Recognising that businesses have a responsibility to operate in a sustainable and socially responsible manner, beyond just financial performance, the Hong Kong Exchanges and Clearing Limited’s (HKEx) Environmental, Social, and Governance (ESG) Reporting Guide aims to provide guidance and set standards for companies listed on the Hong Kong Stock Exchange to enhance their ESG performance and disclosure. The code and implemenation guide outlines a set of disclosure requirements, covering governance, climate risks, emissions, resources consumption, labour rights, anti-corruption, product responsibility, etc.

Under the requirements of latest listing rules of HKEX, an issuer must publish its ESG report on an annual basis and regarding the same period covered in its annual report. An ESG report may be presented as information in the issuer’s annual report or in a separate report. Regardless of the format adopted, the ESG report must be published on the Exchange’s website and the issuer’s website.

On 19 April 2024, HKEX published a consultation conclusions on climate disclosure requirements.

First of all, ESG Code has replaced the name of ESG Guide, meaning that its importance is further strengthened.

Critical Effective Dates of New Requirements

HKEx will adopt a phased approach by requiring issuers to report on the New Climate Requirements, as follows:

  • all listed issuers (i.e. both Main Board listed issuers and GEM listed issuers) will be required to disclose scope 1 and scope 2 GHG emissions on a mandatory basis for financial years commencing on or after 1 January 2025;
  • all Main Board listed issuers will be required to report on the New Climate Requirements (other than scope 1 and scope 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;
  • LargeCap Issuers (i.e. Hang Seng Composite LargeCap Index constituents) will be required to report on the New 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 New Climate Requirements (in addition to scope 1 and scope 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

For the avoidance of doubt, the table above only summarises issuers’ disclosure obligations under Part D of the ESG Code. Non-climate disclosure requirements set out in Parts A to C of the ESG Code will continue to apply.

Key points that we believe issuers will have to prepare early for a progressive plan to fulfill the disclosure requirements:


  • Issuers must disclose information about the governance body or individuals responsible for overseeing climate-related risks and opportunities. This includes identifying those responsible and providing details about their roles as reflected in terms of reference, mandates, role descriptions, and other related policies.
  • Oversight Functions and Management’s Role

Climate-related risks and opportunities

  • including physical risk and transition risk over the short, medium and long term.
  • A description of the current and anticipated effects of climate-related risks and opportunities on the issuer’s business model and value chain; and
  • A description of where in the issuer’s business model and value chain climate- related risks and opportunities are concentrated.

About Strategy and Decision-making

  • Current and anticipated changes to the issuer’s business model, including its resource allocation, to address climate-related risks and opportunities;
  • adaptation and mitigation efforts (whether direct or indirect);
  • transition plan the issuer has (including information about key assumptions used in developing its transition plan, and dependencies on which the issuer’s transition plan relies), or an appropriate negative statement where the issuer does not have a climate-related transition plan; and
  • how the issuer plans to achieve any climate-related targets (including any greenhouse gas emissions targets (if any))
  • Issuer will also need to disclose information on resources planning and progress of plans

Financial Impact Related Disclosures

  • Disclosures (qualitative and quantitative) on impact on financial position, financial performance and cash flows for the reporting period


  • Disclosures of information that enables an understanding of the resilience of the issuer’s strategy and business model to climate-related changes, developments and uncertainties from the identified climate-related risks and opportunities.

Risk Management Process and Related Policies

Greenhouse Gas Emissions

  • Scope 1 greenhouse gas emissions
  • Scope 2 greenhouse gas emissions
  • Scope 3 greenhouse gas emissions
  • Standards: the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) and Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011)

Capital deployment

  • the amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.

Carbon Prices

  • Information on internal carbon prices (if used)


  • Disclousres on whether climate-related considerations are factored into remuneration policy, or an appropriate negative statement

Setting and Disclosing Climate-rated Targets

  •  -hether the target is a gross greenhouse gas emissions target or a net greenhouse gas emissions target. If the issuer discloses a net greenhouse gas emissions target, the issuer is also required to separately disclose its associated gross greenhouse gas emissions target;
  • Detailed information about uses of carbon credits

Testimonials and Clients’ Recognition

GreenCo’s team possess good technical knowledge and project management skills. They deliver top quality work well within tight timeframe. They also have great communication with clients.

Sustainability Director, a famous Gaming company in Macau

GreenCo’s team is helpful and always provides prompt responses. They have demonstrated professionalism in sharing valuable insight in ESG development.

Corporate Communications Director, a well-known chain Food and Beverage company in Hong Kong

We appreciate the competence and professionalism GreenCo’s team demonstrated during the preparation and delivery of the workshop and the analysis.

Group HR and Communications Director, a well-established chemical manufacturing company originated from China

What are the key updates that Hong Kong Listed Companies should get prepared for?

  • ESG Reporting Guide will be renamed as the ESG Reporting Code

  • A new Part D headed “Climate-related Disclosures” is added, which equals  80% of the length of the current ESG Reporting Guide

  • Upgrading from the “comply or explain” provision, the proposed ESG Code mandate all issuers to make climate-related disclosures in their ESG reports

  • The effective date of the new disclosure requirements is 1 January 2025 (i.e. ESG report for FY2025 shall comply with the new requirements)

  • Interim provisions are available for certain disclosures (financial effects of climate-related risks and opportunities, scope 3 emissions and certain cross-industry metrics) for the first two reporting years following the effective date

  • Issuers have a two-year grace period and are expected to fully comply with all the new climate-related disclosures in financial years commencing on or after 1 January 2027 (i.e. the ESG Report for FY2027 must fully comply with all new requirements).
  • The new climate-related disclosures will be categorised under four core pillars: 1) Governance; 2) Strategy; 3) Risk management and 4) Metrics and targets

In view of:

  1. The level of complication and the level of resources required to fully comply with the proposed climate-related disclosure is much higher than the current ESG reporting framework;
  2. The nature of the proposed climate-related disclosures is mandatory, meaning that issuers are not possible to use general and brief explanations to fulfil the disclosure requirement as under the “comply or explain” provision; and
  3. Investors’ demand and stakeholders’ expectations of transparent and accountable disclosure are surging,

GreenCo suggests companies getting prepared as soon as possible.

What are the detailed scope of ESG reporting or disclosure services GreenCo provides?

Attributed to our experience and professionalism, GreenCo can offer you the following services:

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.
For more information, please refer to the consultation paper published by the HKEX via:

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