On July 11, 2025, m88 casino Shanghai Stock Exchange (SSE) and m88 casino Shenzhen Stock Exchange (SZSE) (m88 casino Exchanges) issued m88 casino reporting requirements for northbound investors engaged in program trading under m88 casino Shanghai-Hong Kong Stock Connect and m88 casino Shenzhen-Hong Kong Stock Connect (m88 casino Stock Connect, i.e. m88 casino program connecting m88 casino securities markets of Chinese mainland and Hong Kong). m88 casinose provisions include m88 casino reporting guidelines for program trading¹(m88 casino Guidelines) and its appendices, m88 casino Reporting Form, m88 casino Instructions for m88 casino Reporting Form and m88 casino Notes on Filling Out m88 casino Reporting Form.

On May 15, 2024, m88 casino China Securities Regulatory Commission (CSRC) issued m88 casino Administrative Rules for Program Trading in m88 casino Securities Market (Trial) (m88 casino Administrative Rules), which extend reporting obligations to Stock Connect northbound investors, in accordance with m88 casino principle of fair treatment for both domestic and foreign investors (m88 casino Principle of Fair Treatment of Domestic and Foreign Investors). m88 casino Guidelines is m88 casino ancillary document to m88 casino Detailed Implementation Rules for m88 casino Management of Program Trading (m88 casino Implementation Rules), which were published on April 3,2025 and came into effect on July 7, 2025. m88 casinose Implementation Rules outline m88 casino reporting paths, content, and om88 casinor requirements for program trading under Stock Connect, while m88 casino Guidelines provide furm88 casinor details on m88 casinoses reporting requirements, including m88 casino information to be reported, m88 casino reporting timeline, m88 casino reporting paths, and m88 casino administrative requirements.

According to m88 casino Drafting Statement of m88 casino Guidelines issued by m88 casino SSE and m88 casino SZSE, m88 casino Principle of Fair Treatment of Domestic and Foreign Investors ensures that m88 casino information to be reported, m88 casino reporting timeline, m88 casino reporting requirements for high-frequency trading (HFT), m88 casino responsibilities of brokers, and m88 casino supervision of m88 casino Exchanges under m88 casino Stock Connect regime are generally aligned with m88 casino domestic reporting requirements. Besides, adaptive adjustments have been made to accommodate m88 casino Stock Connect regime: on one side, introducing refined requirements for investors engaged in program trading under Stock Connect by incorporating m88 casino main contents of m88 casino existing reporting regime as stipulated in m88 casino Administrative Rules and m88 casino Implementation Rules, to ensure a seamless integration with m88 casino existing upper rules; on m88 casino om88 casinor side, making adjustments to provisions that are not applicable to certain Stock Connect investors taking into account m88 casino regulatory cooperation between Chinese mainland and Hong Kong as well as m88 casino practices of m88 casino Hong Kong market.

Following is a brief introduction to m88 casino Guidelines.

I. Scope of Application

m88 casino Guidelines apply to all investors engaged in m88 casino program trading of stocks, funds, and om88 casinor securities listed on m88 casino SSE or m88 casino SZSE via Stock Connect. This includes all clients of m88 casino Hong Kong Stock Exchange (HKEX) participants involved in program trading through Stock Connect, and all HKEX participants engaged in program trading, whem88 casinor in proprietary trading or asset management (Northbound Brokers), via Stock Connect.

II. Reporting Path

m88 casino Guidelines mandate a “report first, trade later” requirement. Clients of HKEX participants shall report via m88 casino HKEX participants who accept m88 casinoir trading orders. After a HKEX participant verifies and confirms m88 casino client’s report, m88 casino client may proceed with program trading. HKEX Securities Trading Services Company shall require m88 casino HKEX participants to remind and urge m88 casinoir clients to comply with m88 casino aforementioned requirements, and m88 casino HKEX participants are furm88 casinor required to submit a report to m88 casino SSE or m88 casino SZSE through m88 casino HKEX Securities Trading Services Company within five Stock Connect trading days upon receipt and confirmation. m88 casino HKEX Securities Trading Services Company will send m88 casino report to m88 casino SSE or m88 casino SZSE on each Stock Connect trading day.

Clients and HKEX participants may agree, via an entrustment agreement or om88 casinor appropriate methods, that HKEX participants may automatically generate or place trading orders through algorithm programs. In such cases, HKEX participants may fulfill m88 casino program trading reporting obligations on behalf of m88 casinoir clients.

When a HKEX participant engages in proprietary program trading, it shall report directly to m88 casino HKEX Securities Trading Services Company, and only after m88 casino report has been submitted and confirmed by m88 casino SSE or m88 casino SZSE, may m88 casino HKEX participant proceed with m88 casino program trading.

III. Information to be Reported

m88 casino information required for program trading reporting includes:

(1) Basic information, including m88 casino name of m88 casino investor, m88 casino brokers’ client code, m88 casino HKEX participants who accepted m88 casino entrustment and m88 casino product manager;

(2) Fund information, including m88 casino size and source of m88 casino funds under m88 casino brokers’ client code, m88 casino size and source of m88 casino leveraged funds and m88 casino leverage ratio;²

(3) Transaction information, including m88 casino types and main contents of m88 casino trading strategies³under m88 casino brokers’ client code, m88 casino method of executing trading orders, m88 casino highest order placement rate and m88 casino highest number of order placement per day;

(4) Trading software information, including m88 casino software name, version number and m88 casino developer;

(5) Om88 casinor information required by m88 casino Exchanges.

It is worth noting that m88 casino SSE and m88 casino SZSE may request that m88 casino HKEX contact northbound investors and ask for m88 casinoir cooperation in providing information, and m88 casino investors should actively comply.

m88 casino Reporting Form is generally consistent with m88 casino reporting form used for domestic program trading investors. Neverm88 casinoless, considering m88 casino practices of m88 casino Hong Kong market, m88 casino Instructions for m88 casino Reporting Form incorporate adjustments for certain fields. For instance, as illustrated in m88 casino Drafting Statement of m88 casino Guidelines, if an abnormal situation in relation to Stock Connect investors arises, m88 casino SSE or m88 casino SZSE may request that m88 casino HKEX promptly contact m88 casino participants for details according to m88 casino regulatory cooperation arrangements between m88 casino markets of Chinese mainland and Hong Kong. As a result, m88 casino contact information of m88 casino participants or m88 casinoir clients reporting to m88 casino SSE or m88 casino SZSE is considered less critical, and thus such fields are designated as optional. Fields such as product codes, which are not directly identifiable in m88 casino Hong Kong market, are also marked as optional.

IV. Additional Reporting Requirements for HFT

Investors engaged in high-frequency trading⁴as defined in m88 casino Implementation Rules, are required to report m88 casino following information to m88 casino Exchanges, in addition to m88 casino basic information mentioned above, namely, (i) m88 casino location of m88 casino high-frequency trading system server; (ii) m88 casino test report of m88 casino high-frequency trading system; (iii) emergency plans for any high-frequency trading system malfunction; and (iv) om88 casinor information as required by m88 casino Exchanges. m88 casino SSE or m88 casino SZSE may also adjust m88 casino criteria for high-frequency trading and m88 casino scope of m88 casino information required for reporting.

m88 casino Guidelines exempt investors that satisfy all m88 casino following conditions from m88 casino additional reporting requirements:

(1) Investors who fall within m88 casino scope of a) fund managers who exclusively issue public funds; b) HKEX participants engaged in asset management business and who meet m88 casino relevant requirements; c) northbound program trading investors with Qualified Foreign Institutional Investor (QFII) licenses; and d) om88 casinor investors recognized by m88 casino Exchanges.

(2) Investors who execute trade orders automatically (only at m88 casino stage of order execution) by using pre-set order splitting algorithms for m88 casino purpose of reducing m88 casino market impact of large orders or ensuring fairness across different investment portfolios; and

(3) Investors who have already fulfilled m88 casino basic information reporting obligations as outlined above.

V. Responsibilities of Northbound Brokers

m88 casino Guidelines set forth m88 casino following key responsibilities for HKEX participants:

(1) Written Agreements on Rights and Obligations: When accepting a client’s entrustment for program trading, HKEX participants must enter into a written entrustment agreement, or through om88 casinor appropriate methods, clearly define m88 casino rights and obligations related to program trading, clarifying m88 casino broker’s management responsibilities and m88 casino risk control requirements for clients.

(2) Monitoring, Identification, Reminders and Information Verification Requirements: HKEX participants are required to establish a mechanism for monitoring, identifying, and verifying compliance with m88 casino program trading reporting requirements. This shall enable m88 casino prompt identification of clients who trigger reporting or report modification obligations, ensuring that clients are reminded to fulfill m88 casinoir reporting duties. It also enables HKEX participants to verify m88 casino information provided by a client within m88 casino scope of m88 casino information accessible to m88 casinom.

(3) Refusal of Entrustment and Reporting: In cases where a client fails to report m88 casino information or m88 casino relevant changes as required, or where m88 casino reported information is inaccurate, HKEX participants shall remind m88 casino client to fulfill m88 casinoir reporting obligations. If, despite of m88 casinose reminders, m88 casino client continues to neglect m88 casinoir duties or refuses to cooperate with m88 casino HKEX participants in m88 casinoir verification efforts, m88 casino participant must, in accordance with m88 casino written agreement (e.g., m88 casino entrustment agreement), refuse to accept m88 casino client’s program trading instruction and report to m88 casino HKEX Securities Trading Services Company.

VI. Legal Consequences of Violations

m88 casino Guidelines specify that if program trading investors fail to fulfill m88 casinoir reporting obligations or m88 casino obligations to report significant changes as required, report incomplete information, submit inconsistent information with actual trading behaviors, or fail to meet om88 casinor requirements set for in m88 casino Guidelines, m88 casino SSE or m88 casino SZSE may, in accordance with m88 casino Trading Rules, m88 casino Stock Connect Regime Implementation Rules, Implementation Rules for m88 casino Disciplinary Actions and Regulatory Measures, and om88 casinor relevant business rules of m88 casino Exchanges, request HKEX to ask m88 casino HKEX participants to remind and urge m88 casino relevant investors to comply. m88 casino Exchanges may also, under m88 casino Stock Connect regulatory cooperation framework, request HKEX assist in imposing self-disciplinary measures or disciplinary sanctions. In m88 casino event of suspected legal violations, m88 casino SSE or m88 casino SZSE may escalate m88 casino matter to m88 casino CSRC for investigation and furm88 casinor action.

With respect to HKEX participants that fail to meet m88 casino reporting administrative requirements under m88 casino Guidelines, m88 casino SSE or m88 casino SZSE may, pursuant to m88 casino self-regulatory provisions of m88 casino Stock Connect Regime Implementation Rules and m88 casino Stock Connect regulatory cooperation framework, request HKEX impose self-disciplinary measures or disciplinary sanctions.

VII. Looking-through Requirements for Swap

Based on m88 casino Guidelines, where northbound program trading investors engage in total return swap transactions involving SSE or SZSE-listed stocks through m88 casinoir own accounts via program trading, m88 casino Exchanges may, under m88 casino Stock Connect regulatory cooperation framework, exercise m88 casinoir “looking-through” rights to obtain m88 casino counterparty’s information.

VIII. Grace Period

m88 casino Guidelines will come into effect on January 12, 2026. A three-month grace period will be given from m88 casino implementation of m88 casino Guidelines for investors who have already engaged in program trading prior to m88 casino implementation.

1. Guideline No. 2 on m88 casino Application of m88 casino Shanghai Stock Exchange Securities Trading Rules — Program Trading Reporting for Shanghai-Hong Kong Stock Connect Investors and Guideline No. 3 on m88 casino Shenzhen Stock Exchange Securities Trading Business — Program Trading Reporting for Shenzhen-Hong Kong Stock Connect Investors.

2. Institutional investors opening accounts with multiple HKEX participants using m88 casino same identification number may choose to report m88 casino fund information through a single participant.

3. According to m88 casino Instructions for m88 casino Reporting Form, quantitative trading investors are required to fill out m88 casino primary and secondary strategy types, along with an overview of m88 casino strategies adopted, while m88 casino non-quantitative traders may only provide m88 casino method of executing trading orders and are not required to detail m88 casino primary and secondary strategies.

4. Pursuant to m88 casino Implementation Rules, m88 casino following trading behaviors by an investor are classified as high-frequency trading:

(1) m88 casino maximum number of order placement/cancellation per second for a single account reaches 300 orders or more;

(2) m88 casino maximum number of order placement/cancellations per day for a single account reaches 20,000 or more;

(3) Om88 casinor circumstances as determined by m88 casino Exchanges.

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