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12 November 2025

SGX RegCo Issues Its Response On Its Proposals For A More Disclosure Based Regime

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
With effect from October 29, 2025, Singapore Exchange Regulation (SGX RegCo) has put into place measures in response to comments on its consultation paper on "A Shift to a More Disclosure-Based Regime" (issued on May 15, 2025) (Response).
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With effect from October 29, 2025, Singapore Exchange Regulation (SGX RegCo) has put into place measures in response to comments on its consultation paper on "A Shift to a More Disclosure-Based Regime" (issued on May 15, 2025) (Response). In the Response, the SGX RegCo implemented changes to facilitate listings on the SGX.

Key updates

  • Profit test: The minimum pre-tax profit requirement is reduced from SGD30 million to SGD10m, making SGX more accessible for emerging companies.
  • Financial position: Issuers can now disclose outstanding debts in the prospectus without mandatory repayment before listing, expediting the listing timeline.
  • Conflict of interest: Conflicts with interested persons need not be resolved before listing but must be disclosed if unresolved, expediting the listing timeline (real estate investment trusts (REITs) and business trusts (BTs), which must still resolve conflicts pre-listing).
  • Internal controls: Material weaknesses need not be resolved before listing but must be disclosed, with plans for remediation, supporting transparency.
  • REITs and life science companies: Rules now facilitate listings for REITs with short-term leases and early-stage life science firms.
  • Financial watch-list and trading alerts: SGX RegCo removes the financial watch-list and introduces time-limited trade-with-caution alerts, reducing market disruptions.

Read our reportfor a summary of the key changes.

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