The listed issuer financing exemption “has succeeded beyond our most optimistic expectations”, Stan Magidson, Chair of the Canadian Securities Administrators, said in July as Canadian regulators moved to make its higher limits permanent. Canada’s reform is one of many. The measures adopted or proposed in the third quarter fall at four stages of the capital raising process. Most remove or shorten procedural steps. At the book-building stage, Saudi Arabia and South Korea add mechanisms and requirements intended to make the demand behind an IPO, and the price it supports, more reliable. Overall, observed reforms span four stages of the capital raising process:

Policy reforms at the pre-marketing stage focus on three areas: (1) easing restrictions on analyst research during IPOs, (2) widening the scope for publicity before the prospectus is lodged, and (3) formalising early testing of institutional demand before the price range is set.

The UK and Australia are easing restrictions on research by analysts at banks working on an IPO. The UK has scrapped its seven-day waiting period between publication of the approved prospectus or registration document and the release of such research, together with the requirement to give analysts outside the syndicate the same access to the issuer. Australia proposes replacing 42 pages of sell-side research guidance with eight pages of principles, under which analysts could contribute to deal selection, due diligence and underwriting decisions, while controls such as wall-crossing for analysts involved in pitches and prospectus-based valuations in investor education reports would remain. Both changes respond to industry feedback that the existing rules were too prescriptive or costly.

The two regimes share an origin and are now converging from opposite directions. Both date from 2017–18 and were introduced to address perceived bias in research produced by banks on a deal. The UK’s response was to mandate access for independent analysts and impose a waiting period on connected research; Australia’s was to restrict, in detail, when analysts could interact with the issuer and with their own bank’s corporate advisers. The UK is removing its mandated mechanisms after respondents said they had produced little independent research while adding execution risk. Australia is replacing its restrictions with principles after feedback that they were too prescriptive. After the changes, the two land on similar ground: research by analysts at banks on the deal is permitted, contact between analysts and the issuer before a bank is appointed remains restricted in both, and the approved prospectus remains the reference document, as the document after which connected research may be published in the UK and the basis for any valuation in Australian investor education reports.

Australia also proposes allowing issuers to advertise and publicise an IPO at any stage before lodging a prospectus. The current exception permits only basic factual statements, and ASIC found that most offerors avoid pre-lodgement publicity because of the regulatory risk. According to ASIC, the change would allow issuers to communicate in a controlled and accountable way, help them gauge market interest and reduce the risk of misinformation. ASIC also sees it as reducing an unnecessary difference between the rules for raising capital in public and private markets. Advertisements would have to identify the issuer and any seller, state when and where the prospectus will be available and direct investors to consider it. That would bring the regime closer to the rules that apply after lodgement and broadly into line with comparable overseas jurisdictions.

Under the amended Capital Markets Act, due to take effect in November, South Korean lead managers will be able to share information intended for the registration statement with qualified institutional investors once due diligence is complete. They can then ask about desired prices and volumes before setting the price range. The FSC expects this to make offer pricing more rational, as market demand can be taken into account at that stage. Confidentiality agreements are required, as the information has not yet been disclosed, and lead managers must record the date, counterparty and content of each exchange. Participation is limited to institutions meeting eligibility criteria, including at least KRW 30 billion in entrusted assets for private fund and discretionary managers.

At the filing and review stage, reforms address two issues: (1) duplicated work for companies listing in more than one market, and (2) the format and timing of regulatory review, through mandatory online filing and processing deadlines.

Since 30 September, companies seeking to list in Hong Kong and Malaysia at the same time can do so through a single application. Under a Single Submission Arrangement introduced by Hong Kong’s Securities and Futures Commission (SFC) and the Securities Commission Malaysia (SC), a company applying for a primary listing on the main market of one exchange and a simultaneous secondary listing on the other submits one application and one listing document that meets the requirements of both markets. Each regulator has set up a dedicated review team as a contact point for applicants, and the two regulators and the Hong Kong exchange coordinate their reviews to align timelines and streamline queries. The arrangement builds on a memorandum of understanding signed in July and, according to the regulators, should reduce duplication and compliance costs while widening companies’ access to cross-border fundraising and investors. Approval remains a matter for each authority and exchange, and none is bound by another’s assessment.

In the Philippines, the SEC has made online filing mandatory for registration statements. Under a memorandum circular issued on 24 August, applications for initial public offerings, follow-on offerings, direct public offerings and first-tranche shelf registrations, other than for debt securities, must be submitted through its Online Application for Registration Statements platform, which was tested with stakeholders before launch. Applications are to be processed within 40 days of payment of the initial assessment fee. The SEC links the change to improving the ease of doing business through automation and faster turnaround times, and to encouraging more companies to consider the capital market as a source of funding.

Reforms at the book-building stage run in a different direction from those at the other three. Whereas the measures at the other stages mostly remove steps or widen what issuers may do, citing the cost, time and execution risk that existing rules impose on issuers, the book-building reforms add obligations or conditions, in response to problems the regulators identify in market outcomes: orders that are not backed by investors’ ability to pay, and sharp price falls as investors sell immediately after listing. Both aim to make investor demand more reliable, both when orders are placed and once shares start trading. The measures cover the validity of investor orders, the timing of underwriting commitments, the information issuers disclose to support pricing, and the advance allocation of shares to investors that accept lock-ups.

Saudi Arabia’s Capital Market Authority (CMA) has proposed rules to strengthen the link between orders placed during book-building and investors’ actual ability to pay. Financial advisers and other institutions receiving orders would have to verify that each order reflects the liquidity actually available to the investor, accept only cash or cash equivalents as evidence of financial capacity, and ensure that orders become binding for payment by the subscription deadline set out in the prospectus. The underwriting agreement would have to be in effect before book-building begins, committing the underwriter from that point to buy all the shares on offer. If the underwriter’s resulting holding would cause the issuer to fail the listing requirements, the shares would not be listed and the underwriter would still have to buy them. To give investors a clearer basis for their orders and for setting the offer price, issuers would also have to disclose forecasts and forward-looking financial performance indicators covering at least one year, subject to due diligence by their financial adviser. According to the CMA, the package would make the order book a more reliable basis for setting the offer price.

From November, South Korea will allow IPO lead managers to set aside part of an offering for cornerstone investors: institutions that commit before the IPO to buy shares and hold them for at least six months. In return, they are allocated shares in advance, out of the portion of the offering reserved for institutional investors. The FSC’s aim is to bring stable, longer-term investors into IPOs from the start, build confidence in new listings and reduce the so-called “IPO stock tragedy”, in which share prices fall sharply because investors sell heavily straight after listing. The cornerstone system is introduced alongside the pre-IPO demand forecasting described above, so the same package widens what lead managers may do before the price range is set and attaches lock-ups and caps to the allocations that follow.

For companies that are already listed or registered, reforms shorten the route to further capital, in several cases by relying on their existing disclosure record. The measures take two forms: exemptions from prospectus or approval requirements, and faster registration of new offerings.

Canada’s securities regulators have proposed making permanent the higher limits under the listed issuer financing exemption, which allows listed companies with up-to-date disclosure records to raise capital from the public without a prospectus. A 2025 blanket order raised the annual limit per issuer to the greater of CAD 25 million and 20% of market value, capped at CAD 50 million, from a previous maximum of CAD 10 million. The proposals would also relax the requirement that issuers show sufficient funds for the 12 months after an offering, which market participants said many smaller issuers could not meet, while requiring additional disclosure from issuers facing going-concern uncertainty. In Thailand, the SEC has proposed that companies listed on the LiVE Exchange be able to place new shares or convertible debentures with up to 50 institutional and high-net-worth investors, raising less than THB 10 million in any 12 months, without SEC approval or a registration statement. The SEC presents the proposal as part of its work to make the capital market a fundraising channel for SMEs while maintaining appropriate investor protection.

Source: CSA Notice and Request for Comment, 23 July 2026; OSC Annex C, Table 1

China’s securities regulator (CSRC) has proposed making it easier for listed companies to raise follow-on capital. Companies with high-quality disclosure could register private placements priced through competitive bidding once and then issue in several tranches, which the CSRC says would help them raise funds when market conditions allow and avoid the market impact of single large fundraisings. The standard cap on the fast-track route for small refinancings would double to RMB 600 million for companies listed in Shanghai and Shenzhen, subject to a limit of 20% of net assets. The proposals would also tighten the terms of private placements, with all placements priced by reference to the first day of the offering period and a 36-month lock-up for placements to controlling shareholders.

In Peru, the securities regulator (SMV) has simplified the registration of public offerings under rules in force since 29 August. Some filings are now registered automatically, including non-fundamental changes to an offer and the updated prospectus that issuers must file three years into a multi-offering programme. Issuers may also incorporate documents they have already filed, such as annual reports and financial statements, by reference rather than filing them again. Established issuers, with at least two years on the register and no sanctions beyond admonitions in the past year, can register short-term debt under a programme automatically. The SMV says the changes will make its procedures more efficient, reduce compliance costs and make it easier for current and new issuers to access the market.