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ARTICLE · 26 SEPTEMBER 2025

Enhancing Accountability

Revised Corporate Governance Code On Risk Management and Internal Control Systems: Four Essential Questions For Directors To Ask & Answer.

Hong KongCorporate/Commercial Law
Alva Lee
Alva Lee
David Lonergan
David Lonergan
Longhui Loo
Longhui Loo
Candy Wan
Candy Wan

Through a comparative analysis of disclosure requirements in other prominent markets, HKEX disclosure requirements in risk management and internal control (RMIC) are among the most comprehensive globally. This sets a benchmark for corporate governance over RMIC with the implementation of its revised Corporate Governance Code (CG Code), effective for financial years beginning on or after 1 July 2025. Jointly published by KPMG and The Hong Kong Chartered Governance Institute (HKCGI), this report explores how the revised CG Code places greater emphasis on board accountability, transparency, and structured oversight of RMIC systems.

Based on a survey of over 600 listed companies, the report finds that more than 90% of respondents expect the revised CG Code to impact board practices in reviewing RMIC systems, with a quarter anticipating a significant effect. The new Mandatory Disclosure Requirements (MDRs) call for more comprehensive and transparent disclosures, including

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