Question 1

What HKEX ESG reporting requirements must Hong Kong listed companies meet in 2026?

Accepted Answer

All issuers must disclose Scope 1 and Scope 2 greenhouse gas emissions. Constituents of the Hang Seng Composite LargeCap Index (that were in the index for the whole of the preceding year) must make full mandatory disclosure of Part D of the ESG Reporting Code for financial years commencing in 2026, including Scope 3; those reports are generally published in 2027. For other Main Board issuers, the remaining Part D provisions apply on a "comply or explain" basis. The HKEX Code and FAQs, as updated from time to time, prevail.

Question 2

How does ISSB S2 relate to HKEX ESG reporting?

Accepted Answer

Part D of the HKEX ESG Reporting Code is based on the ISSB's IFRS S2 climate-related disclosures. The work of an ESG adviser for Hong Kong-listed issuers is to write S2 governance, strategy, risk management and metrics into disclosure that can be published in a Hong Kong annual report — not to produce a separate international template.

Question 3

When should a December year-end issuer start its ESG report?

Accepted Answer

A December year-end ESG report is usually published in the same week as the annual report. Data inventory, Scope 3 supplier questionnaires and board climate-oversight records should not be left until the first quarter of the following year. Market practice in Hong Kong is to complete the framework and gap analysis before year-end, then lock numbers, reconcile and deliver after year-end.

Question 4

Why engage a Hong Kong ESG adviser rather than an overseas template team?

Accepted Answer

HKEX disclosure is a Listing Rule obligation. The text goes into Hong Kong annual reports, circulars and board papers, and often needs Chinese-English alignment. A local adviser works with the Code, FAQs, the LargeCap / non-LargeCap boundary, and whether the Chinese and English drafts rest on the same set of numbers.

Question 5

What is "comply or explain"? Is it different for LargeCap issuers?

Accepted Answer

For most Main Board issuers, certain Part D provisions may be explained if not complied with. For issuers that were Hang Seng Composite LargeCap Index constituents for the whole of the preceding year, Part D (including Scope 3) is mandatory from financial years commencing in 2026. LargeCap status is determined by the HKEX FAQ "in the index for the whole year" test.

Question 6

What does AMMO do, and what does it not do?

Accepted Answer

AMMO prepares and advises on ESG reports, undertakes internal control reviews and financial translation, and provides business and property valuation through partners. We do not replace the auditor's opinion on the financial statements, and we do not put unverified emissions or social data into a report.

Question 7

Does ESG reporting apply only to large companies?

Accepted Answer

No. HKEX already requires a minimum disclosure (Scope 1 and Scope 2) of listed issuers. Small and mid-cap listed issuers still file an annual report; the difference is the mandatory scope of Part D, not whether disclosure is required. Pre-IPO companies preparing for a Hong Kong listing typically rehearse against the same Code.

Question 8

How are AMMO's fees structured?

Accepted Answer

Our fees are scoped based on your listing board, financial year-end, whether this is a first-year or switch engagement, and the depth of climate and Scope 3 work required. Following a short briefing, we provide a clear proposal with scope, timeline and fee band. Where deliverables can be defined upfront, we favour fixed-scope engagements rather than open-ended enterprise retainers.

Question 9

What does Part D of the HKEX ESG Reporting Code require?

Accepted Answer

Part D sets out climate-related disclosures under four headings: governance, strategy, risk management, and metrics and targets, drawing on IFRS S2. For financial years beginning on or after 1 January 2025, every issuer must disclose Scope 1 and Scope 2 greenhouse gas emissions. Whether each remaining provision is mandatory, comply-or-explain or voluntary depends on the issuer's category and financial year, as set out in the Code and HKEX FAQs.

Question 10

What does your ESG reporting engagement cover?

Accepted Answer

A typical engagement runs from scoping and materiality assessment through data collection, greenhouse gas calculation, drafting and a compliance review against the Code, to support during management and board review and final publication. Where Part D work is in scope, it also covers the climate governance narrative, climate risk and opportunity assessment, and the Scope 3 data inventory. We confirm which of these the issuer needs before quoting.

Question 11

Do you work with issuers whose financial year does not end in December?

Accepted Answer

Yes. We build the reporting timetable from the issuer's own financial year-end, whether that is March, June, December or another date, and work backwards from its publication deadline. Data requests, Scope 3 supplier questionnaires and the board's review are scheduled against that date, so the report is not compressed into the weeks before the annual report goes to print.

Question 12

How do you approach A+H and other China-related issuers?

Accepted Answer

We work from one evidence base and present it twice: once for the HKEX ESG Reporting Code and once for any Mainland sustainability report the group also publishes. The same emissions, workforce and supply-chain figures feed both. Chinese and English drafts are prepared from that single data set and checked against each other before board sign-off, so the two reports do not contradict each other.

Question 13

Can you prepare the climate transition plan disclosure?

Accepted Answer

Yes, as part of Part D work. Where the issuer has a climate-related transition plan, we draft the disclosure of its targets, planned actions, resources, key assumptions, dependencies and progress for board review. Where the board has not adopted a plan, we help it say so accurately, without implying targets or commitments that have not been approved.

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