Practical Overview of HKEX’s Latest Guidance on Disclosure Requirements

  • English

  • HKCGI Member, Graduate, Student, Affiliated Person & Non-Member


  • Ms Stephanie Chan, Partner, Sidley Austin
  • Mr Adrian Tang, Senior Associate, Sidley Austin


In recent years, the Hong Kong Stock Exchange (“HKEX”) has placed a greater focus on ensuring that corporate disclosures are made by listed issuers on a timely basis and the contents of such disclosures are factually accurate, complete and not misleading. The key premise is that disclosure of information is a cornerstone requirement to enable investors to have sufficient information to make informed decisions on their investments in listed issuers. This includes information regarding all material factors which may affect the investors’ interests. In the March 2023 edition of its Enforcement Bulletin, the HKEX expressed reservations on the practice of disclosing “partial truths”, noting that such disclosures may also be regarded as misleading by omission. One particular area where such partial truth disclosures may be deployed is in resignation announcements for directors and auditors, which the HKEX considers may be in part to obfuscate the actual underlying reasons for the departures. Similarly, another area of disclosure that is attracting the HKEX’s recent attention surrounds the use of IPO proceeds by newly-listed issuers.

In this seminar, two speakers from Sidley Austin’s contentious regulatory team will provide a practical overview of the latest guidance and enforcement trends from the HKEX with respect to compliance with the disclosure requirements under the Hong Kong Listing Rules. In particular, the speakers will draw attention to key considerations in handling public disclosures by listed issuers and share practical tips in managing enquiries and investigations brought by the HKEX pursuant to alleged disclosure failures.

Highlights of the seminar:

  1. General overview of March 2023 edition of HKEX’s Enforcement Bulletin;
  2. HKEX’s latest focus on partial truth disclosures;
  3. Considerations for resignation announcements for directors and auditors;
  4. HKEX’s expectations for disclosures by newly-listed issuers;
  5. Recent enforcement trends involving corporate disclosure; and 
  6. Practical tips on handling enquiries and investigations on alleged disclosure failures.

(Recorded in June 2023)

Level: Intermediate

Speakers' bio:
Ms Stephanie Chan
Mr Adrian Tang

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