Hong Kong Exchanges and Clearing Limited (HKEX)
HKEX consistently raises expectations for ESG reporting. Listed companies are required to meet defined governance, environmental, social, and climate disclosure requirements, with mandatory climate reporting expanding from 2025. This guide outlines what HKEX expects and how organisations can deliver ESG-compliant reports with confidence.
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What is the HKEX ESG code?
Hong Kong Exchanges and Clearing Limited (HKEX) ESG code, previously known as the HKEX ESG or environmental, social, and governance reporting guide, requires disclosures of listed companies. HKEX acts as the regulator of reporting ESG standards and oversees the disclosure of listed companies on both the Main Board and the Growth Enterprise Market (GEM).
Over the past decade, HKEX ESG regulations have evolved from voluntary guidance into a structural ESG reporting guide aligned with the international ESG policy.
What are Hong Kong and HKEX ESG reporting rules?
HKEX first introduced ESG disclosure obligations in 2013. Since then, the ESG code has been revised several times, especially in 2019, with the environmental KPI update in 2021 and then through the introduction of new climate-related disclosures under Part D of the ESG.
Today, the HKEX reporting code is built on:
- Part A: Principles and structure of the HKEX ESG reporting
- Part B: Mandatory disclosure requirements focusing on the governance, process, and scope aspects of all listed issuers
- Part C: “Comply-or-explain” approach on the core ESG performance
- Part D: Climate-related disclosures under the governance, strategy, risk management, and metrics and targets core pillars aligned with IFRS and the TCFD recommendations
ESG reports must be published annually, covering the same reporting period as the company’s annual reports, and released within five months of the financial year-end.
Mandatory Disclosures
Under Part B of the ESG Code, all issuers must include a board statement in their ESG report that explains:
- The board’s oversight of ESG matters
- The ESG management’s approach and strategy outline on how material ESG risks are evaluated and prioritised
- How the board reviews progress against ESG goals and targets
Issuers must also explain how they apply the ESG reporting principles of materiality, qualitative reporting, and consistency, including:
- How material ESG topics are identified
- What ESG standards, methodologies, and assumptions are used
- Any changes to KPIs or reporting methods
Companies must clearly define the reporting boundary, outlining which entities and operations are included and why.
“Comply-or-Explain” Disclosures
Part C of the HKEX ESG reporting guide adopts a comply-or-explain approach across environmental and social subject areas. Issuers must either report the required information or provide clear reasons for any non-disclosure or omission.
Environmental disclosures
- Air emissions and waste generation and handling.
- Energy and water use and resource efficiency
- Emission reduction targets and performance tracking
Social disclosures
- Workforce composition and turnovers
- Health and safety performance and labour standards
- Employee practices, training, and development
- Supply chain management
- Product responsibility and community investment
- Anti-corruption practices
This structure allows flexibility and maintains accountability that encourages companies to build ESG policies that reflect their actual risks and operations.
Why are the HKEX regulations important?
HKEX ESG reporting requirements are a shift from compliant reporting to forward-thinking sustainability disclosure. Investors now expect insight into how ESG issues affect business models, financial performance, and long-term resilience.
The regulations also place accountability squarely on the board. It reinforces ESG as a board responsibility that affects capital access, investor confidence, and regulatory standing in a market progressively shaped by sustainability expectations.
Who needs to comply with the HKEX ESG reporting?
The HKEX ESG reporting guide applies to:
- All Main Board listed companies
- All GEM-listed companies
Climate-related disclosures apply differently depending on issuer size and listing status. But scopes 1 and 2 greenhouse gas (GHG) emissions are already mandatory for all listed issuers from 2025 onwards.
What are the HKEX ESG reporting requirements?
At a high level, issuers must follow this HKEX checklist:
- Publish an annual ESG report or include ESG disclosures within their annual report
- Follow the ESG reporting principles set out by HKEX
- Disclose mandatory governance and reporting information
- Address environmental and social KPIs on a comply-or-explain basis
- Prepare climate-related disclosures under Part D of the ESG Code
HKEX recognises other ESG standards, including GRI, SASB, CDP, and the IFRS Sustainability Disclosure Standards, as long as the disclosures remain comparable to HKEX ESG reporting requirements.
What is the scope of HKEX ESG reporting?
HKEX ESG reporting spans four environmental and eight social aspects under Parts B and C of the ESG Code. The climate-related risks and opportunities are addressed separately under Part D.
Climate disclosures cover:
- Governance and management oversight
- Climate-related risks and opportunities
- Business model and value chain scope
- Financial impacts and resilience
- Risk management processes
- GHG emissions (scopes 1, 2, and 3)
- Targets, transition plans, capital deployment, and carbon pricing
The scope extends beyond operations to include relevant parts of the value chain where material climate risks or emissions exist.
What is the implementation timeline for HKEX ESG reporting?
HKEX has adopted a phased approach for climate-related disclosures:
From financial years starting 1 January 2025
- All issuers must disclose scope 1 and scope 2 GHG emissions.
- Main Board issuers and LargeCap issuers (constituents of the Hang Seng Composite LargeCap Index) report other climate disclosures on a comply-or-explain basis.
- GEM issuers are encouraged to report beyond scope 1 and 2 emissions disclosures on a voluntary basis during the transition period.
From financial years starting 1 January 2026
- LargeCap issuers or the constituents of the Hang Seng Composite LargeCap Index: must comply with all Part D climate disclosures on a mandatory basis.
How Presgo Supports HKEX ESG Reporting
Presgo ESG reporting software helps organisations create sustainability reports according to the HKEX ESG Reporting Code and IFRS S2 by offering a well-organised platform that connects data, disclosures, and governance.
Presgo’s customisable solutions for your HKEX reporting:
Data Hub
Presgo’s Data Hub centralises ESG data, defines reporting boundaries, and maintains validation checks and audit trails for Part B disclosures
Disclosure Hub
Disclosure Hub structures HKEX- and IFRS S2-aligned narratives, including comply-or-explain disclosures
Carbon Calculator
Carbon Calculator supports Part D by tracking and reporting Scope 1, 2, and 3 greenhouse gas emissions
Materiality Assessment
The Materiality Assessment supports Part B and Part C by identifying and prioritising ESG and climate topics based on stakeholder input
Presgo helps companies move from fragmented ESG data to ESG-compliant and sustainable reporting that stands up to regulatory review and stands out to market expectations.
