A Refreshed Materiality Assessment Approach
In 2025, we undertook a comprehensive refresh of our materiality assessment to fully adopt a double materiality assessment approach, strengthening alignment with evolving global sustainability disclosure standards to steer our sustainability reporting and strategic planning. This approach ensuring that sustainability material topics are identified and assessed through two complementary lenses:
- Financial materiality – sustainability-related risks and opportunities that could reasonably be expected to affect MTR’s revenues, asset values or liabilities or cost of capital; and
- Stakeholder materiality – MTR’s actual and potential positive and negative impacts on stakeholders including customers, employees, communities and the environment.
This process aligns with both local and international sustainability reporting standards and incorporates considerations from our Enterprise Risk Management framework. The assessment was conducted at the consolidated business group level, covering both our Hong Kong and overseas operations. The results from the foundation of our Sustainability Report and will assist in shaping our strategy, risk management and disclosures.
Assessment Process
The assessment process comprises four phases:
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Phase 1 - Context Setting and Research:
MTR’s business model, value chain, business strategies and risks were reviewed, alongside an assessment of global megatrends, to identify a set of MTR-related key megatrends shaping the transport and property industries. The assessment was benchmarked against HKEX's ESG Reporting Code, IFRS S1 and GRI reporting requirements.
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Phase 2 - Stakeholder Engagement and Insight Gathering:
Targeted interviews were conducted with MTR’s senior management and external stakeholders to assess how identified megatrends translate into sustainability-related strengths, weaknesses, opportunities and threats (“SWOT”) across MTR’s operations and value chain.
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Phase 3 - Identification and Double Materiality Assessment:
Insights from research and stakeholder engagement were consolidated into a comprehensive list of organisation-specific sustainability-related impacts, risks and opportunities (“IROs”). Each IRO was assessed for both financial and stakeholder materiality, drawing on MTR’s Enterprise Risk Management (“ERM”) framework to evaluate impact severity and likelihood. With reference to the ERM materiality threshold, material IROs were identified and subsequently consolidated into coherent Material Topics and Sub-topics.
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Phase 4 - Review, Endorsement and Strategic Alignment:
The resulting Material Topics were endorsed by MTR’s management and benchmarked against industry peers to ensure completeness, strategic relevance and alignment with our long-term business strategy.
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Key Megatrends
During Phase 1, nine global megatrends were identified that relate to the public transport and property sectors and influence MTR’s long-term sustainability profile. These megatrends informed the identification and prioritisation of MTR-specific sustainability IROs, which subsequently formed MTR’s Material topics.
Low-carbon transition – Decarbonisation accelerates with electrification and reporting.
Global emissions are rising, pushing stricter regulations and carbon pricing. Rail electrification, hydrogen, and battery technologies are key solutions. Climate reporting standards are expanding, driving transparency and compliance.- Pace of transition
- Electrification
- Climate reporting standards
- Low-carbon technologies
Physical effects of climate change – More frequent and severe extreme weather events are disrupting infrastructure and operations across industry.
Heatwaves, floods, and droughts are increasing, damaging transport networks and properties, and increasing costs to repair, maintain and upgrade. Companies must invest in climate adaptation, but most lack resilience strategies, creating financial and operational risks.- Extreme weather events
- Climate adaptation
Nature and biodiversity – Biodiversity loss threatens ecosystems and economies.
Climate change accelerates biodiversity decline, depleting natural resources, disrupting supply chains, and impacting businesses. New disclosure standards and nature-based solutions are emerging, while circular design helps reduce waste and environmental impact.- Nature-climate nexus
- Nature-related financial disclosure
- Circularity
Changing societal expectations – Consumers demand sustainability, digital experiences, and safety.
Businesses are shifting towards sustainability, stakeholder capitalism, and customer-centric models. Consumers expect seamless digital experiences, with ESG and safety considerations shaping corporate priorities. Despite growing climate-consciousness, debates around diversity, equity and inclusion continue to evolve.- Sentiment towards ESG
- Stakeholder capitalism
- Customer and employee experience and safety
Changing demographics – Ageing populations and urban growth reshape workforce needs.
Global ageing trends are increasing demand for accessible infrastructure, while urban growth is driving cross-border commuting to address labour shortages. Enhanced connectivity, such as high-speed rail links, is crucial for economic integration and workforce mobility.- Ageing population
- Urban growth and mobility
Geopolitics and supply chain resilience – Global shifts, conflicts, and protectionism reshape trade flows.
Globalisation is evolving as trade barriers rise and nations prioritise self-reliance. Geopolitical conflicts and energy market disruptions are driving companies to regionalise supply chains, diversify sourcing, and secure resilient trade networks.- Globalisation in flux
- Protectionism
- Global conflict
- Supply chain impacts
Future of transport – Sustainable, smart mobility is transforming urban transit.
Cities are shifting towards multimodal, low-emission transport systems, with artificial intelligence (“AI”) and Internet of Things (“IoT”) enhancing efficiency and safety. However, infrastructure faces cybersecurity risks, and equitable access remains a challenge amid rapid urban development.- Modal shifts
- New technology
- Socioeconomic Impacts
Future of work – AI, labour shortages, and values-driven careers reshape jobs.
Labour shortages and shifting priorities are transforming the workforce, with younger generations seeking work-life balance over corporate ambitions. AI is automating tasks while creating new roles, and purpose-led work is becoming a key factor in talent attraction and retention.- Labour shortages
- Impacts of AI and technology
- Purpose-led work
Data use and cybersecurity – Balancing innovation with stronger data security is crucial.
Cyberattacks are growing in sophistication, targeting critical infrastructure and businesses. Stricter data regulations are reshaping compliance requirements, challenging companies to innovate while ensuring security and privacy in a digital world.- Cybercrime
- Data privacy
Our Material Topics
Derived from the nine identified megatrends and insights from stakeholder engagement, a set of detailed, business-specific sustainability-related IROs was evaluated for materiality using MTR’s ERM framework as a guide. IROs deemed material were then consolidated into Material Topics designed to support clear communication with stakeholders and steer MTR’s long-term strategic direction. As a result, six Material Topics were identified, which align closely with our three Environmental and Social Objectives and 10 focus areas. Detailed descriptions of these Material Topics and their Corresponding Sub-topics are outlined below.
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Identification of MTR’s Material Topics
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Material Topics
