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TCFD Compliance Guide

TCFD Reporting Guide for Hong Kong Companies: 2026 Compliance

The TCFD framework is now the backbone of climate disclosure in Hong Kong. This guide walks you through the 4 TCFD pillars, the HKEX mandatory timeline, and a practical step-by-step process for producing a compliant TCFD report.

By Peak M&S Education Centre · July 2026 · 8 min read

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The Task Force on Climate-related Financial Disclosures (TCFD) framework has become the global standard for climate risk reporting — and it's now mandatory in Hong Kong. If your company is listed on the HKEX or plans to list, understanding TCFD reporting is no longer optional. This guide explains everything you need to know.

What Is TCFD and Why Does It Matter in Hong Kong?

The TCFD was established by the Financial Stability Board (FSB) in 2015 to develop a consistent framework for companies to disclose climate-related financial information. The framework helps investors, lenders, and insurers understand the financial implications of climate change on an organisation.

In Hong Kong, the HKEX has adopted TCFD-aligned climate disclosure requirements as part of its ESG reporting framework. This means listed companies must report against the TCFD recommendations, and the timeline is already underway. The HKEX requirements are also aligned with international ESG reporting standards, creating a comprehensive climate disclosure regime.

The TCFD Framework: 4 Pillars Explained

The TCFD framework is built on four foundational pillars. Each pillar addresses a specific dimension of how climate change affects a business:

1. Governance

This pillar examines how climate-related risks and opportunities are overseen by the board and management. You need to disclose:

Investors want to see that climate risk is taken seriously at the highest level — not just delegated to a sustainability team.

2. Strategy

This pillar focuses on the actual and potential impacts of climate-related risks and opportunities on your business, strategy, and financial planning. Key disclosures include:

Scenario analysis is a critical component — you must demonstrate that your business strategy is resilient under various climate futures.

3. Risk Management

This pillar describes how climate risks are identified, assessed, and managed within your organisation's overall risk management framework. You need to explain:

4. Metrics and Targets

This final pillar requires you to disclose the metrics and targets you use to assess and manage climate-related risks. Essential disclosures include:

For many companies, Scope 3 emissions calculation is the most challenging part — see our Scope 3 emissions guide for practical help.

HKEX Mandatory TCFD Timeline

The HKEX has implemented a phased approach to mandatory climate disclosures. Here's the timeline you need to know:

FY2025 (Financial years commencing on/after 1 January 2025): Main Board issuers must make TCFD-aligned climate disclosures on a "comply or explain" basis. Large issuers (with market capitalisation over HK$10 billion) face the earliest requirements.

FY2026 (Financial years commencing on/after 1 January 2026): All Main Board issuers must comply with mandatory climate disclosures aligned with international ESG standards, incorporating the full TCFD framework. This is the critical compliance year for most listed companies.

FY2027+ (Financial years commencing on/after 1 January 2027): Full mandatory compliance including Scope 3 emissions reporting for all Main Board issuers. Assurance requirements may also be introduced.

For a deeper comparison between TCFD and international ESG standards, read our TCFD vs international ESG standards comparison guide.

Step-by-Step: How to Produce a TCFD Report

Producing a compliant TCFD report requires careful planning and cross-functional coordination. Here's a practical 6-step process:

Step 1: Establish Governance and Project Team

Assign clear ownership of the TCFD reporting process. The board should have ultimate oversight, while a cross-functional team (finance, risk, operations, sustainability) handles day-to-day execution. Designate a TCFD project lead.

Step 2: Conduct Climate Risk Assessment

Identify physical risks (extreme weather, sea-level rise, temperature changes) and transition risks (policy changes, technology shifts, market changes, reputational impacts) relevant to your business. Use a structured risk assessment methodology.

Step 3: Perform Scenario Analysis

Test your business strategy against multiple climate scenarios. The most common scenarios used are 1.5°C/2°C (aggressive decarbonisation) and 4°C (business-as-usual). This analysis helps identify strategic vulnerabilities and build resilience.

Step 4: Calculate Carbon Emissions (Scope 1-3)

Collect data and calculate your Scope 1, 2, and 3 emissions using the GHG Protocol methodology. This is often the most resource-intensive step — start early and ensure data quality.

Step 5: Set Targets and Define Metrics

Establish science-based or aligned reduction targets for emissions and other climate metrics. Define the KPIs you'll track and disclose. Ensure targets are aligned with Hong Kong's 2050 carbon neutrality goal.

Step 6: Draft, Review, and Disclose

Prepare your TCFD report covering all four pillars. Review with the board and senior management. Consider obtaining third-party assurance to enhance credibility. Publish in your ESG/sustainability report or annual report.

Common TCFD Reporting Challenges

Hong Kong companies face several challenges when implementing TCFD reporting:

How Our Course Can Help

Our ESG Sustainable Solutions 4.0 course covers the full TCFD framework in depth, including practical workshops on carbon accounting (Scope 1-3) and scenario analysis. Designed for professionals who need to understand and implement TCFD reporting, the course provides:

Start Your TCFD Compliance Journey

TCFD reporting is now a regulatory requirement, not a nice-to-have. Hong Kong companies that start early will be better positioned for compliance and will build investor confidence. The key is to begin now — assess where you stand, identify gaps, and build the capability to report comprehensively.

Contact us or WhatsApp +852 4423 7445 to learn how our TCFD-focused ESG training can help your company achieve compliance. Next intake: 25-26 July 2026.

Master TCFD Reporting for Hong Kong Compliance

Learn the full TCFD framework, carbon accounting, and HKEX compliance requirements. ESG Sustainable Solutions 4.0 — next intake 25-26 July 2026. Government funding available.

Enrol Now

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