Know the critical compliance dates. Deploy early.
What is this China's securities regulator issues management measures strengthening independent director qualifications, nomination, duties and accountability for listed companies.
Who is affected All Mainland China listed companies
What is this The ISSB's first two sustainability standards, covering general disclosure requirements and climate-related disclosures, take effect for annual reporting periods beginning on or after this date, forming the reference baseline that HKFRS and China's CSDS align to.
Who is affected Entities in jurisdictions that have adopted IFRS S1/S2, voluntarily or mandatorily
What is this Shanghai, Shenzhen and Beijing exchanges publish sustainability reporting guidelines for designated index constituents and dual-listed companies.
Who is affected SSE 180, STAR 50, SZSE 100, ChiNext constituents and dual-listed companies
What is this The Ministry of Finance, together with eight other authorities, issues the foundational Basic Standard for corporate sustainability disclosure, aligned with ISSB principles. Voluntary adoption only, pending scope finalisation.
Who is affected Listed companies initially, with plans to extend to non-listed and smaller enterprises
What is this Scope 1 and Scope 2 GHG emissions disclosure becomes mandatory for all Main Board and GEM issuers; other climate disclosures apply on a comply-or-explain basis for Main Board issuers (mandatory for LargeCap Issuers from 2026).
Who is affected All Main Board and GEM issuers, with stricter mandatory timing for LargeCap Issuers
What is this The revised CG Code strengthens board effectiveness, risk management and disclosure. It introduces a recommended Lead INED, director tenure disclosure requirements, and an overboarding cap limiting INEDs to six Hong Kong-listed directorships (with transitional arrangements). The hard nine-year tenure cap and cooling-off period phase in later, by 2028 and 2031.
Who is affected All issuers
What is this HKFRS S1 and S2 may be applied voluntarily and are fully aligned with ISSB IFRS S1 and S2.
Who is affected All Hong Kong companies (voluntary)
What is this The Ministry of Finance and eight other ministries jointly issue China's first thematic sustainability standard, focused specifically on climate-related disclosure, building on the 2024 Basic Standard.
Who is affected Listed companies, with the biggest companies already required to report under Beijing, Shanghai and Shenzhen exchange rules from April 2026
What is this LargeCap Issuers (based on Index membership throughout 2025) must disclose the full Climate Requirements, including Scope 3 and beyond, on a mandatory basis for financial years commencing on or after this date.
Who is affected Hang Seng Composite LargeCap Index constituents
What is this Designated Mainland listed companies must publish their 2025 sustainability reports by this date.
Who is affected SSE 180 / STAR 50 / SZSE 100 / ChiNext constituents and dual-listed companies
Current date on the 2023–2031 listed-issuer path.
What is this China plans to finalise climate-specific disclosure standards and application guidance, building toward a fully unified sustainability disclosure system.
Who is affected Mainland listed companies, expanding progressively to non-listed entities
What is this Large public interest entities are expected to fully adopt HKFRS S1 and S2.
Who is affected Large listed issuers and unlisted financial institutions
What is this Long-serving INEDs cannot make up the majority of the board from the first AGM held on or after this date, as part of the phased tenure cap rollout.
Who is affected Relevant INEDs and issuers
What is this China aims for a fully operational, mandatory, ISSB-aligned sustainability disclosure regime covering listed and non-listed companies of all sizes.
Who is affected All Mainland Chinese enterprises, phased in from large to small
What is this The complete nine-year independence limit and cooling-off period requirement apply to all INEDs, completing the phased transition begun in 2025.
Who is affected All issuers and INEDs
HKEX climate rules are not one-size-fits-all. They are layered by issuer type. HKEX Appendix C2 climate requirements and HKFRS S1/S2 are two parallel tracks — do not treat them as the same regime.
Already in force for reporting periods from 2025. Layered by issuer: LargeCap must disclose in full; other Main Board issuers must disclose Scope 1 and 2, with other climate items on a comply-or-explain basis; GEM remains voluntary.
Effective 1 August 2025 for voluntary adoption, fully aligned with ISSB IFRS S1 and S2. Large public interest entities (Large PAEs) are expected to apply HKFRS SDS in full no later than 2028. Large PAEs means (a) Hang Seng Composite LargeCap constituents and (b) unlisted financial institutions with significant influence in Hong Kong.
Every Main Board issuer — large or small — must disclose Scope 1 and 2 from FY2025. Only LargeCap must make the full climate package mandatory. Other Main Board issuers may still explain rather than fully disclose governance, strategy, risk management, and metrics and targets.
The revised Corporate Governance Code took effect on 1 July 2025. Work through the checklist below, then open each item for the rule, timing and what to do next.
Mainland China is building a unified sustainability disclosure system in phases, moving from voluntary to mandatory, large enterprises to small, and qualitative to quantitative requirements, with full national coverage targeted by 2030. For A+H and dual-listed issuers, the near-term milestones below determine when Mainland obligations start running on a separate clock from HKEX Part D.
Mandatory climate disclosure (from 2026) plus the full new CG Code.
HighIFRS S2-aligned climate disclosure (comply or explain) plus the CG Code.
Medium-highHong Kong requirements plus Mainland sustainability reporting.
HighA more gradual transition, but the direction of travel is the same.
MediumMust meet the latest disclosure framework from listing.
Depends on listing date
AMMO Group Corporate Services Limited
AMMO Group advises Hong Kong–listed issuers on ESG reporting, climate disclosure and board governance under the HKEX codes. Practical notes for company secretaries and IR — not generic sustainability commentary.
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