap Index constituent throughout the year immediately before the reporting year — so index membership during 2025 determines mandatory reporting for financial year 2026, published in 2027.
Where HKFRS S1 and S2 fit
The HKICPA has issued HKFRS S1 and HKFRS S2, fully aligned with the ISSB standards. They are available for voluntary use, but are not mandatory unless and until a regulator requires them. The cross-government roadmap published in December 2024 sets out an intention for full adoption by listed companies and other significant publicly accountable entities no later than 2028. In practice, most issuers are treating the HKEX Part D requirements as the near-term obligation and HKFRS S1 and S2 as the direction of travel.
Requirements change, and the position for your specific reporting year matters more than the general picture. We confirm the applicable rule set at scoping rather than assuming, and this page is reviewed against HKEX publications — but it is a summary, not advice on your circumstances.
What tends to go wrong
- Climate risks are identified for the report but never enter the enterprise risk register or capital approval process, so the risk management disclosure describes something that does not operate.
- Scope 2 is reported on one basis only, or grid emission factors are applied inconsistently across years and suppliers.
- Scenario analysis arrives as a finished document with no model behind it, and cannot answer where a number came from.
- Targets are announced ahead of the plan that would deliver them, creating a disclosure problem in later years.
- The ESG report and the annual report say slightly different things about the same matters.
Ready to scope this?
Tell us your listing status and reporting year end. We come back with a defined scope, a fee and a realistic timeline — not a brochure.