Key Takeaways
- Strengthen inventory management: Firms should maintain accurate, real-time visibility over securities holdings to ensure timely access and placement.
- Review settlement chains: Identify weak points across trading, clearing, and settlement workflows.
- Automate manual processes: Reliance on manual intervention increases error and delay risks under compressed timelines.
- Client and counterparty engagement: End-to-end readiness across the settlement chain is critical for success.
- Avoid over-reliance on US experience: UK post-trade arrangements differ significantly from those in the US.
- Address specific challenges: These include same-day securities lending and collateralisation, tighter FX cut-offs for cross-border trades, and potential settlement delays in CREST if matching is not timely. Firms are increasingly conducting detailed T+1 readiness assessments, focusing on automation, system upgrades, and identifying client segments still dependent on manual workflows.
Next Steps
The FCA will continue industry engagement and expects firms to develop and communicate detailed T+1 transition plans, including risk identification and mitigation strategies. Firms should monitor updates via the AST website and the FCA’s T+1 page as the transition progresses toward 2027.
ESMA issues supervisory statement on MiFIR Review application transition regime
ESMA published a supervisory statement on the MiFIR Review application transition regime and updated the Manual on pre- and post-trade transparency under MiFIR/D.
Key Takeaways
Supervisory statement: The statement provides practical guidance on:
- the application of the provisions on commodity derivatives and derivatives on emission allowances, and to the new SI regime;
- the ‘single’ volume cap mechanism;
- the application of the revised transparency rules for bonds, structured finance products, emission allowances, and equity instruments introduced by the MiFIR review; and
- the discontinuation of FITRS in the context of the Double Volume Cap regime.
Manual on pre-trade and post-trade transparency: The updated manual includes new Section 6 on pre-trade transparency for equity instruments and Section 7 on the input/output data reported to/transmitted by the CTP.
Saudi Arabia consults on plans to open stock market to all foreign investors
The Saudi Capital Markets Authority (CMA) has released a draft regulatory framework for public consultation that would allow all non-resident foreign investors to directly invest in shares, debt instruments, and investment funds listed on the Kingdom’s Main Market. This marks a major shift from the previous regime, which limited direct access to certain qualified investors or required indirect participation via swap agreements.
Key Takeaways
- Open Access: Any foreign investor, not just those classified as “Qualified Foreign Investors” (QFIs), would be allowed to invest directly in listed shares.
- Old Rules Repealed: The CMA would remove the QFI system and rules that let foreign investors participate through swap agreements, bringing KSA’s investment framework closer to international standards.
- Ownership Limits Stay:
- A single foreign investor (unless a strategic investor) may not own 10% or more of the shares or convertible debt instruments of any single listed company.
- The total foreign ownership is capped at 49% of the shares or convertible debt instruments of any listed company
These limits are clearly retained in the proposed amendments and apply across both equity and convertible debt securities.
- Rule Changes Across the Board: Multiple CMA rules and definitions would be updated, including those covering investment accounts, depositary receipts, and company governance.
Next Steps: The public consultation is open for 30 calendar days. Final rules will be published after reviewing comments and feedback.
SSC issues new regulation on concurrent IPO and listing reviews
Summary
Vietnam’s State Securities Commission (SSC) has issued a new regulation to streamline the concurrent review of IPO and stock listing applications, aiming to shorten timelines, enhance transparency, and improve capital-raising efficiency in the securities market.
In more detail
The new Coordination Regulation, issued under Decision No. 709/QĐ-UBCK on September 27, 2025, implements Article 111a of Decree No. 155/2020/ND-CP (as amended). It sets out a mechanism for SSC and the Ho Chi Minh City Stock Exchange (HOSE) to jointly review IPO and listing applications, including financial statements, paid-in capital reports, company charters, and other documents. The process allows for information-sharing, written exchanges, and technical meetings, with HOSE commencing its review immediately after SSC grants the IPO registration certificate. This eliminates overlapping procedures, aligns IPO and listing requirements, and strengthens investor protections by ensuring greater consistency and transparency.
Next steps
The SSC expects the regulation to accelerate post-IPO listings, improve the efficiency of capital raising, and enhance the competitiveness of Vietnam’s securities market. Companies pursuing IPOs will benefit from a more streamlined process that prepares them simultaneously for listing requirements, helping to boost investor confidence and support sustainable market development.
