Global Trustee and Fiduciary Services Bite-Sized Issue 2 2026

13 QUICK LINKS AIFMD BENCHMARKS REGULATION CRYPTOASSETS FINTECH FUND LIQUIDITY MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2026 ASIA PACIFIC SFC Directs IPO Sponsors to Promptly Conduct Internal Reviews to Rectify Serious Deficiencies in the Preparation of New Listing Documents On 30 January 2026, the Securities and Futures Commission (SFC) issued a circular concerning issues related to serious deficiencies in the preparation of some listing documents, sponsors’ potential misconduct and significant mismanagement of resources amidst a surge in new listing applications in 2025. The SFC said that, in reviewing recent listing applications, it and The Stock Exchange of Hong Kong Limited (SEHK) identified a number of serious deficiencies in the preparation of listing documents and responses to regulatory comments as well as failure to attend to key regulatory processes at the offer stage. The SFC says that these shortcomings strongly suggest that some sponsors might not have a thorough understanding of the listing applicants, whilst others might have failed to perform reasonable due diligence before submitting listing applications and addressing regulators’ enquiries. The SFC also noted serious resources issues on the part of some sponsors, including over-reliance on external professional parties to conduct specific tasks without adequate assessments of their competency and resources, insufficient capacity of sponsor principals to properly supervise transaction teams and participate in listing engagements, and a lack of staff with the requisite knowledge, skills and experience in Hong Kong IPOs to undertake sponsor work. The SFC said that 13 sponsors that received a joint letter from it and SEHK in December 2025, citing specific cases of concerns, as well as sponsors with strained resources, are required to complete comprehensive reviews on the concerns raised and on their resources available to conduct sponsor work, respectively, within three months. For all sponsors, they are required to report to the SFC the ratio of active listing engagements undertaken to the number of appointed sponsor principals, and any staff engaged in IPO sponsor work who have not passed the required examination within prescribed timeframe. The SFC said it will also commence a thematic review on sponsors soon. For current listing applications, the SFC also warns in the circular that, where sponsors provide materially incomplete or unsatisfactory responses to regulators or where listing documents are considered unreasonably lengthy, the vetting process may be suspended. As of 31 December 2025, vetting of 16 listing applications had been suspended. In this connection, the SFC will notify its regulatory counterparts of the suspension of the vetting process. Furthermore, sponsors that have designated any sponsor principal to simultaneously supervise or participate in six or more active listing engagements must provide the SFCwith a viable rectification and resource plan and demonstrate a responsible approach tomanaging their resources. Given that certain sponsors have engaged individuals who have not met the eligibility criteria for passing the required examination, all individuals engaging in IPO sponsor work are now subject to tightened examination requirements. For sponsors whose work continues to be unsatisfactory, the SFC may restrict their business scope and the number of active listing engagements that they are permitted to handle. Link to Circular here