What governs pre-deal research distribution, jurisdiction by jurisdiction.
Plain-English summaries of the rules on when pre-deal research can be published, who may receive it and how long records must be kept. Every statement names its instrument and links to the primary source.
The rules at a glance
| Jurisdiction | When research can go out | How long records must be kept |
|---|---|---|
| India | A manager or co-manager must not publish research for 40 days after an IPO is priced, or 10 days after an FPO is priced (Research Analysts Regulations 2014, Reg. 18). There is no post-listing blackout in ICDR. Nothing outside the offer document may go to any group of investors or to a research analyst (ICDR Sch. IX(10)). | Merchant-banker records: 8 financial years (Merchant Bankers Reg. 16(1)). Insider-information database: 8 years (PIT Reg. 3(6)). Research-analyst records: 5 years (RA Reg. 25(2)). |
| United States | Regulation S: no selling effort aimed at the US. Under the SEC’s 1998 guidance, a website is not treated as aimed at the US if it names the countries it is meant for, excludes the US, and has procedures to prevent sales to US persons. Whether a waiting period applies depends on the offering’s Rule 902 category: none for Category 1, up to one year for Category 3. FINRA Rule 2241: a manager or co-manager must observe a quiet period of at least 10 days after an IPO and at least 3 days after a secondary offering. | Not stated. We have not verified the retention periods in SEC Rule 17a-4(e). |
| United Kingdom | Research must not be disseminated until the approved prospectus or registration document has been published under PRM 9.5 (COBS 11A.1.4F). The 7-day wait was removed on 5 August 2026 (PS26/16). | At least 5 years (SYSC 9.1.2R). The FCA may require up to 7 under the onshored MiFID Organisational Regulation. |
| European Union | No fixed waiting period at EU level. Research must be correctly labelled as research or as a marketing communication, with conflicts controls (Del. Reg. (EU) 2017/565 Arts. 36–37). A recommendation must carry the content and disclosures in MAR Art. 20 and Del. Reg. 2016/958. | 5 years; up to 7 if the regulator requests (MiFID II Art. 16(7) with 2017/565 Art. 76(8)) |
| Hong Kong | A manager, sponsor, listing agent or underwriter must not issue research for 40 days after an IPO is priced, or 10 days after a secondary offering is priced (SFC Code para. 16.5(g)). There is no pre-listing quiet period in the Code. | Not set in paragraph 16. Not yet verified elsewhere, so we quote none |
| Singapore | Not summarised. The commonly quoted Singapore rule rests on a secondary source: we could not confirm that SFA 2001 s.251(9) exists, and as reported it is a deadline to distribute before lodgement, not a blackout. We will summarise it once the section has been read in full. SFA 2001 | |
India — SEBI
Four sets of SEBI rules, and the DPDP Act, shape pre-deal research in India. ICDR bars giving any group of investors, or a research analyst, information that is not in the offer document. The Research Analysts Regulations set how long a syndicate bank must wait before publishing after pricing. The insider-trading rules require a record of who received unpublished price-sensitive information. Since 3 January 2026, a merchant banker must keep records for eight financial years and keep all data inside India.
United States
A research report promoting an issuer during a deal can itself count as an offer under US securities law. Regulation S takes an offering outside US registration if it is offshore and nothing is aimed at the US market. Rule 144A is a separate route for resales to qualified institutional buyers. For a bank managing an offering, FINRA Rule 2241 sets quiet periods after it, and Regulation AC requires an analyst certification on each report.
United Kingdom
From 5 August 2026 the FCA removed the seven-day wait between publication of the approved prospectus or registration document and the release of connected research, and dropped the requirement to give unconnected analysts the same information. One timing rule remains: research cannot go out until the relevant document is published. Any extra waiting period a bank applies is now its own policy, not law.
European Union
Two sets of EU rules apply. Delegated Regulation (EU) 2017/565 Articles 36 and 37 decide whether a document counts as investment research or a marketing communication, and set the conflict-of-interest controls. MAR Article 20, with Delegated Regulation 2016/958, sets what a recommendation must contain and disclose.
Hong Kong
No. The SFC Code of Conduct has no quiet period before listing; the SFC considered one in 2011 and decided against it. The waiting periods that do exist start after pricing, at paragraph 16.5(g): 40 days after an IPO and 10 days after a secondary offering.
Which waiting periods are law, and which are market practice?
Some waiting periods are set by regulation. Others are habits the market follows. The difference matters when a compliance officer is asked why research was held back.
Set by regulation
India: 40 days after IPO pricing and 10 days after FPO pricing, for a manager or co-manager (SEBI RA Regulations, Reg. 18). United States: at least 10 days after an IPO and 3 after a secondary offering, for a manager or co-manager (FINRA Rule 2241). Hong Kong: 40 days after IPO pricing and 10 after a secondary offering (SFC Code para. 16.5(g)).
Market practice, not law
Hong Kong: the 14 days after a pre-deal research report is issued. United Kingdom: any wait after the prospectus is published, since PS26/16 removed the seven-day rule on 5 August 2026.
Widely quoted, but does not exist
A research blackout after an Indian IPO lists (not in SEBI ICDR). A quiet period before a Hong Kong listing (the SFC declined to create one in 2011). A 15-day FINRA quiet period around lock-up expiry (removed in 2015).
Common questions about these rules
Do the waiting periods run from listing or from pricing?
Mostly from pricing, in India and Hong Kong. In India, a manager or co-manager waits 40 days after an IPO is priced and 10 days after an FPO is priced (SEBI Research Analysts Regulations, Reg. 18); an Indian IPO underwriter's 25 days run from the date of the offering instead. In Hong Kong the same 40 and 10 days run from pricing under SFC Code para. 16.5(g). In the UK the trigger is an event, not a day count: research cannot go out until the approved prospectus or registration document is published (COBS 11A.1.4F).
Why is there no Singapore page?
Because we could not confirm the commonly quoted Singapore pre-deal research rule against a primary MAS or legislative source, including whether SFA 2001 s.251(9) exists. As reported, the rule is a deadline to distribute before lodgement, the mirror image of the blackout it is usually described as. We will publish a Singapore page once the section has been read in full.
How often do these rules change?
On set dates. FCA PS26/16 took effect on 5 August 2026, SEBI's ICDR consolidated text was last amended on 21 March 2026, and EU Directive 2024/2811 began to apply on 6 June 2026. Each page shows when it was last reviewed.
Is any of this legal advice?
No. These pages summarise what each regulation says. They do not tell your firm what its own obligations are. Every figure names the instrument and provision it comes from, so your counsel can check it in one step.
Last reviewed 5 October 2026
Walk your compliance team through these rules with us.
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