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31 May 2023 • Articles

Morrow Sodali

HKEx proposes more comprehensive climate related disclosures to listed companies 港交所建议上市公司披露更全面的气候相关资料



HKEx has recently published a consultation paper seeking market feedback on a proposal to enhance climate-related disclosures under the existing ESG reporting framework. The proposed disclosures would apply to all listed companies, coming into effect from 1 January 2024.

HKEx’s proposal is in line with ISSB and TCFD recommendations covering four thematic areas. The key points are highlighted below:

1.    Governance: Disclosure on the governance process, controls and procedures the board uses to monitor and manage climate-related risks and opportunities

2.    Strategy: Quantitative and qualitative disclosures on the current and future effects of climate change on the financial position, performance, and cash flows, as well as the  issuers’ strategies and operations to build climate resilience

3.    Risk Management: Disclosure on the process for identifying, assessing and managing climate related risks and opportunities, and their integration into the overall risk management process

4.    Metrics and Targets: Upgrading the reporting obligation for greenhouse gas accounting to include also Scope 3 emission reporting, and providing disclosures on industry-based metrics such as capital deployment, internal carbon prices and remuneration policy etc to assess the performance on climate-related target achievements as well as climate mitigation and adaption efforts

IPO applicants should also commence the necessary preparatory work to align with the new disclosure requirements and to ensure their readiness and compliance.

These disclosure enhancements are expected to maintain Hong Kong’s competitiveness as an international financial centre, to keep pace with international developments, to reflect stakeholders’ expectations and to facilitate capital allocation towards a more sustainable future.

Please contact Morrow Sodali ESG Team for the latest marketing trending and practical guidance on how to get ready for the new requirements.

Click here to view the consultation paper.

Consultation Paper on Enhancement of Climate-related Disclosures under the Environmental, Social and Governance Framework (



1. 治理:披露董事会用于监督和管理气候相关风险和机遇的管治流程、监控和程序

2. 策略:披露发行人所面临的气候相关风险和机遇以及应对措施,对公司财务状况、财务表现及现金流的当前和预期影响,以及发行人的策略和运营对气候相关变化的抵御力

3. 风险管理:披露用于识别、评估和管理气候相关风险和机遇的流程,并将其纳入整体风险管理过程

4. 指标及目标扩展温室气体排放的披露至范围三的排放量,披露资本运用、内部碳价格、薪酬政策和其他跨行业指标,以评估发行人应对气候变化的表现



如需获取最新的ESG趋势以及新要求的实用指导,请联系Morrow Sodali ESG团队。


 有關優化環境、社會及管治框架下的氣候相關信息披露的諮詢文件 (



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