HKFRS S1 and HKFRS S2 – Hong Kong Sustainability Disclosure Standards

HKEX listing rules require all Main Board issuers to disclose climate information aligned with IFRS S2 on a comply-or-explain basis from 1 January 2025, with mandatory application for Hang Seng Composite LargeCap constituents from 1 January 2026. Some elements differ from IFRS S2 (e.g., scope of consolidation, industry-based metrics).

Enforcement

Comply-or-explain for all Main Board issuers from 1 January 2025. Mandatory for Hang Seng Composite LargeCap Index constituents from 1 January 2026.

Effective date

1 January 2025 (comply-or-explain); 1 January 2026 (mandatory for HSCI LargeCap)

Covered entities

All HKEX Main Board issuers (comply-or-explain); HSCI LargeCap constituents (mandatory)

Hong Kong's Product Eco-responsibility Ordinance is umbrella legislation under which EPD has rolled out three Producer Responsibility Schemes covering plastic shopping bags (2009), waste electrical and electronic equipment (2018, enhanced 2024) and glass beverage containers (2023). Suppliers pay levies that fund WEEE Park and licensed glass and plastic recyclers.

Enforcement

Mandatory

Effective date

PERO enacted July 2008; Plastic Shopping Bag Charging Scheme effective 7 July 2009 (full coverage 1 April 2015 and charge raised 31 December 2022); WEEE PRS effective 1 August 2018, enhanced scope from 1 July 2024; Glass PRS phased in first half 2023

Covered entities

Suppliers and sellers of regulated electrical equipment (8 categories pre-2024, all EEE from July 2024), retailers selling plastic shopping bags, and suppliers of glass beverage containers placed on the Hong Kong market

Australia has issued ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory under the Corporations Act for in-scope entities; AASB S1 (broader sustainability) is voluntary.

Enforcement

AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.

Effective date

Annual reporting periods beginning on or after 1 January 2025 (phased by entity size)

Covered entities

Group 1, 2, 3 entities under AASB thresholds (large entities first; phased rollout to mid-size and smaller large entities)

The UK government has endorsed IFRS S1 and S2 as UK SRS S1 and S2 for voluntary use. The FCA is consulting on listing rules that would make UK SRS S2 mandatory for listed issuers, with Scope 3 and non-climate sustainability on a comply-or-explain basis.

Enforcement

Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).

Effective date

TBD pending FCA listing-rule outcome

Covered entities

Any UK entity (voluntary). FCA proposal targets in-scope listed issuers.

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. Standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025.

Enforcement

Voluntary

Effective date

Annual reporting periods beginning on or after 1 January 2025 (with transition reliefs)

Covered entities

Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.

SSBJ published final sustainability disclosure standards on 5 March 2025: an Application Standard, a General Standard, and a Climate Standard. The standards are essentially equivalent to IFRS S1 and S2. Mandatory application phases in by market capitalization.

Enforcement

Voluntary now. Mandatory under FSA disclosure framework on phased basis by market cap.

Effective date

Voluntary for periods ending on or after 5 March 2025. Mandatory phased: FY ending March 2027 for issuers with market cap >¥3T, expanding through FY ending March 2029.

Covered entities

Listed issuers in Prime Market (phased by market cap)