HKEx returned several listing applications in 2019 due to the omission of financial information as required by Listing Rule 4.04(1), pursuant to which a main board listing applicant should include in the accountants’ report its consolidated results for each of the three financial years (or two financial years in the case of a biotech company) before the issue of the listing document. HKEx will normally use the proposed listing date indicated in the A1 filing to determine the corresponding track record period that should be covered in the accountants’ report in the final prospectus. HKEx may, however, accept an application proof with an accountants’ report covering a shorter period depending on when the listing application is filed, provided that certain conditions are satisfied.
Assuming the most recent financial year ended on December 31, 2020, and the intended listing date is on or after April 1, 2021, the final prospectus should at least cover the three financial years ended December 31, 2020. For the purpose of the application proof:
- If the listing application is filed before the end of the most recent financial year (i.e., before December 31, 2020), the application will be returned if the submission only includes results for two full years and an appropriate stub period because the applicant has yet to complete the last full financial year of its track record period.
- If the listing application is filed between January 1, 2021, and February 29, 2021, the applicant can include an accountants’ report with a shorter period (i.e., the two financial years ended December 31, 2019, and the nine months ended September 30, 2020) in the application proof, with the final prospectus to be updated with the complete accountants’ report covering the three years ended December 31, 2020.
If a listing applicant expects to be listed within three months after the end of the most recent financial year of its track record period, it may omit the full financial information for its most recent financial year if it applies for and obtains a waiver from strict compliance with Listing Rule 4.04(1). The application proof should include an accountants’ report covering the three financial years ended December 31, 2018, and at least the six months ended June 30, 2019.