A New Era of ESG Reporting in Hong Kong

Under the latest Hong Kong Exchanges and Clearing Limited (HKEX) Listing Rules, all listed issuers must publish an Environmental, Social, and Governance (ESG) report annually, covering the same reporting period as their annual report. Issuers may incorporate ESG disclosures directly into their annual report or publish a standalone report. Regardless of the chosen format, the ESG report must be published on the Exchange’s website and the issuer’s official corporate website.

Starting 1 January 2025, companies listed on the Hong Kong Stock Exchange are required to enhance their ESG performance in compliance with the ESG Reporting Code. Climate Requirements further align with the International Sustainability Standards Board (ISSB) Climate Standard. To assist issuers, HKEX published an implementation guidance on climate disclosures outlining practical steps and available reliefs.

At GreenCo, we support Hong Kong listed companies throughout every stage of their ESG reporting journey. From greenhouse gas (“GHG”) accounting and climate risk assessment to governance enhancement and full ESG report preparation, our experienced consultants provide practical solutions that enable organisations to meet regulatory expectations while creating long-term business value.

Whether you are preparing your first climate-related disclosures or enhancing your existing reporting practices, our team can help you develop a structured roadmap towards full compliance with the HKEX ESG Reporting Code.

What Has Changed?

The revised HKEX ESG Reporting Code introduces considerably more comprehensive disclosure requirements than the previous ESG Reporting Guide. Rather than focusing primarily on environmental performance indicators, companies are now expected to explain how climate considerations are integrated throughout their governance, strategic planning and business operations.

Governance

Listed companies are required to disclose the governance arrangements responsible for overseeing climate-related risks and opportunities. This includes explaining the responsibilities of the board, relevant committees and senior management, together with their oversight processes, reporting mechanisms and decision-making responsibilities. Organisations should also demonstrate how climate considerations are incorporated into governance policies, board discussions and strategic oversight.

Climate Strategy

Companies should identify the climate-related risks and opportunities that may affect their businesses over the short, medium and long term. These include both physical risks, such as extreme weather events and rising temperatures, and transition risks arising from regulatory changes, technological developments and market transformation towards a low-carbon economy.

Issuers are also expected to explain how these risks and opportunities may affect their business model, value chain, products, services and long-term strategy.

Risk Management

Climate-related risks should be incorporated into the organisation’s existing risk management framework. Companies should describe how climate risks are identified, assessed, prioritised, monitored and managed, together with how climate-related risk management integrates with the wider enterprise risk management process.

Greenhouse Gas Accounting

Comprehensive GHG accounting remains one of the fundamental requirements under the HKEX ESG Reporting Code. Companies are expected to quantify and disclose Scope 1, Scope 2 and progressively Scope 3 GHG emissions in accordance with internationally recognised standards, including the GHG Protocol Corporate Accounting and Reporting Standard and the Corporate Value Chain (Scope 3) Standard.

Reliable GHG inventories provide the foundation for climate target setting, emissions reduction planning and future climate disclosures.

Climate-related Financial Effects

Companies are expected to explain both the qualitative and quantitative financial implications of climate-related risks and opportunities. This includes describing the potential impacts on revenue, operating costs, assets, liabilities, capital expenditure, financing activities and future cash flows where relevant.

As investors increasingly seek financially relevant sustainability information, climate disclosures are expected to move beyond narrative descriptions towards more decision-useful financial information.

Metrics, Targets and Transition Planning

Organisations should disclose the climate-related metrics used to monitor performance together with any climate targets they have established. Where GHG reduction targets are disclosed, companies should explain their baseline year, target year, progress achieved and methodologies applied.

Where applicable, companies should also explain their climate transition plan, resource allocation, decarbonisation initiatives and any reliance on carbon credits or offsets.

Key Areas Companies Should Prepare

  • Strengthening Climate Governance

  • Conducting Climate Risk Assessments

  • Performing Climate Scenario Analysis

  • Developing Robust GHG Inventories

  • Assessing Financial Impacts

  • Developing Transition Plans

  • Improving ESG Data Management

  • Setting Meaningful Climate Targets

Implementation Timeline

HKEX Reporting1

How GreenCo Can Help

GreenCo provides comprehensive advisory services that support organisations throughout every stage of HKEX ESG reporting and climate disclosure implementation.

HKEX ESG Gap Assessment

We review your current ESG reporting practices against the latest HKEX ESG Reporting Code and identify practical actions required to strengthen future disclosures.

GHG Accounting

Our consultants prepare comprehensive Scope 1, Scope 2 and Scope 3 GHG inventories in accordance with internationally recognised methodologies, providing reliable emissions data for reporting and target setting.

Climate Risk Assessment

We help organisations identify material physical and transition climate risks affecting their operations, assets, supply chains and long-term business strategy.

Climate Scenario Analysis

Our team performs qualitative and quantitative climate scenario analysis to evaluate organisational resilience under different climate futures, supporting both regulatory compliance and strategic decision-making.

Climate-related Financial Impact Assessment

We assist companies in assessing how climate-related risks and opportunities may affect financial performance, financial position and future cash flows, supporting investor-focused disclosures.

ESG Data Collection and GHG Accounting Programme

To improve reporting efficiency, GreenCo also develops customised ESG data management systems and automated GHG accounting programmes that streamline data collection, emissions calculations and KPI monitoring across multiple reporting periods.

HKEX ESG Report Preparation

Our experienced consultants prepare professionally written ESG reports aligned with the latest HKEX ESG Reporting Code while ensuring disclosures remain practical, balanced and decision-useful.

Board and Management Training

We provide customised workshops for directors, senior management and sustainability teams to strengthen understanding of HKEX climate disclosure requirements and emerging international sustainability reporting developments.

Why Choose GreenCo?

GreenCo is a specialist sustainability consultancy dedicated exclusively to ESG reporting, climate disclosure and greenhouse gas accounting. Since our establishment, we have supported numerous Hong Kong and Singapore listed companies across a wide range of industries in strengthening their sustainability reporting and climate governance.

Our advisory approach combines technical expertise with practical implementation experience. Rather than simply interpreting reporting standards, we work closely with our clients to develop solutions that are proportionate, achievable and aligned with their organisational objectives.

Our consultants possess extensive experience in HKEX ESG Reporting Code compliance, IFRS S1 and IFRS S2 advisory, GHG accounting, climate scenario analysis, materiality assessments and sustainability strategy development. By integrating regulatory knowledge with practical business understanding, we help organisations build credible sustainability reporting that meets both regulatory expectations and investor needs.

Whether your organisation is preparing for its first HKEX ESG report or seeking to enhance existing climate disclosures, GreenCo is committed to providing practical, high-quality advisory services that support long-term sustainable business growth.

Frequently Asked Questions

  • All listed issuers (i.e., both Main Board listed issuers and GEM listed issuers) are required to disclose scope 1 and 2 GHG emissions on a mandatory basis for financial years commencing on or after 1 January 2025;
  • All Main Board listed issuers are required to disclose the Climate Requirements (other than scope 1 and 2 GHG emissions which are required to be disclosed by all issuers) on a “comply or explain” basis for financial years commencing on or after 1 January 2025;
  • Large Cap Issuers (i.e., Hang Seng Composite LargeCap Index constituents) will be required to disclose the Climate Requirements on a mandatory basis for financial years commencing on or after 1 January 2026; and
  • GEM listed issuers are encouraged to report on the Climate Requirements (in addition to scope 1 and 2 GHG emissions which are required to be disclosed by all issuers) for financial years commencing on or after 1 January 2025, on a voluntary basis.

Yes. The HKEX ESG Reporting Code progressively introduces Scope 3 GHG disclosure requirements, although implementation relief are available for eligible issuers.

Yes. The climate-related disclosure requirements introduced under Part D of the HKEX ESG Reporting Code are substantially aligned with the ISSB IFRS S2 Climate-related Disclosures Standard, subject to certain implementation reliefs and local modifications.

The preparation period depends on the complexity of the organisation, data availability and the maturity of existing ESG management systems. Starting preparations 3-4 months before the reporting deadline is generally recommended, particularly where climate-related disclosures require additional assessments or governance enhancements.

GreenCo provides end-to-end advisory services covering HKEX ESG reporting, greenhouse gas accounting, climate risk assessment, climate scenario analysis, ESG data management, board training and sustainability reporting, enabling organisations to strengthen both regulatory compliance and long-term sustainability performance.

Disclaimer: This material has been simplified for understanding and is not exhaustive. This material cannot be relied upon to cover specific situations and the information in this material is not suggested to be used without obtaining specific professional advice. GreenCo and its directors, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance upon the information in this material or for any decision based on it.

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