Major Update on HKEx Listings: Technology Enterprises Channel and Confidential Filing Options

Written By

david cheng Module
David Cheng

Partner
China

I am a partner in our Corporate group based in Hong Kong where I have broad corporate practice spanning equity capital market, debt capital market and public and private M&A.

philip chui module
Philip Chui

Associate
China

I am a corporate and capital markets lawyer in the corporate group of Bird & Bird resident in Hong Kong, with extensive experience working in the London office.

Introduction

In May 2025, the Securities and Futures Commission (“SFC”) and The Stock Exchange of Hong Kong Limited (“HKEx”) announced the launch of the Technology Enterprises Channel (“TECH”), designed to streamline the listing process for Specialist Technology Companies and Biotech Companies under Chapter 18C and Chapter 18A of the Main Board Listing Rules (“Listing Rules”), respectively.

TECH

TECH offers additional support to eligible companies, including a specialised team with expertise in reviewing Chapter 18A and 18C applications dedicated to providing preliminary guidance on sector-specific issues early on before submitting a formal application, including:

  • requirements for the “Core Product”, i.e. the biotech product, process or technology forming the basis of a Biotech Company’s listing application under Chapter 18A of the Listing Rules;
  • recognition of biotech products or clinical trials under different regulatory regimes;
  • the qualifications necessary for the “Sophisticated Investor”, i.e. an investor from which the applicant must have secured a meaningful investment at least six months before listing under Chapter 18A of the Listing Rules; and
  • acceptable sectors for Specialist Technology Industries, for applicants seeking to list under Chapter 18C of the Listing Rules, as well as acceptable new sectors or industries outside the current scope.

Early guidance helps applicants under TECH to align their listing documents with regulatory requirements before formal submission.

Confidential Filing Option

To assist Specialist Technology and Biotech Companies in mitigating the risks of premature disclosure of sensitive information such as proprietary technologies and operational strategies, HKEx will permit such companies to submit their listing application confidentially. This is particularly important for companies in early-stage development given their heightened vulnerability compared to other industries. However, an announcement will still have to be published in accordance with Listing Rules on the same day of the publication of the Post Hearing Information Pack (the near-final prospectus that a listing applicant must submit), upholding the transparency expected of public listings. Such confidentiality measures can be crucial for high-value R&D efforts, where early exposure might compromise patient data in biotech or patent applications in technology hardware.

Streamlined Weighted Voting Rights

The HKEx also clarified that Specialist Technology and Biotech Companies meeting the requirements under Chapters 18C or 18A of the Listing Rules are presumed to have satisfied the i) Innovative Company Requirements and the ii) external validation requirement (typically satisfied through pre-IPO investments by Sophisticated Investors) for the purposes of Chapter 8A. In line with global conventions for high-growth firms, such presumptions ease the process for applicants seeking to adopt weighted voting (or dual-class) share structures, enabling founders to secure long-term strategic direction over the company even after it is publicly listed.

Conclusion

With further measures to enhance market competitiveness, reduce regulatory uncertainty and expedite IPO timelines, the launch of TECH bolsters Hong Kong's status as a leading listing hub for high-growth, innovative companies, whilst still maintaining robust investor safeguards.

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