Who has to comply with the HKEX ESG Reporting Code?
All issuers listed on the Hong Kong Stock Exchange Main Board must comply with Appendix C2, the ESG Reporting Code. The new climate-related disclosures aligned with IFRS S2 are mandatory for Hang Seng Composite LargeCap and Mid Cap issuers from financial years beginning on or after 1 January 2025, and phased in for other issuers thereafter, with full application from FY2026.
When is the HKEX ESG report due?
The ESG report must be published at the same time as the issuer's annual report — within three months of the financial year end for Main Board issuers. It can be a separate report or a dedicated section of the annual report, in both English and traditional Chinese.
What are the A1-A4 and B1-B8 aspects?
Subject Area A (Environmental) contains A1 Emissions, A2 Resource Use, A3 Environment & Natural Resources, and A4 Climate Change. Subject Area B (Social) contains B1 Employment, B2 Health & Safety, B3 Development & Training, B4 Labour Standards, B5 Supply Chain, B6 Product Responsibility, B7 Anti-corruption, and B8 Community Investment.
How does HKEX ESG align with IFRS S2?
The climate-related disclosures under Part D of Appendix C2 are fully aligned with IFRS S2, covering governance, strategy, risk management and metrics & targets. Issuers already reporting under ISSB standards can reuse the same climate data for HKEX with minimal rework.
Are the disclosures comply-or-explain?
Disclosures are a mix of mandatory and comply-or-explain. General Disclosures and all KPIs are mandatory to report, but "comply or explain" applies to specific policies and practices — issuers must either disclose the required policy or explain why it is not applicable. Climate-related disclosures under Part D are mandatory.
Does the report need to be bilingual?
Yes. The ESG report must be published in both English and traditional Chinese, consistent with the HKEX listing rule requirements for corporate communications. Formist generates matched EN/繁體中文 versions of the report in a single workflow.