Single Submission Arrangement for the Simplified Dual IPO Listing Framework

The Securities Commission Malaysia (SC) and the Securities and Futures Commission (SFC) of Hong Kong have established the Simplified Dual IPO Listing Framework, enabling eligible issuers to pursue a simultaneous dual listing on Bursa Malaysia and The Stock Exchange of Hong Kong through a simplified dual IPO listing framework.

Preamble

On 23 July 2026, the SC and the SFC of Hong Kong signed a Memorandum of Understanding Concerning Mutual Recognition of Covered Funds and Simplified Dual IPO Listing Framework (MoU).

The MoU facilitates cross-listings of equity securities between Malaysia and Hong Kong, strengthens regulatory collaboration between the SC and the SFC of Hong Kong, and establishes a framework for simultaneous IPO listings in both markets.

To support this regime, the SC and the SFC of Hong Kong have established a simplified framework for companies seeking simultaneously a primary listing in one jurisdiction and a secondary listing in the other, either on the Main Board of The Stock Exchange of Hong Kong Limited (SEHK) or the MAIN Market of Bursa Malaysia Securities Berhad (Single Submission Arrangement).

The streamlined and coordinated application process may benefit applicants seeking simultaneous primary and secondary listings under the Simplified Dual IPO Listing Framework. The framework adopts a single submission model, under which all required application materials are submitted through the regulator of the primary listing. It also provides for a coordinated review process, including a single channel for regulatory comments and applicants’ responses arising from reviews conducted by the relevant authorities.

Submission Guidance

The table below outlines the application, prospectus and submission requirements applicable to each scenario.

	Primary listing: Hong Kong¹; Secondary listing: Malaysia	Primary listing: Malaysia; Secondary listing: Hong Kong²
Single Application Submission
Application materials	Applicant submits to SEHK: Full application materials required by SEHK; and Full application materials required by SC and the additional information as set out in Appendix III.	Applicant submits to the SC: Full application materials required by the SC; and Full application materials required by SEHK.
Application materials	Note: The submission package should be structured in two separate clearly identified parts: SEHK application materials; and SC application materials. Should the same application materials / documents be required in both parts, references can be made to the relevant materials / documents in the other part of the submission.
Other matters relating to the Application	Type of listing Applicants should specify in the submissions to the authorities whether the listing is: Hong Kong Primary / Malaysia Secondary; or Malaysia Primary / Hong Kong Secondary. Guidance for Hong Kong-licensed sponsor The sponsor should submit information regarding the applicant’s principal activities when it files the sponsor engagement notification to SEHK. Authorisation for primary listing authority to file documents with secondary listing authority In its submission, an applicant should include an authorisation permitting the primary listing authority to file with the secondary listing authority all materials and documents submitted relating to the application, including those submitted by its advisors and agents on its behalf, and an acknowledgement that both the primary listing authority and the secondary listing authority will have access to such materials and documents. Application for relief / waiver from compliance with guidelines or listing requirements Applications for relief / waiver, if applicable, are to be submitted as part of application materials. Document format Applicants are reminded that documents submitted should be in text searchable PDF format.
Prospectus	Single prospectus submitted to SEHK, incorporating the requirements by the SC.	Single prospectus submitted to SC, incorporating requirements by SEHK.
Submitting party	SFC-licensed sponsor Application for secondary listing in Malaysia to be signed by a recognised principal adviser or an SFC-licensed sponsor³	Recognised principal adviser Application for secondary listing in Hong Kong to be signed by an SFC-licensed sponsor
Regulatory queries and applicant’s responses	Single set of regulatory queries issued by: SEHK Responses to queries to be submitted to: SEHK	Single set of regulatory queries issued by: SC Responses to queries to be submitted to: SC
Listing and quotation application to Bursa Malaysia	Applicant must comply with the applicable provisions of the MAIN Market Listing Requirements relating to a secondary listing. Applicant concurrently submits its listing application⁴ and supporting documents for the listing and quotation of its shares on the MAIN Market as part of SC Application Materials to SEHK.	Applicant must comply with the applicable provisions of the MAIN Market Listing Requirements relating to a primary listing. Applicant concurrently submits its listing application and supporting documents for the listing and quotation of its shares on the MAIN Market to SC.
Reporting Accountant (“RA”)	For a listing in Malaysia, the RA must be registered with the Audit Oversight Board (AOB) of the SC. If a foreign audit firm is appointed to become the RA, such foreign audit firm will be required to apply for recognition by the AOB. Please refer to the website of AOB for further information on Recognition of Audit Firms and Individual Auditors. It is advisable to start the process at least three months before the date of submission of the IPO application. For a listing in Hong Kong, the RA must be independent of the issuer to the same extent as required of an auditor under the Companies Ordinance (Cap. 622) and must comply with the independence requirements issued by Hong Kong Institute of Certified Public Accountants or International Federation of Accountants. An applicant must normally appoint a firm that is a Registered PIE Auditor and is not prohibited from acting under the Accounting and Financial Reporting Council Ordinance (Cap. 588)⁵.
Prospectus exposure	Coordination on exposure and registration of draft prospectus The applicant should coordinate the timing of the exposure of the draft prospectus or updated prospectus, as applicable, and the registration of the prospectus in the respective jurisdictions. The applicant should discuss the proposed timetable with both authorities at an early stage and keep them informed of any subsequent changes.

Applicants and their Recognised Principal Advisers or sponsors are encouraged to consult the SC, SFC of Hong Kong or the SEHK, as appropriate, before formally submitting a listing application to discuss the proposed transaction structure and indicative timeline. In particular, an applicant proposing a dual primary listing in Malaysia and Hong Kong may consult the relevant authorities at an early stage regarding the potential application under the Single Submission Arrangement.

The SC’s dedicated team may be contacted at [email protected], while the SFC’s dedicated team may be contacted at [email protected].

Other reference materials

For information relating to simultaneous primary and secondary listings in Malaysia and Hong Kong, applicants should refer to Circular issued by the SFC of Hong Kong, together with related guidance materials available on the SC website and the SEHK website, including:

For a primary listing in Hong Kong, an overseas issuer must be incorporated in a jurisdiction that is included on HKEX's List of Overseas Jurisdictions of Incorporation.
For a secondary listing in Hong Kong, the applicant must be a public company incorporated in Malaysia that is subject of an application for listing on the Main Market of Bursa Malaysia.
Refers to an SFC-licensed sponsor that has affiliates within the same group who are either recognised principal adviser or a holder of a Capital Markets Services Licence to carry on the regulated activity of advising on corporate finance in Malaysia, and is allowed by the SC to sign applications submitted to the SC.
Please refer to item 3 in Appendix III of the Guidance for Listing of Hong Kong Companies on the MAIN Market of Bursa Malaysia Securities Berhad.
If the applicant intends to appoint an overseas audit firm as its reporting accountant, please refer to Chapter 2.1 of SEHK’s Guide for New Listing Applicants. Information on the registration of Hong Kong auditors as PIE auditors and the recognition of non-Hong Kong auditors as PIE auditors can be found on the website of the Accounting and Financial Reporting Council.