沪深北交易所及港交所可持续发展报告披露规则对比（中英）

在可持续发展日益成为全球共识的今天，无论是A股的细化要求，还是港股的国际对标，都推动企业更实质地管理并披露其环境影响。披露已超越合规本身，成为企业展现责任、透明与战略韧性的核心方式。顺应趋势、主动融入，方能在新的市场规则中赢得信任，走向长远。

Comparison of Sustainability Report Disclosure Rules of the Shanghai-Shenzhen-Beijing, and Hong Kong Stock Exchanges

On September 5th, under the unified guidance of the China Securities Regulatory Commission, the Shanghai, Shenzhen, and Beijing Stock Exchanges simultaneously solicited public comment on three new environmental guidelines for the "Sustainability Reporting Guidelines". These guidelines introduce more practical disclosure requirements for pollutant emissions, energy use, and water resource utilization. Building on the existing framework and climate disclosure framework, these revisions further strengthen the sustainability disclosure system for A-share listed companies and reflect a regulatory trend toward aligning the granularity of ESG rules with those of the Hong Kong Stock Exchange.

As ESG disclosure continues to evolve, how companies accurately understand policies, efficiently complete disclosures, and strengthen ESG performance management has become crucial for investor trust and brand reputation. Under the new regulations, listed companies should proactively benchmark against best practices and transform compliant disclosures into a source of competitiveness. This article will compare the ESG requirements of the Shanghai-Shenzhen-Beijing, and Hong Kong Stock Exchanges, offering forward-looking, practical advice for companies.

The Hong Kong Stock Exchange (HKEX) currently uses a single-dimensional principle of "financial materiality." Materiality is defined as "when the board determines that environmental, social, and governance (ESG) matters are material to investors and other stakeholders, the issuer should report them." Materiality assessment for climate-related disclosures is based on "climate-related risks and opportunities that could reasonably be expected to affect its short-, medium-, or long-term cash flows, access to financing, and cost of capital." This suggests that the core of the HKEX's materiality approach is focusing on how ESG risks impact companies from the perspective of investors and other stakeholders.

The Shanghai, Shenzhen, and Beijing Stock Exchanges have explicitly proposed the "Double Materiality" principle. This requires not only an assessment of the substantive impact of ESG issues on a company's financiales (financial materiality), but also an assessment of the significant economic, social, and environmental impacts of a company's activities (impact materiality), embodying both an "inside-out" and "outside-in" perspective.

Hong Kong stocks tend to favor an investor perspective, focusing on how ESG impacts corporate value, while new A-share rules further align with international standards (such as the EU's CSRD), requiring companies to simultaneously examine their own impact on the global economy, reflecting a more comprehensive perspective on responsibility. In the long term, double materiality analysis is likely to become a new trend in global sustainability disclosure. Listed companies are advised to proactively embrace the double materiality principle, focusing not only on the impact of ESG issues on financial performance and risks (financial materiality) but also systematically assessing the actual and potential impact of their operations on the economy, society, and the environment (impact materiality). This will help the companies to identify risks and opportunities more comprehensively and enhance long-term resilience.

In the practice of ESG information disclosure, the Hong Kong stock market and the A-share market present two different framework ideas.

The Hong Kong Stock Exchange's ESG Code specifies general disclosure content and corresponding key performance indicators (KPIs) for each ESG topic (except climate change, which is subject to Code D). This establishes a detailed, topic-specific disclosure framework. The advantage of this approach lies in its clarity, allowing companies to follow the guidelines and respond to regulatory requirements item by item. For example, within the " Product Responsibility " social topic, specific KPIs are required to be reported, such as B6.1: The percentage of products sold or shipped subject to recall for safety and health reasons . This demonstrates a high level of granularity and actionability.

In contrast, the guidelines issued by the Shanghai, Shenzhen, and Beijing Stock Exchanges, beyond the four already-issued guidelines for specific topics, do not establish independent disclosure structures and indicators for each topic. Instead, they draw on the framework of Task Force on Climate-related Financial Disclosures (TCFD), uniformly requiring companies to voluntarily disclose all ESG issues across four dimensions: 1. Governance; 2. Strategy; 3. Impact, Risk, and Opportunity Management; and 4. Metrics and Targets. This approach avoids requiring detailed granularity for each topic, instead emphasizing that companies should establish a systematic management logic and integrate ESG factors into corporate governance and strategic decision-making, demonstrating a more structured and integrated approach.

For listed companies, the frameworks of the Shanghai, Shenzhen, Beijing, and Hong Kong stock exchanges offer valuable insights into optimizing their ESG disclosures and further enhancing their ESG ratings. Listed companies should proactively explore integrating disclosure content with a "double materiality" and TCFD-four-pillar mindset to elevate the strategic focus of ESG management. They should also quickly establish internal systems encompassing governance, strategy, risks, and metrics, avoiding superficial disclosures and striving to reflect substantive content within their own frameworks.

The Shanghai, Shenzhen, and Beijing Stock Exchanges have released detailed disclosure guidelines (draft for public comment) addressing four key areas: climate change response, pollutant emissions, energy utilization, and water resource utilization. These guidelines demonstrate a strong commitment to systematic management of environmental issues and a stronger emphasis on material data and verifiable actions. Hong Kong stocks are already largely aligned with international standards in climate change disclosures, particularly through the introduction of reporting requirements aligned with IFRS S2, which strengthen coverage of climate risks, transition plans, and scenario analysis.

On climate change, the core frameworks for A-shares and Hong Kong-listed stocks are largely consistent and aligned with IFRS S2 , though specific indicators differ. Regarding pollutant emissions, energy use, and water resource utilization, the Shanghai, Shenzhen, and Beijing Stock Exchanges have introduced a more comprehensive disclosure framework through a draft for public comment, aiming to encourage companies to strengthen internal environmental management and achieve green transition.

Listed companies in both A-share and H-share must prioritize the alignment of climate-related disclosures with IFRS S2 compliance, strengthening communication on strategic resilience and risk management. A-share listed companies should also prioritize the quantitative management of pollutants, energy, and water resources, target setting, and disclosure of implementation paths, and establish systematic data collection mechanisms. While Hong Kong-listed companies face less pressure to disclose non-climate environmental issues, they can still voluntarily enhance relevant disclosures, referencing A-share or international standards, to enhance their ESG ratings and international credibility.