The Securities and Futures Commission (SFC), Hong Kong has published circular dated June 29, 2021 on enhanced disclosures for authorised funds which shall include environmental, social and governance (ESG) or climate change or green or sustainability factors as a key investment focus (ESG funds). The new guidance will come into effect on January 01, 2022 and supersedes the previous version issued in 2019.


Salient features of the new guidance are:

  • Disclosure requirements: The new guidance requires an ESG fund to disclose its key features in its offering documents, such as its ESG focus and the portion of ESG-focused investments, the list of ESG criteria and the strategies adopted.
  • Periodic assessment and reporting: The guidance poses a new requirement for ESG funds to conduct an assessment at least annually, demonstrating how the fund has attained its ESG focus during the assessment period and a comparison between the current and at least the previous assessment period (if any).
  • Climate funds: The guidance provides additional guidance for ESG funds with a climate-related focus (Climate Funds), such as illustrative examples of climate-related focuses and indicators, and guidance on disclosures relating to a climate benchmark if the fund has designated one.
  • Application to UCITS funds: UCITS funds will be ESG funds in Hong Kong if they incorporate ESG factors as their key investment focus (UCITS ESG funds). UCITS ESG funds which meet the disclosure and reporting requirements will be deemed to have generally complied with the above requirements, subject to the SFC’s discretion.
  • Ongoing monitoring: Similar to the 2019 Circular, managers are required to regularly monitor and evaluate the underlying investments to ensure the ESG funds continue to meet the stated ESG focus and requirements set out in the new guidance.
  • Implementation of the Revised Circular: Managers of funds seeking SFC authorisation for ESG funds after the Effective Date will need to provide a confirmation of compliance in the form annexed to the guidance.

SFC-authorised funds which qualify as ESG funds will continue to be listed on the SFC’s dedicated ESG funds webpage.


*Tanvi Singh, Editorial Assistant has put this story together.

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