Hong Kong SAR ChinaAccounting and Financial Reporting Council
AFRC, SFC and HKEX target going-concern audit disclaimers
The 8 October 2026 joint statement sets expectations for management, audit committees and auditors and warns the Listing Rules may be amended to suspend such issuers.
By Taxxa AI OyPublished 8 October 2026
On 8 October 2026 the Accounting and Financial Reporting Council (AFRC), the Securities and Futures Commission (SFC) and The Stock Exchange of Hong Kong Limited (the Exchange) issued a joint statementAfrc addressing the increasing number of listed issuers publishing financial statements carrying a disclaimer of opinion solely relating to going concern. A disclaimer of opinion means the auditor has expressed no opinion on the financial statements, raising questions about their reliability. The statement treats reversing the trend as a shared responsibility of management, audit committees and auditors
Afrc, with the common objective of improving the quality and reliability of financial reporting and maintaining investor confidence.
Management is expected to prepare robust going concern assessments supported by reasonable assumptions, reliable data and feasible action plans.Afrc Audit committees are expected to review those assessments critically and to oversee actively whether the action plans are implemented.
Afrc Auditors are expected to evaluate management's assessments critically, to communicate deficiencies they identify and to explain clearly the basis for any disclaimer of opinion.
Afrc The AFRC's Head of Policy, Registration and Oversight added that auditors must deliver a high-quality audit that supports the opinion issued and must communicate in the auditor's report any matters beyond going concern that could lead to a modified opinion.
The warning matters because a going-concern-only disclaimer currently sits in an exception: under the Listing Rules, trading is normally suspended when an auditor issues or flags a disclaimer or adverse opinion, except where it relates to going concern onlyAfrc. The three regulators now say the Exchange will consider amending the Listing Rules as necessary, including requiring suspension of issuers carrying a going-concern-only disclaimer, if no significant improvement is observed.
Afrc The AFRC has previously found that reports behind such disclaimers often contained too little disclosure or explanation to support the basis for the opinion, and it regards disclaimers issued without that support as a marker of poor reporting rather than a safe harbour.
The regulators will continue to monitor the situation and will take regulatory, disciplinary or enforcement action where misconduct or non-compliance is identified. Issuers whose audits are heading towards a going-concern disclaimer should therefore treat the underlying position, not the form of the opinion, as the problem to fix: credible remedial action, documented assumptions and transparent disclosure to the market. Legal basis: the AFRC, SFC and Exchange Joint Statement on Financial Statements with Disclaimer of Opinion solely relating to Going Concern of 8 October 2026, Hong Kong Standard on Auditing (HKSA) 705 (Revised) Modifications to the Opinion in the Independent Auditor's Report, and Main Board Listing Rules Rule 13.50A and GEM Listing Rules Rule 17.49B.
Map each listed-issuer audit at risk of a going-concern disclaimer against the joint statement expectations: press management for documented assumptions and feasible action plans, challenge the assessment at audit-committee level, and explain the basis for any disclaimer in the auditor report.