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)

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)

In December 2023, Bangladesh Bank issued a circular mandating IFRS S1 and S2 disclosures by all banks and financial institutions it regulates, with limited assurance required from the second year of reporting.

Enforcement

Mandatory

Effective date

Annual reports for financial years beginning on or after 1 January 2024

Covered entities

Listed and non-listed banks and finance companies regulated by Bangladesh Bank, including foreign banks and finance companies operating in Bangladesh