HKEX ESG Code
HKEX Listing Rules Appendix C2 — Environmental, Social and Governance Reporting Code
Topic : ESG disclosure · Level : Stock exchange
Today
Part D climate rules from FY2025. Scope 1-2 for all; full climate mandatory FY2026 for HSCLI LargeCap. FAQ updated Apr 2026.
Summary
HKEX's ESG Reporting Code added ISSB-aligned climate rules from 1 January 2025. All Main Board issuers must report Scope 1 and 2 emissions. LargeCap issuers must make full climate disclosures, including Scope 3, from 2026.
Who is concerned
- Turnover
- non précisé
- Employees
- non précisé
- Listed company
- cotées seulement
- Sectors
- All sectors
- Triggering activities
- Main Board listing (GEM: climate voluntary)
- Hang Seng Composite LargeCap constituent
- Extraterritorial reach
- Yes
Many issuers are mainland groups; Scope 3 and value-chain disclosures pull data from suppliers.
- Examples
- H-share mainland automaker
- HK property developer
- LargeCap tech group
What the law requires
- Publish ESG report with annual report
- Disclose Scope 1 and 2 GHG emissions
- Disclose climate governance, strategy, risks, Scope 3 (comply or explain)
Penalties
Listing Rules disciplinary sanctions: public censure, criticism, directors' unsuitability statements. No fixed fines.
What this changes for a supplier in China
HK-listed buyers (many mainland groups) need Scope 3 data; LargeCap issuers must disclose fully from FY2026, so supplier requests rise.
Expected evidence
- Scope 1 and 2 emissions
- Product or spend-based Scope 3 inputs
- Climate risk information
Tiers : Tier 1-2