Securities and Futures Commission & Securities Commission Malaysia Memorandum of Understanding on Simplified Dual IPO Listing Framework Circular on the Single Submission Arrangement for Dual Listings in Hong Kong

On September 30, 2026, the Securities and Futures Commission of Hong Kong (""SFC"") issued a circular entitled 'Circular on the Single Submission Arrangement for Dual Listings in Hong Kong.' This circular was promulgated pursuant to the Memorandum of Understanding Concerning Mutual Recognition of Covered Funds and Simplified Dual IPO Listing Framework (the "MoU"), executed between the SFC and the Securities Commission Malaysia (""SC"") on 23 July 2026. The MoU established a regulatory framework facilitating cross-listings of equity securities, strengthening bilateral supervisory cooperation, and enabling simultaneous initial public offering listings in both jurisdictions.

The Single Submission Arrangement

Pursuant to the single submission arrangement, all requisite application materials are channelled through the regulator of the primary listing jurisdiction. The framework provides for a coordinated review process wherein regulatory comments and applicants' responses arising from reviews conducted by both authorities are addressed through a single communication channel.

Application Materials and Submission Structure

Where an applicant seeks a primary listing in Hong Kong with a secondary listing on the MAIN Market of Bursa Malaysia Securities Berhad, it must submit to SEHK: (i) full application materials as required by SEHK; and (ii) full application materials as required by the SC, together with additional information 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. Conversely, where an applicant seeks a primary listing in Malaysia with a secondary listing in Hong Kong, it must submit to the SC: (i) full application materials as required by the SC; and (ii) full application materials as required by SEHK.

The submission package shall be structured into two clearly identified parts—(i) SEHK application materials and (ii) SC application materials. Where identical documents are required in both parts, cross-references to the relevant materials may be made rather than duplicating such documents.

Additional Application Requirements

Several matters pertain to the preparation of applications under this arrangement: First, applicants must specify whether the proposed listing constitutes a Hong Kong primary / Malaysia secondary or a Malaysia primary / Hong Kong secondary. Second, where an SFC-licensed sponsor is engaged for a Hong Kong primary listing, such sponsor shall include information regarding the applicant's principal activities when filing its sponsor engagement notification with SEHK. Third, applicants must include within their submission an authorisation permitting the primary listing authority to file all materials and documents—including those submitted by advisors or agents on behalf of the applicant—with the secondary listing authority, together with an acknowledgement that both authorities shall have access thereto. Fourth, any application for relief from or waiver of compliance with applicable guidelines or listing requirements must be included as part of the application materials. Fifth, all documents submitted must be in text-searchable PDF format.

Prospectus Requirements

Under this arrangement, a single prospectus is to be prepared and filed. For a primary listing in Hong Kong with secondary listing in Malaysia, the single prospectus shall be submitted to SEHK incorporating the requirements of the SC. For a primary listing in Malaysia with secondary listing in Hong Kong, the single prospectus shall be submitted to the SC incorporating the requirements of SEHK.

Submitting Party and Regulatory Queries Process

The application for a secondary listing on Bursa Malaysia's MAIN Market must be signed by either a recognised principal adviser or an SFC-licensed sponsor that has, within its group, an affiliate which is either a recognised principal adviser or holds a Capital Markets Services Licence for the regulated activity of advising on corporate finance in Malaysia, and who is permitted by the SC to sign applications. The application for a secondary listing in Hong Kong must be signed by an SFC-licensed sponsor.

In respect of regulatory queries: where the primary listing is in Hong Kong (secondary in Malaysia), SEHK shall issue a single set of regulatory queries and all responses are to be submitted to SEHK. Where the primary listing is in Malaysia (secondary in Hong Kong), the SC shall issue a single set of regulatory queries and all responses are to be submitted to the SC.

Listing and Quotation Applications

For a secondary listing on Bursa Malaysia's MAIN Market, applicants must comply with the applicable provisions of the MAIN Market Listing Requirements relating to secondary listings and concurrently submit their listing application together with supporting documents as part of the SC Application Materials. For a primary listing on Bursa Malaysia's MAIN Market, applicants must similarly comply with the relevant MAIN Market Listing Requirements for primary listings and file their listing application and supporting documents with the SC.

Reporting Accountant Requirements

For a listing in Malaysia, the reporting accountant must be registered with the Audit Oversight Board of the SC. Where a foreign audit firm is appointed as reporting accountant, it shall apply for recognition by the AOB; applicants are advised to commence this process no later than three months prior to the submission date of the IPO application. For a listing in Hong Kong, the reporting accountant must be independent of the issuer to the same extent required of an auditor under the Companies Ordinance (Cap. 622) and must comply with independence requirements issued by either the Hong Kong Institute of Certified Public Accountants or the International Federation of Accountants. The applicant is ordinarily required to appoint a firm that is a Registered PIE Auditor and not prohibited from acting under the Accounting and Financial Reporting Council Ordinance (Cap. 588).

Coordination of Prospectus Exposure and Registration

Applicants are expected to coordinate the timing of exposure of the draft or updated prospectus, as applicable, with the registration process in each respective jurisdiction. The proposed timetable should be discussed with both authorities at an early stage, and any subsequent changes must be promptly communicated.

Pre-Filing Consultation

Applicants and their sponsors or recognised principal advisers are encouraged to engage the SFC, SEHK, or the SC—as appropriate—prior to formal submission of a listing application in order to discuss the proposed transaction structure and indicative timeline. In particular, an applicant contemplating a dual primary listing in both Hong Kong and Malaysia is advised to consult the relevant authorities at an early stage regarding potential applicability under this arrangement.

Contact Information

The SFC's dedicated team may be reached at This email address is being protected from spambots. You need JavaScript enabled to view it., and the SC's dedicated team at This email address is being protected from spambots. You need JavaScript enabled to view it..

Reference Materials

For further information relating to simultaneous primary and secondary listings in Hong Kong and Malaysia, applicants should refer to this circular together with the following guidance materials available on the SEHK website and the SC website respectively: (i) SEHK's Explanatory Note on a Malaysia-Incorporated Company's Compliance with Core Shareholder Protection Standards and Other Matters; and (ii) the SC's Guidance for Listing of Hong Kong Companies on Main Market of Bursa Malaysia Securities Berhad.

Supplementary Notes

The following supplementary notes apply: First, an overseas issuer seeking a primary listing in Hong Kong must be incorporated in a jurisdiction included on SEHK's List of Overseas Jurisdictions of Incorporation. Second, 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. Third, where an applicant intends to appoint an overseas audit firm as its reporting accountant, reference should be made to Chapter 2.1 of the Guide for New Listing Applicants; information regarding registration of Hong Kong auditors and recognition of non-Hong Kong auditors as PIE auditors is available on the website of the Accounting and Financial Reporting Council.

This circular was issued by the Corporate Finance Division, Securities and Futures Commission. Page last updated: 30 Sep 2026.