HKEX Climate Disclosure (Listing Rule Appendix C2 / Part D)

Applies to

Issuers listed on the Stock Exchange of Hong Kong; phased by Main Board / GEM, LargeCap / Mid- and Small-Cap.

Key points

• LargeCap issuers (constituents of Hang Seng Composite LargeCap Index): mandatory Scope 1–3 from FY2026.
• All other Main Board issuers: comply-or-explain initially, mandating later.
• Aligned with ISSB IFRS S2; integrates with HKEX ESG Reporting Guide.

Practitioner questions

• Are H-share Indian-parent issuers (if any) treated as LargeCap issuers under HKEX?

Sources

• HKEX — New Climate Requirements