HKEX ESG Reporting Code

The Hong Kong Stock Exchange (HKEX) ESG Reporting Guide (Appendix C2 to the Listing Rules) establishes mandatory and "comply or explain" ESG disclosure requirements for all companies listed on the Main Board and GEM, making Hong Kong one of Asia's most rigorous ESG disclosure regimes.

The ESG Reporting Guide was first introduced in 2013 on a voluntary basis, upgraded to "comply or explain" in 2016, and significantly strengthened in 2020 with mandatory governance disclosures and enhanced environmental reporting requirements. The Guide is structured around two subject areas — Environmental and Social — with a total of 12 Aspects and associated Key Performance Indicators (KPIs).

Structure and Requirements

The Guide comprises two levels of disclosure obligations. Mandatory Disclosure Requirements (MDRs) cover governance structure for ESG issues, reporting principles (materiality, quantitative, balance, consistency), and reporting boundary. These must be disclosed by all issuers without exception.

"Comply or Explain" Provisions cover specific environmental and social aspects. Environmental aspects include emissions (A1), use of resources (A2), the environment and natural resources (A3), and climate change (A4). Social aspects include employment (B1), health and safety (B2), development and training (B3), labour standards (B4), supply chain management (B5), product responsibility (B6), anti-corruption (B7), and community investment (B8).

Key Disclosure Requirements

Under the 2020 revisions, issuers must disclose the board's oversight of ESG issues, including the board's consideration of ESG risks and opportunities, the process for identifying material ESG factors, and how ESG issues are managed. Environmental KPIs require quantitative disclosure of greenhouse gas emissions (Scope 1 and 2), energy consumption, water consumption, and waste generation, with targets and progress reporting.

The climate change aspect (A4) requires disclosure on significant climate-related issues that have impacted or may impact the issuer, and the actions taken to manage them. This was further strengthened by the 2025 climate disclosure requirements aligned with ISSB standards.

Reporting Principles

The Guide requires issuers to apply four reporting principles: Materiality (focus on issues that are sufficiently important to investors and stakeholders), Quantitative (KPIs should be measurable with comparative data), Balance (reports should provide an unbiased picture), and Consistency (consistent methodologies for meaningful comparisons over time).

Enforcement and Compliance

HKEX monitors compliance through its review programme and may issue guidance letters or take disciplinary action for non-compliance with mandatory requirements. The exchange publishes annual ESG reporting reviews highlighting common deficiencies and best practices, which serve as practical guidance for issuers.

Further Reading

• HKEX ESG Reporting Guide — Official guide
• HKEX ESG Academy — Training resources

Related Topics

• HKEX Climate Disclosure
• HK Green Taxonomy
• IFRS S1 & S2\n