Is there a quiet period before a Hong Kong IPO?
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.
| When research can go out | How long records must be kept |
|---|---|
| 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 |
What do the Hong Kong rules say, and where does each come from?
SFC Code of Conduct para. 16.5(g): the waiting periods that exist
A firm acting as manager, sponsor, listing agent or underwriter must not issue research on the issuer for 40 days after an IPO is priced, or 10 days after a secondary offering is priced. Two exceptions apply: the firm already publishes research on the issuer with reasonable regularity, or a major public event occurs. These rules are in 16.5(g), not 16.2, which contains only definitions. SFC Code of Conduct
There is no 14-day pre-listing blackout
The SFC considered requiring a pre-listing quiet period in 2011 and expressly declined. The "14 days" often quoted in the market is voluntary practice that runs after a pre-deal report is issued, not a rule before a filing. A desk that follows it does so as firm policy, not law. SFC consultation conclusion 10CP5
Paras. 16.5(d), 16.7(b), 16.11(c): information barriers
Firms must have policies that stop an analyst writing on a new listing applicant from receiving information that is not expected to appear in the prospectus.
Retention: no number stated
Paragraph 16 sets no retention period, and we have not verified one in another SFC rule or the Securities and Futures Ordinance. We will not quote a Hong Kong retention period until we have.
Not legal advice. Every figure above carries the instrument and provision it comes from, and links to the primary source; where we could not verify one, the text says so rather than guessing. Confirm your own obligations with your counsel or compliance team.
Last reviewed 5 October 2026
How Hong Kong compares with other jurisdictions
| 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 | |
Common questions about the Hong Kong rules
Is there a 14-day SFC blackout before a filing?
No. The SFC Code of Conduct has no pre-listing quiet period. The SFC considered one in 2011 and expressly declined (consultation conclusion 10CP5). The 14 days sometimes quoted is voluntary market practice, and it runs after a pre-deal research report is issued, not before a filing. The waiting periods in the Code are 40 days after an IPO is priced and 10 days after a secondary offering is priced, at paragraph 16.5(g).
Who does the 40-day rule apply to?
A firm acting as manager, sponsor, listing agent or underwriter on the offering. It does not apply where the firm already publishes research on the issuer with reasonable regularity, or where a major public event occurs.
Bring this page to your compliance team, and us with it.
We will take a session with legal or compliance alone if that is more useful than a product demo. Most desks do both.