Governance Briefing — HKEX ISSB-aligned climate disclosure rules

Executive briefing: On 19 April 2024 Hong Kong Exchanges and Clearing Limited (HKEX) published consultation conclusions introducing ISSB-aligned climate disclosures into the Listing Rules (Appendix C2). All issuers must comply for financial years commencing on or after 1 January 2025, with limited transitional relief for the first two reporting years. Boards must disclose governance structures overseeing climate-related risks and opportunities, management roles, and linkage to strategy, risk management, and targets.

Key governance signals

Board responsibility. Issuers must describe the board’s oversight of climate matters, frequency of discussions, and information received.
Management roles. Disclosures must explain management’s responsibilities and how climate governance integrates with internal control frameworks.
Transition relief. Issuers may omit certain quantitative metrics in the first two years but must still describe governance and qualitative processes.

Action checklist

Update board and committee charters to incorporate HKEX climate governance expectations and reporting cadence.
Map existing TCFD disclosures to ISSB requirements, identifying gaps in governance, risk management, and metrics narratives.
Coordinate finance, sustainability, and risk teams to produce consolidated governance evidence for annual reports.

Enablement moves

Deliver director training on ISSB concepts, HKEX transitional relief, and investor expectations.
Enhance data governance and documentation for scenario analysis, transition plans, and target-setting processes.
Engage auditors or assurance providers early to assess readiness for future assurance requirements.

Sources

Zeph Tech assists Hong Kong issuers with ISSB-aligned governance narratives, director training, and disclosure control integration ahead of FY2025 reporting.