Circular on the Single Submission Arrangement for Dual Listings in Hong Kong

2026-09-30 Preamble

On 23 July 2026, the Securities and Futures Commission ( SFC ) and the Securities Commission Malaysia ( SC ) signed a Memorandum of Understanding Concerning Mutual Recognition of Covered Funds and Simplified Dual IPO Listing Framework ( MoU ).

The MoU facilitates cross-listings of equity securities between Hong Kong and Malaysia, strengthens regulatory collaboration between the SFC and the SC, and establishes a framework for simultaneous IPO listings in both markets.

To support this regime, the SFC and the SC have established a simplified framework for companies seeking simultaneously a primary listing in one jurisdiction and a secondary listing in the other, either on the Main Board of The Stock Exchange of Hong Kong Limited ( SEHK ) or the MAIN Market of Bursa Malaysia Securities Berhad ( Single Submission Arrangement ).

The streamlined and coordinated application process may benefit applicants seeking simultaneous primary and secondary listings under the Simplified Dual IPO Listing Framework. The framework adopts a single submission model, under which all required application materials are submitted through the regulator of the primary listing. It also provides for a coordinated review process, including a single channel for regulatory comments and applicants’ responses arising from reviews conducted by the relevant authorities.

Submission Guidance

The table below outlines the application, prospectus and submission requirements applicable to each scenario.

Primary listing: Hong Kong 1

Secondary listing: Malaysia

Primary listing: Malaysia

Secondary listing: Hong Kong 2

Single Application Submission

Application materials

Applicant submits to SEHK :

Full application materials required by SEHK; and

Full application materials required by SC and the additional information as set out in Appendix III of the Guidance for Listing of Hong Kong Companies on MAIN Market of Bursa Malaysia Securities Berhad issued on 30 September 2026.

Applicant submits to the SC :

Full application materials required by the SC; and

Full application materials required by SEHK.

Note:

The submission package should be structured in two separate, clearly identified parts:

(i) SEHK application materials; and

(ii) SC application materials.

Should the same application materials/ documents be required in both parts, references can be made to the relevant materials/ documents in the other part of the submission.

Other matters relating to the Application

1. Type of listing

Applicants should specify in the submissions to the authorities whether the listing is:

Hong Kong Primary / Malaysia Secondary; or

Malaysia Primary / Hong Kong Secondary.

2. Guidance for Hong Kong-licensed sponsor

The sponsor should submit information regarding the applicant’s principal activities when it files the sponsor engagement notification to SEHK.

3. Authorisation for primary listing authority to file documents with secondary listing authority

In its submission, an applicant should include an authorisation permitting the primary listing authority to file with the secondary listing authority all materials and documents submitted relating to the application, including those submitted by its advisors and agents on its behalf, and an acknowledgement that both the primary listing authority and the secondary listing authority will have access to such materials and documents.

4. Application for relief / waiver from compliance with guidelines or listing requirements

Applications for relief / waiver, if applicable, are to be submitted as part of application materials.

5. Document format

Applicants are reminded that documents submitted should be in text-searchable PDF format.

Prospectus

Single prospectus submitted to SEHK , incorporating the requirements by SC.

Single prospectus submitted to SC , incorporating requirements by SEHK.

Submitting party

SFC - licensed sponsor

Application for secondary listing in Malaysia to be signed by a recognised principal adviser or an SFC-licensed sponsor 3

Recognised principal adviser

Application for secondary listing in Hong Kong to be signed by an SFC-licensed sponsor

Regulatory queries and applicant’s responses

Single set of regulatory queries issued by:

SEHK

Responses to queries to be submitted to:

SEHK

Single set of regulatory queries issued by:

SC

Responses to queries to be submitted to:

SC

Listing and quotation application to Bursa Malaysia

Applicant must comply with the applicable provisions of the MAIN Market Listing Requirements relating to a secondary listing.

Applicant concurrently submits its listing application and supporting documents for the listing and quotation of its shares on the MAIN Market as part of SC Application Materials to SEHK .

Applicant must comply with the applicable provisions of the MAIN Market Listing Requirements relating to a primary listing.

Applicant concurrently submits its listing application and supporting documents for the listing and quotation of its shares on the MAIN Market to SC .

Reporting Accountant (“RA”)

For listing in Malaysia, the RA must be registered with the Audit Oversight Board (AOB) of the SC. If a foreign audit firm is appointed to become the RA, such foreign audit firm will be required to apply for recognition by the AOB. Please refer to the website of AOB for further information on Recognition of Audit Firms and Individual

Auditors . It is advisable to start the process at least three months before the date of submission of the IPO application.

For listing in Hong Kong, the RA must be independent of the issuer to the same extent as required of an auditor under the Companies Ordinance (Cap. 622) and must comply with the independence requirements issued by Hong Kong Institute of Certified Public Accountants or International Federation of Accountants. An applicant must normally appoint a firm that is a Registered PIE Auditor and is not prohibited from acting under the Accounting and Financial Reporting Council Ordinance (Cap. 588). 4

Prospectus exposure

Coordination on exposure and registration of draft prospectus

The applicant should coordinate the timing of the exposure of the draft prospectus or updated prospectus, as applicable, and the registration of the prospectus in the respective jurisdictions. The applicant should discuss the proposed timetable with both authorities at an early stage and keep them informed of any subsequent changes.

Applicants and their sponsors or recognised principal advisers are encouraged to consult the SFC, SEHK, or the SC, as appropriate, before formally submitting a listing application to discuss the proposed transaction structure and indicative timeline. In particular, an applicant proposing a dual primary listing in Hong Kong and Malaysia may consult the relevant authorities at an early stage regarding the potential application under the Single Submission Arrangement.

The SFC’s dedicated team may be contacted at HK-Malaysia-duallistings@sfc.hk , while the SC’s dedicated team may be contacted at HK-Malaysia-duallistings@seccom.com.my .

Other reference materials

For information relating to simultaneous primary and secondary listings in Hong Kong and Malaysia, applicants should refer to this circular together with related guidance materials available on the SEHK website and the SC website, including:

SEHK’s Explanatory Note on Malaysia-incorporated Company’s Compliance with Core Shareholder Protection Standards and Other Matters

SC’s Guidance for Listing of Hong Kong Companies on Main Market of Bursa Malaysia Securities Berhad

End

1 An overseas issuer seeking a primary listing in Hong Kong must be incorporated in a jurisdiction that is included on SEHK’s List of Overseas Jurisdictions of Incorporation .

2 For a secondary listing in Hong Kong, the applicant must be a public company incorporated in Malaysia that is already listed or is the subject of an application for listing on the Main Market of Bursa Malaysia Securities Berhad.

3 Referring to an SFC licensed sponsor that has affiliate within the same group who are either recognised principal adviser or a Capital Markets Services Licence holder for the regulated activity of advising on corporate finance in Malaysia, and is allowed by the SC to sign application to the SC.

4 If the Applicant intends to appoint an overseas audit firm as its reporting accountants, please refer to Chapter 2.1 of the Guide for New Listing Applicants . Information on the registration of Hong Kong auditors as PIE auditors and the recognition of non-Hong Kong auditors as PIE auditors can be found on the website of the Accounting and Financial Report Council.

Corporate Finance Division Securities and Futures Commission