New Era of Climate Disclosure for Hong Kong Listed Companies

On 19 April 2024, the Hong Kong Stock Exchange (“HKEX”) released Consultation Conclusions laying out the new requirements in respect of climate-related disclosures following from the consultation paper released in April 2023. The Consultation Conclusions address a number of comments raised by stakeholders in relation to the consultation paper and aligns the disclosure requirements with those of IFRS S2 Climate-related Disclosures (“IFRS S2”) to the maximum extent possible.

It substantially enhances climate-related disclosures under the HKEX Main Board and GEM Listing Rules including the disclosure of financial effects of climate risks and opportunities, climate-related scenario analysis and the quantum of greenhouse gas emissions, subject to a number of different implementation reliefs. The effective date of the amended Listing Rules is 1 January 2025 and a phased approach is introduced based on dividing HKEX issuers into three tiers with differentiated requirements as to mandatory, "comply or explain" or voluntary disclosures to help issuers transition to the new requirements. In addition, the HKEX has issued an Implementation Guidance for Climate Disclosures under HKEX ESG reporting framework to assist issuers in understanding, interpreting and implementing the new requirements.

This Deloitte newsletter outlines the most significant requirements including information on practical exemptions and the phased approach of the new requirements. It also compares the requirements with those of IFRS S2 and the sustainability reporting guidelines for listed companies recently issued by three Chinese mainland stock exchanges. In addition, this newsletter provides insight on next steps including thinking on the opportunities and challenges HKEX reporters will face as a result of the new requirements and how Deloitte can help.

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