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2 October 2026
Introduction
On 30 September 2026, the Securities and Futures Commission (the “SFC”) and the Securities Commission Malaysia (the “SC”) announced the implementation of simplified regulatory procedures and submission arrangements to facilitate simultaneous listings in Hong Kong and Malaysia (the “Single Submission Arrangement”).
The Single Submission Arrangement brings into operation the simplified dual initial public offering (“IPO”) listing framework contemplated under the Memorandum of Understanding between the SFC and SC concerning mutual recognition of covered funds and the simplified dual IPO listing framework signed on 23 July 2026 (the “MoU”).
Under the Single Submission Arrangement, an applicant seeking a primary listing on either the Main Board of The Stock Exchange of Hong Kong Limited (the “Stock Exchange”) or the MAIN Market of Bursa Malaysia Securities Berhad (the “Bursa Malaysia”), together with a simultaneous secondary listing on the other market, may proceed through a streamlined application process via a single listing application submission supported by a single listing document.
The new arrangement is intended to reduce regulatory duplication and compliance costs at the IPO application stage and facilitate greater connectivity between the Hong Kong and Malaysian capital markets.
The arrangement applies to a simultaneous primary and secondary listing involving the Main Board of the Stock Exchange and the MAIN Market of Bursa Malaysia. It does not create a general passporting regime for all forms of cross-listing, nor does it remove the substantive eligibility, disclosure or investor protection requirements applicable in either jurisdiction.
How the Single-Submission Process Works
| Primary listing | Secondary listing | Submission route |
| Hong Kong Main Board | Bursa Malaysia MAIN Market | Submit to the Stock Exchange the full Hong Kong application materials and the full SC materials, including the prescribed additional information |
| Bursa Malaysia MAIN Market | Hong Kong Main Board | Submit to SC the full Malaysian application materials and the full Stock Exchange application materials |
The submission package should be divided into separately identified Hong Kong and Malaysian parts. Where the same application materials or documents are required in both parts, cross-references may be made to the relevant materials or documents in the other part.
Key Features of the Single Submission Arrangement
The Single Submission Arrangement introduces a coordinated approach to the application and regulatory review processes for simultaneous listings in Hong Kong and Malaysia. Its key features include:
- Single Listing Document: An applicant may use one listing document for both listings, provided that the document satisfies the applicable statutory, prospectus, disclosure and listing requirements of both Hong Kong and Malaysia.
- Single Point of Submission: An applicant will submit the application materials required by both markets through the authority responsible for its primary listing. Where Hong Kong is the primary-listing market, the full application materials required by the Stock Exchange and the SC materials, including the prescribed additional information, will be submitted to the Stock Exchange. Where Malaysia is the primary-listing market, the full application materials required by SC and the Stock Exchange will be submitted to SC. The submission package must be divided into separately identified Hong Kong and Malaysian parts, although cross-references may be used for documents required in both parts.
- Dedicated Dual-Listing Review Teams: Dedicated teams and communication channels have been established by the regulators to act as direct points of contact for applicants and their professional advisers. This is intended to facilitate active case management, coordination between the relevant authorities and efficient handling of applications throughout the listing process.
- Coordinated Regulatory Review: The SFC, the Stock Exchange and the SC have established coordinated review processes to align regulatory review timelines, minimise duplication and streamline comments and queries raised with applicants.
The streamlined procedures do not dispense with the regulatory requirements applicable in either jurisdiction. Applicants will remain required to satisfy the relevant statutory, listing, disclosure and investor protection requirements applicable to their proposed listing in each market.
Facilitating the Dual Listing Application Process
In connection with the implementation of the Single Submission Arrangement, the SFC has published a “Circular on the Single Submission Arrangement for Dual Listings in Hong Kong and Malaysia”, setting out the arrangements applicable to prospective dual-listing applicants.
Related guidance materials have also been made available by the Malaysian and Hong Kong authorities. In particular, SC has published the Guidance for Listing of Hong Kong Companies on MAIN Market of Bursa Malaysia Securities Berhad. Reference should also be made to the Stock Exchange’s existing explanatory note concerning a Malaysia-incorporated company’s compliance with Hong Kong’s core shareholder-protection standards and applicable Malaysian laws and regulations.
SC also revised its Guidelines on Submission of Corporate and Product Proposals, Prospectus Guidelines and Equity Guidelines on 30 September 2026 to operationalise the simplified dual-listing framework.
These materials are intended to assist prospective applicants and their advisers in navigating the requirements applicable in the two markets. Applicants, sponsors and other professional advisers are encouraged to consult the SFC, the Stock Exchange or the SC, as appropriate, before formally submitting a listing application to discuss the proposed transaction structure and indicative timetable.
By enabling applicants to prepare a single listing document and proceed through a coordinated submission and regulatory review process, the Single Submission Arrangement is expected to reduce repetitive work and enhance efficiency in the execution of simultaneous Hong Kong-Malaysia listings. At the same time, the continued application of the respective regulatory requirements in both jurisdictions is intended to ensure that the efficiencies introduced by the new arrangement do not compromise existing regulatory standards or investor protection.
Strengthening Connectivity between the Hong Kong and Malaysian Capital Markets
The introduction of the Single Submission Arrangement represents a further development in the regulatory cooperation between Hong Kong and Malaysia following the signing of the MoU in July 2026. It also reflects the broader objective of the two regulators to deepen regional capital market connectivity and facilitate cross-border fundraising opportunities.
Prospective applicants should determine the intended primary-listing market at an early stage, as this will determine the submission channel and the principal application process. They should also conduct an early gap analysis of the eligibility, prospectus, financial-information, corporate-governance and shareholder-protection requirements applicable in both jurisdictions. Although common documents may be cross-referenced, the application package must still address jurisdiction-specific requirements. Applicants should also coordinate with both authorities at an early stage regarding the timing of prospectus exposure and registration and keep them informed of subsequent changes to the timetable. An applicant contemplating a dual-primary listing may also consult the relevant authorities at an early stage regarding the potential application of the Single Submission Arrangement.
The Single Submission Arrangement is also expected to benefit sponsors and other professional advisers by reducing duplication in the preparation and submission of listing materials and facilitating greater coordination in responding to regulatory comments. Nevertheless, applicants and their advisers should consider the applicable requirements of both jurisdictions at an early stage and carefully coordinate the proposed transaction structure, disclosure requirements and listing timetable.
More broadly, the initiative reflects continued efforts to strengthen Hong Kong’s connections with other major capital markets in the region and to enhance its role as an international fundraising platform.
Conclusion
The Single Submission Arrangement is a meaningful procedural development for issuers considering simultaneous access to the Hong Kong and Malaysian capital markets. Its principal benefit lies in allowing the materials required by both markets to be submitted through a single channel, supported by one listing document and a coordinated regulatory review process.
The framework does not, however, amount to mutual recognition of listing eligibility or regulatory requirements. Issuers and their advisers will still need to address the requirements of both jurisdictions and coordinate the transaction structure, disclosure package and timetable from an early stage.
From a commercial perspective, the arrangement may be particularly relevant to suitable businesses seeking to broaden their exposure to investors in Mainland China and Southeast Asia and to diversify their fundraising channels.
Please contact our Partner Mr. Rodney Teoh for any enquiries or further information.
This news update is for information purposes only. Its content does not constitute legal advice and should not be treated as such. Stevenson, Wong & Co. will not be liable to you in respect of any special, indirect or consequential loss or damage arising from or in connection with any decision made, action or inaction taken in reliance on the information set out herein.