With the development of the green finance market, the Hong Kong Monetary Authority (HKMA) has entered the implementation and supervisory phase of its Green and Sustainable Banking framework, marking a structural transition from policy design to enforceable execution. In this phase (Phase 3), authorised institutions are expected to embed climate risk considerations into governance, strategy, risk management and disclosure, in alignment with the Supervisory Policy Manual (GS‑1) and TCFD principles.
A defining shift in Phase 3 is the elevation of data from a reporting element to a regulatory expectation. Institutions are required not only to disclose climate-related information on an annual basis, but also to demonstrate the robustness, consistency and decision-usefulness of underlying data, supported by enhanced use of scenario analysis and stress testing. At the same time, supervisory scrutiny by HKMA is intensifying, reflecting a move towards outcome-based assessment of implementation quality.
This evolution is redefining market discipline. Climate considerations are increasingly embedded in credit allocation and risk pricing, effectively extending regulatory pressure beyond banks to corporates. For listed companies, access to financing is becoming closely linked to the credibility of ESG disclosures and the availability of verifiable carbon data.
Driven by CMA’s mission to promote industry development, CMA Testing actively provides support to corporates through integrated sustainability solutions, including carbon data management, regulatory-aligned reporting, and independent assurance, enabling clients to meet rising expectations from financial institutions and regulators while strengthening transparency and market confidence.
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