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ACGA’s response to the HKEX’s consultation paper on Listing Framework Competitiveness Review

On 11 May 2026, ACGA submitted its response to the Hong Kong Exchange's consultation paper Listing Framework Competitiveness Review (13 March 2026) — the first stage of HKEX's review of its listing framework competitiveness, and the most significant proposed changes to the WVR framework since its introduction in 2018.

The proposals represent a multi-directional expansion of WVR eligibility: financial thresholds reduced, the voting ratio cap raised, the minimum economic interest lowered, and suitability criteria broadened — without a commensurate strengthening of safeguards. We view this as not compatible with the fair and equal treatment of shareholders and risks eroding global investor confidence in Hong Kong's corporate governance standards.

To enhance safeguards for WVR issuers, we call for:

• A seven-year sunset clause on WVR structures 
• INEDs appointed and removed exclusively by non-WVR shareholders 
• A firm requirement of appointing Lead Independent Director for WVR issuers 

Please click here to view ACGA's full response.