ESG in Practice · 2021–22 · Product Level

SFC ESG Fund Circular: The Three Hard Rules

A fund that wants to call itself "ESG" faces three binding requirements under the circular.

Updated: 2026-10-21 Reading time: ~9 min Series: ESG & Green Finance
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A fund wanting to call itself an "ESG fund" in Hong Kong can't just change its name. SFC circular 21EC27 (issued 29 June 2021, effective 1 January 2022) sets three hard rules: ESG must be the fund's key investment focus before it can be named that way; offering documents must disclose how ESG is actually done; and the fund must be periodically assessed — at least annually — on whether it delivers. This piece unpacks the circular's operational requirements, and how it became Hong Kong's first gate against greenwashing.

21EC27Circular ref — replaces the 2019 version
2022.1.1Effective date
~60SFC-authorised ESG funds when the circular issued
AnnualMinimum frequency of periodic assessment

Three lines: naming, disclosure, periodic assessment

The circular's structure is clean, organised around one core principle: name must match substance.

RuleRequirementPractical meaning
NamingESG or similar terms (green, sustainable, climate…) must "accurately and proportionately" reflect the fund's ESG features — no overstatement; funds without an ESG focus generally shouldn't use such namesThe name is the first audit point — name and holdings not matching is an instant problem
DisclosureOffering documents must explain how the ESG focus is implemented — investment strategy, screening criteria, reference benchmarks, ESG data sources and methodologyDisclosure isn't form-filling — the SFC is checking how you do ESG, not how you talk about it
Periodic assessmentThe manager must assess, at least annually, how the fund attains its ESG focus, and disclose this to investorsESG is an ongoing commitment — the account comes due every year

Which funds are caught

The circular governs SFC-authorised funds that take ESG factors as a "key investment focus" and reflect that focus in their investment objective or strategy. The keyword is "key" — merely "considering" ESG in the investment process is not the same as making ESG a focus. A conventional equity fund calling itself "ESG-aware" without ESG driving its selection logic should not be marketed under an ESG-style name.

The circular adds specific guidance for climate-themed funds — funds claiming to invest in climate transition/decarbonisation must disclose how they define "climate-related," how they screen, and how they measure outcomes.

RegSir's take — this circular is the foundation of Hong Kong's anti-greenwashing architecture. It doesn't rely on a "greenwashing offence"; it works through the product-authorisation gate: to sell an ESG-named fund to retail, you pass naming review, disclosure review and annual assessment. The SFC also publishes a database of authorised ESG funds with key features — transparency itself is the discipline. For fund managers: naming is a marketing decision but a compliance responsibility — legal/compliance sign-off should come before the name goes out.

Compliance checkpoints

Official sources

DocumentIssuerDate
ESG funds circular (21EC27)SFC2021.6.29
New ESG fund disclosure guidance — press releaseSFC2021
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