HKEX opens up

Listing reforms broaden access and make Hong Kong a more competitive market for global issuers

The consultation conclusions by the Stock Exchange of Hong Kong (SEHK) (a wholly owned subsidiary of Hong Kong Exchanges and Clearing [HKEX]) on 24 July 2026 on the competitiveness review of the listing framework mark an important new phase in Hong Kong’s competition for global listings. The reforms are not merely technical amendments to the Hong Kong Listing Rules. Read together, they show a deliberate attempt to make Hong Kong a more flexible and issuer-friendly market for innovative companies, overseas issuers and founder-led businesses while preserving the investor protection standards central to Hong Kong’s regulatory identity.

The timing is no coincidence. Hong Kong has enjoyed a strong recovery in IPO activity during 2025 and 2026, but continues to compete against New York, London, Singapore and major Chinese mainland exchanges for innovative companies and international issuers. The reforms represent a conscious effort to ensure that Hong Kong’s listing framework evolves alongside market developments and remains competitive for primary and secondary listings, particularly when issuers have a broad range of capital-raising venues to choose from.

The reforms also arrive as major listing venues move quickly. The consultation paper referred to regulatory developments in the US, the UK and Singapore, each seeking to simplify listing processes, attract growth companies and improve market competitiveness. The HKEX’s response is one of continuous evolution rather than deregulation: broadening access, reducing friction, and aligning with international practice without abandoning market quality.

Non-public filing extended to all

One of the most important changes is the expansion of non-public filing to all new applicants. Previously, this option was available only to eligible secondary listing applicants, biotech companies under chapter 18A, and specialist technology companies under chapter 18C, with other applicants requiring specific waivers or relief. Under the revised framework, any new applicant may choose not to publish its application proof (AP) when submitting its listing application, with public disclosure generally deferred until the post-hearing information pack (PHIP) stage.

The significance of this reform is best understood in its historical context. Publication of an AP was a cornerstone of the 2013 overhaul of Hong Kong’s IPO sponsor regulatory regime, which sought to enhance sponsor accountability, improve disclosure quality and increase transparency by requiring a substantially complete draft prospectus to be submitted and generally published at filing. By allowing all new applicants to make confidential filings, Hong Kong is effectively rolling back one of the most visible transparency measures introduced in 2013 while preserving public disclosure at the PHIP stage.

This represents a remarkable modernisation of Hong Kong’s IPO process. It recognises that concerns over commercially sensitive information, proprietary business data and transaction confidentiality are not unique to 18A biotech and 18C specialist technology applicants. For issuers, non-public filing should reduce premature market exposure, reputational uncertainty and disruption if timetables are delayed or market conditions change. It also brings Hong Kong closer to leading international capital markets, particularly the US, where confidential submission regimes have long been available to IPO applicants.

The HKEX has paired this flexibility with a strengthened application return mechanism. Where an application is returned because it is not substantially complete, the exchange will publish the applicant’s and sponsor’s details, the names and roles of the professional parties involved, and the reasons for return. This is intended to preserve accountability and filing quality while avoiding unnecessary costs of mandatory early publication for applications still under regulatory review.

WVR eligibility broadened, thresholds lowered

The weighted voting rights (WVR) reforms are another central part of the competitiveness package. The HKEX has reduced the financial eligibility thresholds for WVR applicants: test A now requires an expected market capitalisation of at least HKD20 billion (USD2.55 billion), reduced from HKD40 billion, while test B now requires market capitalisation of at least HKD6 billion and revenue of at least HKD600 million, reduced from HKD10 billion and HKD1 billion, respectively. These reductions bring Hong Kong closer to Chinese mainland requirements while keeping the WVR entry thresholds above the ordinary main board thresholds.

The HKEX has also refined the “innovative company” requirement. In addition to route A for technology-driven innovation, new route B recognises companies whose success is attributable to a new business model, even where the relevant technology is not novel or central to the business. Route B applicants will generally need to demonstrate strong growth, including at least 30% revenue CAGR (compound annual growth rate) over the track record period, and a prominent industry position.

This is a meaningful shift. The HKEX is acknowledging that innovation is no longer confined to proprietary technology. Valuable businesses today derive their competitive advantage from platform economics, ecosystem design, data-led operations or other operating models. The revised framework gives advisers and applicants a clearer route to explain business model innovation within a WVR application.

For very large applicants, the HKEX will also permit a WVR ratio of up to 20:1 where the company has a market capitalisation of at least HKD40 billion at listing. The exchange has further clarified when it may accept a lower minimum economic interest for WVR beneficiaries, subject to a floor of at least 5% of total issued share capital and a value of at least HKD4 billion. These changes are designed to accommodate founder-led companies whose founders have been diluted through private financing rounds while retaining investor protection safeguards.

HKEX eases overseas listing pathways

The reforms should also be read as part of Hong Kong’s continuing effort to attract overseas-listed issuers, particularly Chinese mainland issuers already listed in the US. For secondary listings, the HKEX has lowered the thresholds for overseas WVR issuers so that they match the revised primary WVR thresholds. For non-WVR overseas issuers, the market capitalisation threshold under criteria B has been reduced from HKD10 billion to HKD6 billion.

These changes respond to a practical competitiveness concern: regulatory thresholds should not deter credible overseas issuers from adding Hong Kong as a listing venue.

The HKEX has also expanded the circumstances in which issuers may use US Generally Accepted Accounting Principles and removed the requirement to convert to Hong Kong Financial Reporting Standards or International Financial Reporting Standards following a US delisting.

These changes are particularly relevant to US-listed Chinese and Asian issuers considering Hong Kong. By reducing conversion costs and compliance complexity, the HKEX has removed a potential friction point that may previously have discouraged companies from pursuing a Hong Kong listing, dual primary listing or homecoming listing.

The HKEX has also streamlined its guidance on conversion from secondary listing to dual primary or primary listing. Although the substantive requirements have not changed, the updated guidance is intended to make the pathway clearer. This may become increasingly relevant as issuers seek Stock Connect eligibility, deeper regional liquidity and a stronger Hong Kong investor base.

Flexibility for biotech, tech listings

The HKEX has also made the specialist listing regimes more flexible. Previously, a biotech company or specialist technology company that could satisfy one of the financial eligibility tests under rule 8.05 was generally required to list under the ordinary main board route, even if its business profile remained aligned with chapter 18A or chapter 18C.

The revised framework removes that rigidity. Commercialised biotech companies and specialist technology companies may now choose to list under the applicable specialist chapter even where they are financially eligible under the ordinary route. The HKEX has also disapplied or modified requirements designed for pre-revenue or earlier-stage companies, such as certain third-party investment and warning statement requirements.

This change is practical and commercially sensible. A company does not cease to be a biotech or specialist technology company simply because it has achieved revenue, cash flow or profit. The reforms allow issuers to select the route that best reflects their business, preserves access to the technology enterprise channel where applicable, and avoids penalising companies for successful commercialisation.

HKEX reforms widen access cautiously

The July 2026 reforms represent a clear regulatory direction. The HKEX is seeking to compete more effectively for global listings but has not chosen deregulation as the answer. Instead, the reforms widen access to Hong Kong’s market through calibrated changes: broader non-public filing, lower WVR and secondary listing thresholds, clearer recognition of business model innovation, greater issuer choice for specialist companies, and practical guidance for overseas issuers.

While the reforms’ success will be measured by the quality and diversity of issuers choosing Hong Kong, the direction is clear. The exchange has signalled a willingness to modernise its listing framework, reduce friction and compete actively for international listings while maintaining investor protection standards that underpin confidence in Hong Kong’s capital markets.