HONG KONG: HKEX Proposes Enhancements to Structured Products Listing Framework

Monday October 6 2025

On 30^th September 2025, the Stock Exchange of Hong Kong Limited (HKEX) published a consultation paper on proposed enhancements to the listing regime for structured products (the Consultation Paper). The consultation is open for a six-week period, concluding on Tuesday, 11^th November 2025. Key proposals include:

Increasing market competitiveness

• Lowering the minimum issue price requirement for derivative warrants to $0.15 from $0.25; and removing the minimum issue price requirement for callable bull/bear contracts to facilitate a wider range of product terms.
• Changing the eligibility threshold for an ETF as underlying security for structured products issuance to at least $1 billion of assets under management, from at least $4 billion of public float capitalisation, over a 60-day qualifying period.
• Requiring emulation issues to have identical product terms as existing issues.
• Expanding entitlement ratio of derivative warrants and callable bull/bear contracts with additional ratios.
• Removing prescriptive product terms requirements from the Listing Rules and requiring product issuance to be subject to permitted product terms to be published by the Exchange from time to time.

Enhancing market quality and investor protection

• Raising issuers’ minimum net asset value requirement to $5 billion from $2 billion and mandating that issuers be regulated entities.
• Mandating investment grade ratings by all credit rating agencies from which credit ratings are sought. The credit rating requirement may be fulfilled by the issuers, guarantors or their respective holding companies.
• Mandating the minimum service level for liquidity provision specified in the listing documents to comply with minimum service levels as published by the Exchange from time to time.
• Shortening the publication timeframe of interim financial reports (in respect of the first six months) by issuer and guarantor to three months after the end of the interim period.
• Mandating publication of consolidated financial statements for issuers and guarantors that have subsidiaries.

Elevating market efficiency

• Removing the requirement to publish launch announcement and streamlining listing document for further issues of structured products to reduce issuers’ administrative burden without compromising the amount of information available to investors.
• Allowing securities dealers (that are also issuers) to offer incentives subject to safeguards set out in the Listing Rules. Incentives relating to specific structured products shall be in the form of fee discounts.

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