Between 4 and 7 February 2026, Partners Willy Cheng and Lai Lam represented the firm at the Interlaw Asia Pacific Regional Meeting in Sydney. As a founding member of this elite global network which comprises over 90 firms in 150 cities, our participation ensures we remain at the forefront of international legal developments.

Under the theme “Connecting Through Shared Values,” the three-day event was designed to strengthen business ties and foster cooperation between member firms from across the Asia Pacific and beyond. During the summit, Mr. Cheng and Ms. Lam engaged in a series of curated sessions and workshops focusing on the most pressing issues facing the profession. These discussions explored the defining role of AI within the Banking and IP sectors, the impact of shared values on recruitment for Employment and Labour in the digital age, and contemporary strategies for Leadership and Management. The meeting also provided a dedicated forum for participants to discuss specific business development initiatives aimed at deepening cross-border cooperation and streamlining service delivery across the region.

Please contact our Partners Willy Cheng or Lai Lam for further enquiries about this event.

On 6 February 2026, our Consultant Kenneth Leung and Associate Ronnie Tse partnered with TF International Securities Group Limited (“TFI”) to deliver an exclusive training seminar titled “Mastering Part XV of the Securities and Futures Ordinance (SFO)”.

At TFI’s Hong Kong headquarters, Kenneth and Ronnie provided an in-depth analysis of the “Disclosure of Interests” (DI) regime, a cornerstone of market transparency in Hong Kong.

Why Part XV Matters Now

For directors, chief executives and shareholders of listed companies, failure to timely and accurately disclose interests can result in criminal liability, imprisonment, and reputational damage. For securities firms and licensed corporations, understanding the nuances of the regime—particularly the latest updates—is critical for both internal compliance and client advisory.

Key Highlights from the Session

The seminar provided TFI’s team with a practical roadmap through the complexities of Part XV, moving beyond basic rules to address advanced operational challenges. Key topics included:

• The “Treasury Shares” Update: Clarifying the SFC’s May 2024 revised Outline of Part XV, specifically the rule that treasury shares remain part of the “issued voting shares” denominator, reflecting the new framework for treasury shares adopted by the HKEX in June 2024.
• Deemed Interests & The “Chain”: Unpacking the “one-third rule” for controlled corporations and how interests aggregate across complex group structures, family trusts, and concert party agreements.
• Pitfalls in Electronic Filing: Best practices for navigating the HKEX DION System, including the strict “3-business-day” rule and common errors in filing Initial Notifications versus Change in Nature notices.
• Exemptions from UBO Disclosure: A deep dive into the exemptions under Part XV, helping investment managers understand situations where the ultimate beneficial owner (UBO) does not need to be disclosed.

About TF International Securities

TFI is one of the most established Chinese-funded securities groups in Hong Kong, operating through subsidiaries holding SFC licences for types 1, 2, 4, 5, 6, and 9 regulated activities. TFI is under the stewardship of Hubei Hongtai Group Co., Ltd, the sole financial services enterprise affiliated with the Hubei Provincial People’s Government.

How We Can Help

Navigating the SFO requires a team of people well versed in its practical application, beyond a plain reading of the rules. Our Regulatory Enforcement & Compliance team specializes in helping listed companies, substantial shareholders, and financial institutions manage their reporting obligations and regulatory risks.

For enquiries or to schedule a tailored regulatory compliance seminar for your team, please contact our Consultant Kenneth Leung or Associate Ronnie Tse.

联会的成立是粤港澳三地法律界融合发展的重要里程碑，旨在加强三地法律专业人士的交流与协作，促进跨境法律服务的协同发展，并精准回应大湾区内日益增长的跨司法管辖区法律需求。作为区内执业律师的关键沟通平台，联会将致力于落实《粤港澳大湾区发展规划纲要》，推动法律服务的深度融合。徐律师作为联会副主席将克尽己任，尽心履职，与联会成员保持紧密合作，积极发挥沟通协调与专业桥梁作用，与业界同仁携手推动法律服务水平的持续提升，为粤港澳大湾区的高质量发展贡献专业力量。

如阁下有查询或想了解更多详情，请联络本所合伙人徐凯怡律师。

公司法改革常务委员会是香港财经事务及库务局辖下的重要咨询组织，其职能就《公司条例》和《证券及期货条例》等条例修订向政府提供专业意见。委员会致力于构建清晰、高效且稳健的法律框架，以优化企业营运环境，进一步巩固香港作为国际商业及金融中心的领先地位。

徐律师是香港律师会理事、大中华法律事务委员会副主席及仲裁委员会委员；同时担任香港国际仲裁中心理事和香港国际仲裁中心仲裁女性俱乐部 (WIA) 委员。徐律师多获多家知名仲裁机构委任为仲裁员及调解员，包括香港国际仲裁中心、中国国际经济贸易仲裁委员会、上海国际仲裁中心、华南（香港）国际仲裁院、亚非法协（香港）、北京仲裁委员会/北京国际仲裁中心等。此外，她亦是广东省高级人民法院﹑深圳前海合作区人民法院的特邀调解员。

徐律师拥有粤港澳大湾区执业律师资格及中国委托公证人身份，并为英国特许仲裁司学会院士。

如阁下有查询或想了解更多详情，请联络本所合伙人徐凯怡律师，或按此查看香港政府之新闻公报。

Stevenson, Wong & Co. is pleased to announce that our Partner and Head of Banking and Finance, Litigation and Dispute Resolution, and Co-head of the FinTech Group, Heidi Chui, alongside our Partner and Deputy Head of Corporate Finance and Co-head of the FinTech Group, Rodney Teoh, have been honoured as Growth Drivers in The A-List 2025–26 by China Business Law Journal.

This recognition reaffirms the sustained leadership of both Partners in their respective fields. Ms. Chui has been acknowledged for this accolade for the fifth consecutive year, while Mr. Teoh has received this honour for the third consecutive year.

The selection for the “A-List Elite Lawyers” is based on thousands of nominations and independent research from corporate legal counsel, executives, and legal peers, ensuring a high level of industry credibility. The “Legal Elite” category specifically aims to recognise exceptional lawyers who demonstrate both profound professional expertise and significant market influence, particularly in driving business development and earning client trust.

We would like to express our gratitude to China Business Law Journal and our clients for their ongoing support.

For further details, please contact our Partners, Heidi Chui and Rodney Teoh, or view the official report on the CBLJ website here.

HKEX Publishes Consultation Paper on Enhancements to Board Lot Framework

 9 January 2026

1. Introduction

On 18 December 2025, Hong Kong Exchanges and Clearing Limited (“HKEX” or the “Exchange”) published a consultation paper on proposed enhancements to the board lot framework in the Hong Kong securities market (the “Consultation Paper”). The initiative, mandated by the HKSAR Government’s Task Force on Enhancing Stock Market Liquidity established in August 2023, aims to streamline trading, clearing and settlement processes while expanding investor participation.

The consultation period will run until 12 March 2026. Stakeholders are invited to submit feedback via HKEX’s online questionnaire, with a consultation conclusions paper tentatively (the “Consultation Conclusions”) scheduled for release by the end of the first half of 2026. This update breaks down the core proposals, their strategic rationale, and potential impacts on market participants.

2. Background: Hong Kong’s Board Lot Framework

A board lot is the standard number of shares required for a single transaction in the securities market, serving as a cornerstone of orderly trading and operational efficiency. Unlike most major global exchanges that adopt a single unified board lot unit, Hong Kong’s current framework is “issuer-led”, allowing each listed company to determine its own board lot size.

This approach has resulted in significant fragmentation. Currently, 44 distinct board lot units are in use, ranging from 10 shares to 100,000 shares. While 2,000 shares is the most common unit which is used by 25% of issuers, the 100-share unit accounts for the largest share of average daily turnover and market capitalisation.

This fragmentation has created multiple challenges:

(i)      Operational inefficiencies: Complexity in trading, clearing and settlement processes;
(ii)      Barriers to retail participation: Extremely high board lot values make certain securities
          unaffordable for small investors, while low board lot values risk “negative value trades”
          where execution costs exceed trade value; and
(iii)      Misalignment with global practices: Divergence from international standards complicates
          cross-market trading, particularly for Southbound Stock Connect investors familiar with
          Mainland China’s unified 100-share board lot.

Additionally, Hong Kong’s market has a higher proportion of low-priced securities (56% of securities traded in the Hong Kong securities market (“Applicable Securities”) trade below HK$1.0) and fixed execution costs, making an immediate shift to a single unified board lot unit impractical due to the risk of widespread negative value trades.

3. Key Enhancements in Detail

3.1  Board Lot Value Floor and Ceiling Guidance

To balance accessibility and risk mitigation, HKEX proposes revising existing guidance and introducing a new ceiling:

(i)      Reduction of board lot value floor guidance: HKEX proposes decreasing the existing board
          lot value floor from HK$2,000 to HK$1,000. This adjustment reduces entry barriers without
          increasing negative value trade risks. The floor applies only when issuers list or adjust board
          lot units. No action is required if stock price movements push values below HK$1,000.
(ii)      Introduction of board lot value ceiling guidance: HKEX proposes to introduce board lot
          value ceiling at HK$50,000, applicable only to issuers using units larger than 100 shares. The
          ceiling encourages issuers to split units to maintain accessibility.

 3.2 Standardisation of board lot units

HKEX proposes reducing the number of permissible board lot units to eight board lot options (i.e., 1, 50, 100, 500, 1,000, 2,000, 5,000, and 10,000 share(s)), covering diverse price bands from HK$0.1 to HK$1,000+ per share. The proposed new board lot framework would result in 657 securities needing to change board lot units, representing approximately 25% of the 2,680 Applicable Securities. The standardised set supports future convergence to a single unit by encouraging gradual adoption of smaller units.

 3.3 Phased Implementation Aligned with the Uncertificated Securities Market (“USM”)

To minimise market disruption, the framework will be rolled out in two phases, coordinated with HKEX’s USM initiative which replaces physical share certificates with electronic records:

Phase One:

(i)      New issuers: Must adopt the eight standardised units and comply with the HK$1,000
          floor/HK$50,000 ceiling upon listing.
(ii)      Existing issuers: No immediate unit standardisation required. Only need to adhere to the
          HK$1,000 floor/HK$50,000 ceiling guidelines.

Phase Two: Existing issuers must adopt one of the standardised units within a specified period after transitioning to USM. This aims at avoiding reprint physical share certificates and optimising issuer resources.

 A detailed implementation timeline may be included in the Consultation Conclusions Paper.

4. Strategic Implications for Market Participants

The proposed enhancements will have distinct impacts on key market stakeholders:

 Approximately 25% of listed issuers will need to revise their board lot units to one of the eight standardised options. In the long term, these reforms will reduce operational complexity and better align with the needs of global and international investors—particularly for “A+H share” issuers seeking consistency across Mainland China and Hong Kong markets. Issuers must continuously monitor their board lot values to ensure compliance with the HK$50,000 ceiling applicable to units exceeding 100 shares.

Investors will benefit from lower entry barriers, expanding access to high-quality securities, reducing concentration risk, and enabling portfolio diversification. Institutional investors will find trading, hedging and settlement processes simplified by standardised units, lowering operational costs and the risk of errors.

Fewer board lot units significantly enhance the operational efficiency of brokers and intermediaries by streamlining system configurations, order entry, and client onboarding processes. Reduced odd lot creation and clearer value guidelines help mitigate operational and settlement risks, strengthening risk management. Additionally, standardised board lots simplify the management of associated products, whose terms are often linked to the underlying securities’ board lot units, eliminating the need for complex adjustments.

5. Conclusion

The consultation period runs until 12 March 2026, and all interested parties—including issuers, brokers, institutional and retail investors, legal and compliance professionals, and investor advocacy groups—are strongly encouraged to submit feedback via the Exchange’s online questionnaire.

Given the transformative nature of these proposals, stakeholders are urged to:

(i)      review the Consultation Paper in full (available on HKEX’s website);
(ii)      provide detailed, data-driven feedback by 12 March 2026 to shape the final rules; and
(iii)      prepare for phased implementation, particularly aligning systems and processes with USM
          transition timelines.

The success of this reform will depend on balancing operational efficiency, investor accessibility and issuer flexibility, ensuring Hong Kong’s securities market remains dynamic, inclusive and aligned with global best practices.

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.