Consultation on Proposals to Introduce a Paperless Listing & Subscription Regime, Online Display of Documents and Reduction of the Types of Documents on Display

The Stock Exchange of Hong Kong Limited (the “Exchange”) in July issued a consultation paper on its proposals to introduce a paperless listing & subscription regime, online display of documents and reduction of the types of documents on display (“Consultation Paper”).

Currently, the Exchange’s Listing Rules (“Rules”) require the issue of listing documents in physical printed form to be made available at designated places in Hong Kong during the public offer period, subject to a few exceptions. The Rules also require the physical display of certain documents for inspection, for example, material contracts, directors’ service contract, experts’ consents and statements of adjustments. 

The Exchange considered that the printed form listing documents have been rendered out-of-date with the advancement of technology. They are also environmental unfriendly and time and cost ineffective. Therefore, it proposed to amend the Listing Rules to:

(a) require (i) all listing documents in a new listing to be published solely in an electronic format; and (ii) the new listing subscriptions, where applicable, to be made through online electronic channels only (with a few exceptions);

(b) replace the requirement for certain documents to be physically displayed with a requirement for those documents to be published on the Exchange’s website and on the issuer’s website; and

(c) with respect to notifiable transactions and connected transactions, reduce the types of documents that are mandatory for an issuer to display. 

The Consultation Paper was considered by Council with the assistance of the Company Law Committee. A submission was prepared in response. In a summary, the Law Society welcomes the Exchange’s proposal in general. It also provided comments on some of the proposals. A copy of the above submission can be found on the Law Society’s website: