Sidley Regulatory Insights for Listed Issuers and Licensed Corporations — 2025 Enforcement Priorities, Developments and Trends

2025’s Year of the Snake is shaping up to be another year of major developments in the regulatory space for listed issuers and licensed corporations, and it is critical for directors, licensed persons, and governance professionals to keep abreast of these developments and take steps to ensure compliance with regulatory requirements and expectations. In this client update, we provide an overview of some key regulatory developments that listed issuers and licensed corporations should anticipate and be aware of for the coming year. These include various regulatory proposals, measures, and changes that will come into force this year and a number of ongoing disciplinary actions and enforcement proceedings being undertaken by the Hong Kong regulators for which decisions may be rendered in the course of 2025. Listed issuers and licensed corporations should have regard to these developments as they may have significant implications for their ongoing business operations.

Upcoming Regulatory Developments and Trends

1. Implementation of enhancements to the Corporate Governance Code

Following the release of the Stock Exchange of Hong Kong Limited’s (HKEX) consultation conclusions for the review of the Corporate Governance Code (CG Code) and related Listing Rules, amendments to the CG Code and relevant Listing Rule provisions have been finalized and are set to take effect on July 1, 2025. The amendments target board effectiveness, board independence, diversity, risk management and internal controls, and capital management, with an overall aim to uphold the standard of corporate governance by listed issuers. Key amendments include but are not limited to the following:

• Lead INED: It is a new recommended best practice for listed issues to designate an independent non-executive director (INED) as a “lead INED” to facilitate communication among the INEDs, within the Board, and with shareholders.
• Directors’ training: First-time directors are required to attend at least 24 hours of training within the first 18 months of their appointment. An exception to this rule is if the relevant first-time director has had directorship experience on foreign exchanges, in which case the training requirement would be reduced to 18 hours. Existing directors are also required to attend annual mandatory training on topics stipulated by the HKEX.
• Long-serving INEDs: Listed issuers are to phase out any long-serving INEDs with over a nine-year tenure (Long-Serving INEDs) during the HKEX’s transition period. By the listed issuer’s 2029 Annual General Meeting (AGM), a majority of INEDs on an issuer’s board must not be Long-Serving INEDs. By the listed issuer’s 2032 AGM, there must not be any Long-Serving INED on the listed issuer’s board.
• Risk management and internal controls review: A listed issuer shall conduct a review of its risk management and internal control systems at least annually and make enhanced disclosure of the relevant review and findings.

In view of these additional requirements, listed issuers should look to strengthen the level of communication among board members and facilitate the independent oversight offered by the INEDs so as to bolster the issuer’s regulatory compliance and risk management. It should also ensure that annual compliance assessments are conducted to confirm that internal control and risk management systems are operating as intended and the necessary training for directors and staff have been carried out.

Corporate governance has been and will remain one of the key areas of focus for the regulators. In particular, we anticipate the Hong Kong regulators to continue their efforts in monitoring INEDs’ work and ensuring compliance and fulfilment of their duties and responsibilities. For more details regarding regulators’ expectation for INEDs and INEDs’ roles and responsibilities, please refer to our previous article.

2. An enhanced regime for climate-related disclosures for listed issuers

Hong Kong regulators have voiced their support for the global initiative for sustainable finance and been facilitating Hong Kong’s development as a leading hub for sustainable finance. Following the publication of the strategic framework for green finance in September 2018, the Securities and Futures Commission (SFC) established the Green and Sustainable Finance Cross-Agency Steering Group (CASG) (comprising various other local authorities and regulators including the Hong Kong Monetary Authority and the HKEX) in May 2020 (later joined by the Accounting and Financial Reporting Council (AFRC) in January 2024) to coordinate efforts on the growth of green and sustainable finance in line with the Hong Kong government’s climate strategies.

In January 2024, following the agenda for green and sustainable finance issued in August 2022, the SFC specifically listed “leading financial market transformation through technology and ESG,” that is, environmental, social, and governance (ESG), as one of its four strategic priorities in capital market regulation when it published its three-year strategic plan, detailing its commitment to steer the local development of corporate sustainability disclosures standards and deter greenwashing (which in essence refers to misrepresentations about an entity’s green credentials). Most recently, on February 6, 2025, the CASG affirmed that its priority for 2025 will be to foster the growth of sustainable finance, including the development of a comprehensive sustainability disclosure ecosystem in Hong Kong (see the SFC’s news and HKMA’s press release both dated February 6, 2025).

Further, the latest version of Hong Kong’s sustainability disclosures regime for listed issuers is captured in the Environmental, Social and Governance Reporting Code (ESG Code). The ESG Code provides for an enhanced regime for listed issuers’ climate-related disclosures effective from January 1, 2025, and has been added as a new Part D to Appendix C2 of the Listing Rules. Under this regime, in addition to the various existing obligations that require reporting on various aspects in the ESG reports either on a mandatory or “comply or explain” basis (which mandates the provision of considered reasons if no disclosure is made), listed issuers must also do the following:

(i) Starting January 1, 2025, make disclosures of their absolute gross greenhouse gas emissions generated during the reporting period that are classified as Scope 1 and Scope 2 in their ESG report in accordance with the new requirements; and

(ii) Comply with the other new climate-related disclosure requirements as set out in Part D of the ESG Code in phases, which are for now on a “comply or explain” basis for Main Board issuers. Starting from January 1, 2026, they will specifically become mandatory for “LargeCap” issuers who are Hang Seng Composite LargeCap Index constituents throughout the year immediately prior to the reporting year in question. These requirements remain on a voluntary basis for GEM issuers.

The new requirements concern disclosures in terms of governance; information for investors to understand the climate-related risks and opportunities that might influence the issuer’s business; strategy in response and decision-making concerning climate-related targets; qualitative and quantitative information about the current and anticipated financial effect of climate-related risks and opportunities; the climate resilience of the issuer’s approach; climate-related risk management; emissions level; and certain other specified measures for assessing the issuer’s climate-related performance in terms of governance, policies, and targets.

In late 2024, the HKEX and the AFRC respectively reviewed listed issuers’ ESG disclosures under the then reporting regime and their sustainability reporting and assurance practices (see the HKEX’s 2024 Analysis of ESG Practice Disclosure dated November 25, 2024 and the AFRC’s report on the market readiness for sustainability reporting and assurance in Hong Kong dated January 27, 2025). Notably, the HKEX found an over 91% compliance rate among the 2,489 issuers reviewed (except in terms of labor standards, which were met with only an 80% compliance rate). Meanwhile, the AFRC found that among the 798 listed entities that responded to its survey, there was a variety of approaches to delegating the responsibility for oversight of sustainability reporting, including either to audit committees, a specially appointed board committee called a sustainability committee, the chief executive officer, chief financial officer, or a chief sustainability officer. The AFRC also noted some challenges for issuers in preparing the ESG reports, including insufficient human resources or expertise and the constantly evolving regulatory requirements and standards.

Aside from the ESG Code, listed issuers and their governance professionals should also familiarize themselves with HKEX’s Implementation Guidance for Climate Disclosures under HKEX ESG reporting framework. Where needed, they should consult professional advisers regarding the requirements and recommended practices and obtain guidance on the approach to ensure compliance with the Listing Rules, failing which there may be adverse enforcement consequences from the regulators. Below are some key recommendations:

• Ensure accurate climate-related disclosures: Ensure the issuer is equipped with an updated governance structure and appropriate personnel with relevant expertise for ensuring sufficient and accurate climate-related disclosures.
• Mitigating the risk of greenwashing: While complying with the new disclosure requirements is important, it is equally important to ensure that there are no greenwashing statements that render the disclosures false or misleading. Apart from HKEX investigations and disciplinary actions on a breach of the Listing Rules, other regulators may undertake parallel investigations and enforcement actions (e.g., the SFC could investigate and sanction the listed issuer and its directors for disclosure-related misconduct pursuant to the Securities and Futures Ordinance (Cap 571) (SFO). The SFC may also potentially invoke its statutory power under Section 213 of the SFO to seek a range of orders from the Hong Kong Court against the listed issuer and/or the directors, including compensation and restoration orders.
• Directors’ accountability: Directors, whether an executive director or INED, cannot disclaim liability for greenwashing disclosures as they bear individual and collective duties toward the issuer. Directors should therefore ensure they participate in, and are properly informed of, the issuer’s key decisions concerning ESG and climate-related disclosures to the public and consider a review of the internal controls concerning ESG reporting. This is to verify that any statements made about the issuer’s ESG standards or green credentials can be properly substantiated. If necessary, they should also consider engaging sustainability assurance services.

3. HKEX’s guidance on long suspension and delisting

In November 2024, the HKEX published a new guidance letter “Guidance on investigations conducted by long suspended issuers” (GL120-24) to assist issuers whose shares have been suspended and for which resumption of trading is subject to fulfilment of certain resumption conditions or guidance. The guidance clearly sets out directors’ obligations and responsibilities in these circumstances, with a view to achieving resumption of trading as soon as practicable for the issuer to maintain its listing status.

As mentioned in the guidance letter, among other things, some of the key expectations of the HKEX on directors include the following:

• Preservation of evidence and provision of assistance in the investigation: All potentially relevant evidence shall be preserved and made readily available to the investigator. Directors should identify and ensure any potentially relevant evidence is not tampered with or lost. They should also assist the investigation by allowing the investigator all reasonable access to the electronic devices, documents and records that may be relevant.
• Independence of investigation: Any internal investigation to be conducted should be handled independently and supervised by an independent committee. To ensure this independence, members of the independent committee shall not have been involved in the relevant transaction or event subject to investigation (i.e., typically INEDs) and should not seek advice from the same legal representatives as the issuer or other connected persons or persons involved in the relevant irregularities.
• Cooperation: While the independent committee is primarily in charge of conducting the investigation, all directors should nonetheless procure the issuer and its personnel to assist the independent committee and facilitate the investigation.

Furthermore, the HKEX also updated its “Guidance on long suspension and delisting” (GL95-18). The HKEX set out in this guidance letter the operation of the delisting framework under the Listing Rules, issuers’ general obligations and the HKEX’s regulatory actions during the resumption process, and guidance specific to certain types of suspension cases. The HKEX will not accept Covid-19 as a valid reason for extending the remedial period.

In the post-pandemic era, regulators expect listed issuers to proactively comply with the relevant regulatory requirements in a timely fashion. The HKEX has adopted a streamlined approach to delist issuers that have failed to achieve resumption before the expiry of the Remedial Period. Past court cases, where former listed issuers have attempted to challenge the delisting decisions of the HKEX, have also shown that there is no realistic prospect of success. Suspended issuers should therefore focus on formulating a cogent resumption plan to resolve any outstanding issues as soon as practicable.

4. Continued enforcement focus to combat corporate misconduct, disclosure failures, financial reporting, and market misconduct

We observed that the regulators have remained very active in pursuing enforcement and disciplinary actions against both listed issuers and their directors in Hong Kong. Based on the SFC’s statistics, in the quarter ended September 30, 2024 alone, there were 468 ongoing investigations; of the active cases, most concerned intermediary misconduct (180 cases), market manipulation (85 cases), and corporate misgovernance (73 cases). It is anticipated that the regulators’ enforcement priorities to target stock market manipulation, disclosure failures, corporate fraud, and other misconduct will continue in 2025.

Some of the cases that the regulators have been pursuing:

• HKEX disciplinary actions: In January 2025 alone, the HKEX has already taken disciplinary actions against two listed issuers and their former directors in respect of Listing Rules breaches and the former directors’ breaches of their directors’ duties in managing the issuers’ affairs.
  • On January 9, 2025, the HKEX took disciplinary action against Regal Partners Holdings Limited and three of its former executive directors (click here and here for the HKEX’s two Statements of Disciplinary Action) in respect of a guarantee provided by the issuer’s subsidiary for the private benefit of one of these directors.
  • On January 16, 2025, the HKEX took disciplinary action against a listed company and its former directors in respect of the Listing Rules breaches and the directors’ breaches of their directors duties in connection with the issuer’s misapplication of initial public offering proceeds and losses resulted from certain lending arrangements. The SFC is in parallel progressing its civil proceedings against the same issuer, its former directors and subsidiaries under Section 214 of the SFO in connection with those corporate misconduct activities, seeking orders for disqualification and compensation as well as an order to appoint an external auditor to review and prepare a report on the issuer’s internal control procedures.
  • On February 11, 2025, the HKEX similarly took disciplinary action against two former executive directors of Pa Shun International Holdings Limited for their breach of directors’ duties in respect of their failure to exercise reasonable skill, care, and diligence to protect the issuer’s interest and identify and monitor the risks in two acquisitions.

• SFC prosecution of ramp-and-dump activities: The SFC is progressing the criminal prosecution of nineteen individual defendants suspected to be involved in large-scale ramp-and-dump activities using shares of three listed issuers, as revealed following the SFC and Hong Kong Police’s joint investigations. This is a continuation of the regulators’ ongoing efforts to combat stock market manipulation and fraud perpetrated by criminal syndicates operating the ramp-and-dump schemes.
• SFC market misconduct cases: In 2024, the SFC actively pursued enforcement against market misconduct and commenced three proceedings at the Market Misconduct Tribunal (MMT), seeking determinations and enforcement orders in relation to the conduct of insider dealing, false trading, price rigging, and stock market manipulation that it identified involving listed issuers as well as listed issuers’ breach of the requirement to disclose inside information under Part XIVA of the SFO. The SFC also concluded three other cases before the MMT in 2024 concerning insider dealing, false trading, and disclosure of false or misleading information inducing transactions. We expect the SFC will continue to proactively pursue cases of market misconduct, including before the MMT, involving the following listed issuers:
  • Asiasec Properties Limited concerning the insider dealing conduct on the part of the listed issuer’s company secretary, her relative, a driver serving a person connected to the listed issuer through a contemplated acquisition of shares in the listed issuer, and the driver’s wife. The SFC has already secured a decision against the driver and his wife with cold-shoulder orders, cease-and-desist orders, and costs orders made against them by the MMT on January 7, 2025. The proceedings against the company secretary and her relative remain ongoing.
  • China Investment Fund Company Limited and Smartac Group China Holdings Limited both in respect of a scheme of false trading, price rigging, and stock market manipulation through a series of matched trades and other trading activities performed by the chairman, non-executive director, and substantial shareholder of a company holding a substantial number of shares in the listed issuer (and his affiliated parties). The two proceedings were consolidated by the MMT into one consolidated proceedings, which is scheduled to be heard in May 2025.
  • Dickson Concepts (International) Limited, a case of insider dealing and breach of disclosure requirements on the part of the listed issuer, its executive directors, and an affiliated investment holding company. The case is scheduled to be heard in December 2025.

• AFRC disciplinary actions: The AFRC has similarly remained active in the past year, taking disciplinary actions against misconduct in the accounting profession arising from audit failures related to listed issuers. Among the four disciplinary cases published by the AFRC in 2024, two were against Public Interest Entity Auditors and their personnel’s breaches of auditing standards in the audits of listed issuers. In 2024, we have witnessed the AFRC impose a series of sanctions for various audit-related breaches and non-compliances for the first time, and it is expected that in 2025 the AFRC will continue to explore the powers within its arsenal to deter misconduct. We also anticipate that the AFRC will continue with its close engagement and cooperation with the SFC, HKEX, and other enforcement agencies to target cases of mutual interest.

5. SFC’s thematic review of cybersecurity of licensed corporations

In February 2025, the SFC published the Report on the 2023/24 Thematic Cybersecurity Review of Licensed Corporations (Cybersecurity Report), further to its examination of licensed corporations’ compliance with the Guidelines for Reducing and Mitigation Hacking Risks Associated with Internet Trading (Cybersecurity Guidelines). While the Cybersecurity Guidelines do not have the force of law, a failure to comply with the principles contained therein may reflect adversely on the fitness and properness of the licensed person.

Overall, the SFC observed an improvement in licensed corporations’ compliance with the relevant cybersecurity regulatory requirements. However, from 2021 through 2024, there were nevertheless eight reported material cybersecurity incidents that caused significant business disruptions or hacking of client accounts. Some non-compliance instances discovered by the SFC during its review concerned matters including, but not limited to, two-factor authentication for system login, security control configurations of the system servers, and firewall and encryption of sensitive data.

Licensed corporations are reminded to pay attention to the security loopholes, control deficiencies, and non-compliance instances identified in the SFC’s review and ensure compliance with the relevant guidelines and requirements to maximize security for their online trading platform. In the Cybersecurity Report, the SFC forecast that it will conduct a more comprehensive review of the existing cybersecurity regulatory requirements and standards and develop an industrywide framework to provide guidance to licensed corporations for managing cybersecurity risks. Licensed corporations should stay alert of any updates and enhancements to the regulatory framework, comply with the regulatory requirements and beware of any potential cybersecurity risks, take steps to protect the security of its trading platform, and avoid becoming victims of phishing and other hacking activities.

6. Increased cooperation between regulatory and enforcement authorities

As observed from a number of enforcement cases in recent years, Hong Kong regulators and enforcement agencies, including the SFC, HKEX, AFRC, and ICAC, have been strengthening their collaboration to maximize the use of their respective investigative powers and enhance the deterrence effect of their enforcement efforts. In more serious cases, joint operations are carried out by different regulators together as part of a fact-finding exercise. For example, it was reported in the AFRC’s Annual Report 2023-2024 that it had conducted a tripartite operation with the ICAC and SFC in 2023 to pursue suspected misconduct and corporate fraud involving listed issuers (also see the SFC news on October 19, 2023) and it also signed a memorandum of understanding with the HKMA dated August 17, 2023, committing to collaborative arrangements like referrals and exchange of intelligence to maximize the two regulators’ efforts in upholding the quality of financial reporting, auditing, and the accounting professionals’ work related to the banking sector. In the upcoming year, it is expected that the regulators will continue to join hands in enforcement actions, especially high-profile cases, to effectively tackle financial crimes.

Hong Kong regulators have also had frequent meetings with organizations and regulators from other jurisdictions to enhance cross-border collaboration. For instance, in the second half of 2024 alone, the SFC has had meetings with, inter alia, the Ministry of Finance (PRC MoF), Governor of the People’s Bank of China, China Securities Regulatory Commission, and National Financial Regulatory Administration of the PRC. At these meetings, the regulators discussed how cross-border securities crimes and misconduct may be tackled effectively and explored ways to strengthen cross-border regulatory cooperation with a view to achieving higher efficiency and comprehensive outcomes. Similarly, the AFRC reported on its success in December 2023 in obtaining audit working papers located in the PRC through the Bureau of Supervision and Evaluation of PRC MoF for the AFRC’s inspection and investigation (see the AFRC’s Annual Report 2023-2024 and the AFRC press release dated December 15, 2023). This regulatory collaboration with the PRC MoF had also contributed to the detection of contravention of Mainland laws and regulations by a Hong Kong audit firm (see the AFRC press statement dated August 2, 2024). In February 2025, the SFC attended the three-day regional committee meetings of the International Organization of Securities Commissions and met with Asia-Pacific securities regulators and other financial authorities and senior regulators from Europe and Asia Pacific (including the State Securities Commission of Vietnam and Financial Stability, Financial Services, and Capital Markets Union) to discuss a coordinated regional approach to tackle scams and online harm, techniques to detect and investigate investment frauds, supervisory cooperation, crypto regulation, and capital market issues of common interest as well as the latest developments in financial supervision and regulation for digitalization, fintech, and sustainable finance. Given the regulators’ priorities to protect Hong Kong’s status as an international financial hub and to uphold the integrity of its markets, it is anticipated that the regulators will continue to work closely with regulators from other jurisdictions and among themselves to utilize their respective capabilities and authority and facilitate effective enforcement outcomes.

7. Potential updates to the HKEX regulatory approach following the SFC’s 2024 Review of the HKEX’s performance on regulation of listing matters

In December 2024, the SFC completed its review of the performance of the HKEX in its regulation of listing matters during 2022 and 2023 and published its findings in a report. Among other things, the SFC specifically focused on the supervision and compliance performance regarding disclosure of material information.

In the review period, there were nearly 400 non-compliance cases involving non-disclosure of material information, most commonly related to notifiable or connected transactions. The SFC suggested that the HKEX review its existing policy and system for regulating these types of Listing Rule breaches and impose meaningful sanctions to deter future breaches. The SFC also recommended imposing a requirement for the listed issuer to issue an announcement regarding its Listing Rule breach and to draw up a remedial plan, against which the listed issuer will need to report on implementation progress at appropriate time intervals.

Furthermore, the SFC specifically recommended that in cases where listed issuers have repeatedly committed regulatory breaches, blatantly disregarded Listing Rule requirements, or otherwise demonstrated bad faith or gross negligence, the HKEX should impose more stringent disciplinary sanctions on the relevant parties. Overall, we anticipate that the HKEX will adopt a potentially more stringent and assertive regulatory approach to deter misconduct by listed issuers and directors.

8. HKEX’s Report of Review of Issuers’ Annual Reports, Guide on Preparation of Annual Report and listed issuers’ lending practices

In December 2024, the HKEX completed and published the findings of its review of listed issuers’ annual report, addressing key compliance issues regarding disclosure requirements under the Listing Rules and accounting standards in issuers’ financial statements. Accompanying its Report of Review of Issuers’ Annual Reports (HKEX Review Report), the HKEX published a new Guide on Preparation of Annual Report (Guide), summarizing the key disclosure rules and reminding issuers of HKEX’s expectations for disclosure in their annual reports. For details regarding the HKEX Review Report and the Guide, please refer to our previous article.

From the HKEX’s report, areas of regulatory interest this year include (i) problematic cases and disclosures of material lending transactions, (ii) disclosures in the “management discussion and analysis section” by issuers (including newly listed issuers), and (iii) reasons leading to modified audit opinions in issuers’ financial statements and disclosure concerning the modifications. In particular, issuers’ lending practices have come under close scrutiny from a number of regulators in recent years. This is evident from the repeated references to regulatory and compliance issues regarding lending arrangements in regulatory publications such as the HKEX’s April 2024 edition of its Enforcement Bulletin (see the discussion in our article dated May 3, 2024) as well as the Joint Statement by the SFC and AFRC on the common failures of issuers and auditors in relation to internal controls and scrutiny over loan arrangements.

With the clear guidance given in the HKEX Review Report and the Guide, the HKEX expects listed issuers and directors to stay mindful of their overall disclosure obligations and relevant responsibilities when preparing the listed issuers’ annual reports and disclosures and ensure the listed issuers fully comply with the relevant regulatory requirements.

Conclusion

 In conclusion, there are a number of significant regulatory updates and developments that are anticipated in 2025, and they reflect a renewed push by Hong Kong regulators to further enhance the corporate governance framework, expand disclosure requirements to better inform investor decision-making, and adopt more forceful enforcement efforts to deter misconduct and encourage greater compliance by listed issuers and directors. In particular, listed issuers and directors should be mindful of the following.

• Corporate governance: the practical implications of the enhancements to the CG Code and how these may affect the issuer’s approach to internal governance, including with respect to INED appointments and annual assessments on risk management and internal controls.
• ESG disclosure requirements: the additional requirements for climate-related disclosures and their potential impact on annual financial reporting and corporate announcements, including an increased burden for verifying factual accuracy and the need to ensure that any disclosed information is not partial truth or may otherwise be regarded as false or misleading.
• Delisting regime: the stringent approach adopted by the HKEX under its suspension and delisting regime, and the need for a suspended issuer to take urgent and proactive steps to comply with all of the resumption conditions and guidance, including items that may require some time to resolve (e.g., the resolution of audit issues and the publication of outstanding annual reports), well before the expiration of the Remedial Period.
• Lending arrangements: disclosure requirements and regulatory expectations regarding lending arrangements, which will undoubtedly continue to feature as a major enforcement priority for regulators in the coming year; all stakeholders should pay attention to their regulatory duties and responsibilities, and comply with the relevant rules and obligations, to avoid non-compliance and regulatory investigations.
• Enforcement trend: the various enforcement priorities that the regulators continue to focus on, including corporate misfeasance, disclosure failures and market misconduct, and whether any of their activities may trigger an investigation or potential enforcement action arising from a breach of the Listing Rules or other regulatory requirements; the prospect of parallel investigations being commenced by multiple regulators on related regulatory issues, which may substantively increase the costs and time burden for resolving regulatory inquiries and investigations.
• Collaboration between regulators: the increased level of regulatory cooperation and information sharing among Hong Kong’s regulators and enforcement agencies, as well as with regulators from other jurisdictions, which further enhances their effectiveness and ability to determine disciplinary outcomes more readily based on the available pool of evidence collectively gathered.

Licensed corporations are likewise reminded to observe the Cybersecurity Guidelines and the observations arising from the Cybersecurity Report to ensure that their security measures are sufficiently up to date to prevent cybersecurity incidents, business disruptions, and the potential for significant reputation loss arising from mishandling of client information and data.

The new regulatory changes in 2025 will introduce additional elements of compliance to the already complex regulatory landscape, which will necessitate additional training for directors and staff and updates to internal policies and procedures. Listed issuers, directors, and licensed corporations are therefore recommended to take proper steps and devote sufficient resources to enhance their compliance readiness while staying well-informed about the latest changes to the applicable regulatory requirements.