Green Finance

Green Finance

SFC: Consultation Conclusion on the Management and Disclosure of Climate-related Risks by Fund Managers



On 20 August 2021, Hong Kong Securities and Futures Commission (“SFC”) issued the Consultation Conclusions on the Management and Disclosure of Climate-related Risks by Fund Managers. According to the consultation conclusion, fund managers managing collective investment schemes (“CISs”) are proposed to take climate-related risks into consideration in their investment, properly manage the risks, and promote clear, comparable and high-quality disclosures to help investors make more informed decisions. The Fund Manager Code of Conduct is proposed to be amended to reflect the new requirement. 


Two-tier approach

A two-tier approach is to be implemented by SFC: (i) set of baseline requirements for all fund managers and (ii)  a set of enhanced standards only for large fund managers (fund managers with assets under management that equal or exceed HKD 8 billion).  
Large Fund Managers are required to identify the portfolio carbon footprints of the Scope 1 and Scope 2 GHG emissions of funds’ underlying investments and to disclose them in terms of enterprise value.
Implementation timeline
The regulatory requirements for climate-related risks will become effective after the transition periods:
Large Fund Managers
  • Baseline requirements:
  • Enhanced standards:

20 August 2022 (12-month transition period)

20 November 2022 (15- month transition period)

All Other Managers
  • Baseline requirements:
20 November 2022 (15- month transition period)


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