ESG in Practice · 2025–26 · Listing Disclosures

HKEX Climate Rules: IFRS S2 Enters the Listing Rules

Among the first exchanges to write IFRS S2 into listing rules — three tiers of issuers, three different clocks.

Updated: 2026-10-21 Reading time: ~9 min Series: ESG & Green Finance
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On 19 April 2024 HKEX published its climate-disclosure consultation conclusions, writing IFRS S2 into Appendix C2 of the Listing Rules (the ESG Code) — making Hong Kong one of the first exchanges in the world to do so. The rules took effect 1 January 2025, but not uniformly: three issuer tiers, three different clocks. Misidentify your tier and you misread your deadline — this piece helps you place yourself.

FY2025LargeCaps: Scope 1+2 mandatory; other Main Board: comply-or-explain
FY2026LargeCaps: all new requirements mandatory
115Consultation responses, broad market support
IFRS S2Baseline; ISSB-prepared reports deemed compliant
Three issuer tiers, three compliance clocksMandatory intensity differs across LargeCap, other Main Board and GEM issuers LargeCap issuers (Hang Seng Composite LargeCap Index)Scope 1+2: mandatory FY2025 | other new rules: mandatory FY2026 Other Main Board issuersComply-or-explain from FY2025 GEM issuersVoluntary disclosure from FY2025
One rulebook, three intensities — LargeCaps are the proving ground, smaller issuers get a runway

What the new rules require

The new climate provisions follow IFRS S2's four pillars: governance (how the board and management oversee climate risk), strategy (climate-risk impact on the business model, transition plans, resilience analysis), risk management (identification and treatment of climate risks), and metrics & targets (Scope 1/2/3 emissions, industry metrics, internal carbon pricing, remuneration linkage). Scope 1+2 is the most concrete "numbers task" — LargeCaps already owe it for FY2025.

HKEX also issued implementation guidance (referencing IFRS S1) plus "reasonable information" and "capabilities/resources" relief provisions — issuers may disclose using reasonable information available at the reporting date rather than perfect data. A pragmatic design: if the regime demanded perfect data first, it would never start.

"Comply-or-explain" doesn't mean "optional"

Comply-or-explain reads lenient; practice is harsher. If you don't disclose you must state why — and "we lack the data" reads as a confession to investors. In an era when institutions build ESG into research, "we are unable to disclose" is itself a signal. The subtlety: voluntary on the surface, enforced by market discipline underneath.

RegSir's take — the cleverness is the mixed grip: mandatory for LargeCaps (resources and impact), comply-or-explain for the rest (no crushing smaller issuers at once). Practical advice: don't wait for the mandate — the FY2025 "explain" window is for testing the water and buying time; start the data infrastructure now and FY2026 won't be a scramble. A bonus for going straight to ISSB: an ISSB-prepared report is automatically deemed compliant with the climate rules — one job, two boxes ticked.

Compliance checklist

Official sources

DocumentIssuerDate
Climate disclosure consultation conclusionsHKEX2024.4.19
Listing Rules amendments (Update No. 146)HKEX2024.4
New climate requirements — effective-date tableHKEX2024
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