The revised Corporate Governance Code emphasises the need for diligent oversight of risk management internal control (RMIC) systems

Structured review processes ensure consistency, accountability, and transparency in RMIC, ultimately strengthening stakeholder confidence

Structured review processes ensure consistency, accountability, and transparency in...

25 September 2025, Hong Kong SAR, China (“Hong Kong”) – Hong Kong is reinforcing its position as a leading international financial centre, setting a benchmark for corporate governance over RMIC with the implementation of the revised Corporate Governance Code (CG Code), according to a new report jointly published by KPMG and The Hong Kong Chartered Governance Institute (HKCGI). The report, Enhancing Accountability: Revised Corporate Governance Code on Risk Management and Internal Control Systems – Four Essential Questions for Directors To Ask & Answer, highlights how Hong Kong’s enhanced disclosure requirements are placing a greater emphasis for a structured review process of RMIC among listed companies supported by governance professionals as trusted advisers.

The revised CG Code, effective for financial years starting on or after 1 July 2025, introduces more comprehensive Mandatory Disclosure Requirements (MDRs) for boards to confirm and evidence the appropriateness and effectiveness of their RMIC systems. These requirements include detailed disclosures on the scope and findings of annual reviews, including any significant control failings or weaknesses, as well as the responsibilities of internal and external parties in the review process, which governance professionals, apart from an advisory role, serve to coordinate. 

Alva Lee

Alva Lee, Partner, Head of Governance, Risk and Compliance Services / ESG Governance Services Lead, Hong Kong SAR, KPMG China, says:

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Hong Kong’s revised CG Code marks a significant step forward in strengthening board’s accountability and transparency on RMIC systems. The new requirements not only raise the bar for RMIC’s disclosures, but also prompt boards to establish a clear review framework to demonstrate their commitment to robust governance. By adopting structured review processes and leveraging assurance mapping, companies can build greater stakeholder confidence and position themselves for long-term success in an increasingly complex risk environment through strong corporate governance over RMIC.

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David Simmonds FCG HKFCG, President, HKCGI; Chief Strategy, Sustainability and Governance Officer, CLP Holdings Limited, says:

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Risk management and internal control are central to sustainable business. HKCGI members, as governance professionals, provide the expertise and coordination needed to turn the CG Code’s expectations into practical, actionable processes. By linking directors, management, and external parties, they help ensure that reviews are rigorous, transparent, and credible, reinforcing accountability and stakeholder confidence.

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A survey conducted in April 2025 by KPMG and HKCGI, with over 600 responses from listed companies, found that more than 90% of respondents expect the revised CG Code to impact the board’s effort in reviewing RMIC systems, with around a quarter anticipating a significant impact.

The report provides practical guidance for boards and management on implementing effective RMIC reviews, including the establishment of control repositories, regular testing of material controls, and confirmation from management to boards. It also offers a comparative analysis of disclosure requirements in other major markets, demonstrating Hong Kong's commitment to advancing good corporate governance practices over RMIC.

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In 2025, KPMG marks “80 Years of Trust” in Hong Kong. Established in 1945, we were the first international accounting organisation to set up operations in the city. Over the past eight decades, we’ve woven ourselves into the fabric of Hong Kong, working closely with the government, regulators, and the business community to help establish Hong Kong as one of the world’s leading business and financial centres. This close collaboration has enabled us to build lasting trust with our clients and the local community – a core value celebrated in our anniversary theme: “80 Years of Trust”.

Celebrating 80 years in Hong Kong

About The Hong Kong Chartered Governance Institute

(Incorporated in Hong Kong with limited liability by guarantee)

The Hong Kong Chartered Governance Institute (HKCGI) is the sole accrediting body in Hong Kong and the Chinese mainland for the globally recognised Chartered Secretary and Chartered Governance Professional qualifications. Formerly known as The Hong Kong Institute of Chartered Secretaries (HKICS), HKCGI is the Hong Kong/China Division of The Chartered Governance Institute (CGI).

With a legacy of over 75 years, HKCGI has established itself as a trusted and reputable professional body in the region. Its influence extends to CGI’s global network of around 40,000 members and students, making it one of its fastest-growing divisions. HKCGI’s community comprises about 10,000 members, graduates, and students, with significant representation in listed companies and diverse governance roles across various industries.

Guided by the belief that governance leads to better decision-making and a better world, HKCGI is committed to advancing governance in commerce, industry, and public affairs. It achieves this through education, thought leadership, advocacy, and active engagement with its members and the broader community. As a recognised thought leader, HKCGI promotes the highest standards of governance while advocating for an inclusive approach that considers the interests of all stakeholders, and ensures that every voice is heard and valued.

Better Governance. Better Future.

For more information, please visit www.hkcgi.org.hk.