ACGA Open Letter: Prioritization of Annual Reports before AGMs and alignment of record dates closer to AGMs

On 19 March 2025, ACGA released an open letter recommending changes on the disclosures time of Yuho.

Following the public letter that we sent to regulators in Japan on 17th October 2024 providing feedback from our members on regulatory issues, we understand that the Financial Services Agency (FSA) has formed a Council to prioritize Yukashoken Hokokusho report (Yuho report in short, Japanese term for an "Annual Securities Report")  to be issued before Annual General Meetings (AGMs). However, the Council Secretariat's December 20 materials suggest a targeted approach to relaxing rules for a select group of progressive companies, rather than implementing uniform changes across the entire market.  

The Asian Corporate Governance Association (ACGA) and its undersigned members would like to follow-up on the issue of releasing Yuho reports before AGMs and on the alignment of record dates closer to AGMs. We strongly encourage these changes on the timing of Yuho disclosures in relation to AGMs and realignment of record dates should apply to all companies, with a transition period of three years or less for Tokyo Stock Exchange (TSE) Prime- and Standard Market listed companies, and a longer transition period of possibly up to five years for other companies. Merely allowing progressive firms to voluntarily adopt changes without mandating universal compliance would lead to limited adoption, a missed opportunity for reform and potential market confusion. 

ACGA Open Letter