Frequently asked questions
Answers to common questions on HKEX ESG reporting, climate disclosure, internal control and how AMMO works with listed issuers.
What HKEX ESG reporting requirements must Hong Kong listed companies meet in 2026?
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.
How does ISSB S2 relate to HKEX ESG reporting?
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.
When should a December year-end issuer start its ESG report?
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.
Why engage a Hong Kong ESG adviser rather than an overseas template team?
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.
Why should an internal control review be done together with ESG reporting?
If ESG figures have no reconcilable collection and approval process, annual-report disclosure and directors' confirmations are exposed. An internal control review for a Hong Kong listed company assesses whether controls are adequate by business cycle; the same process can support emissions, labour and supply-chain ESG data, so the two reports do not tell different stories.
What is "comply or explain"? Is it different for LargeCap issuers?
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.
What does AMMO do, and what does it not do?
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.
Does ESG reporting apply only to large companies?
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.
How are AMMO's fees structured?
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.