In December 2019, the Hong Kong Stock Exchange has issued its consultation conclusions on proposals to enhance the Environmental, Social and Governance (“ESG”) Reporting Guide and related Listing Rules. Under the new ESG Reporting requirements, which have already been applying to the listed firms for financial years commencing on or after 1 July 2020, what may trip up most issuers in meeting the requirements is the challenge of setting and revealing its development targets concerning sustainability as the latest listing rules expressly require the disclosure of targets for KPIs A1.5 (emission targets), A1.6 (reduction targets), A2.3 (energy use efficiency targets) and A2.4 (water efficiency targets) on a “comply or explain” basis in the ESG Reporting Guide. When reporting on corresponding targets, it goes without saying that essentials for a standard target language including the baseline and context, range and locations of entities included, expected results and timeline for achieving them, and whether they are voluntary or mandatory (i.e. based on legislation), and if mandatory, then specify the relevant legislation that should be considered and disclosed. Among all four types of targets that are to be set and presented, however, setting appropriate targets for emissions, especially greenhouse gas (“GHG”) emissions, seems to be the hardest as it is the only one that is directly related to the impacts the business operations may have on climate change and that can be used to holistically measure the effectiveness of a variety of steps taken to accomplish the reduction targets, energy use efficiency targets and water efficiency targets, which can all be efficiently established step-by-step with reference to the recommendations and indicators in “An Analysis of the Goals and Targets by the Global Reporting Initiative and the UN Global Compact”.