EU and UK Prospectus Regimes: Comparative Table of Key Divergences and Forthcoming Changes (EU Listing Act; UK POATRs and FCA admission rules, 2026)

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Practice notes

STOP PRESS:

Regulation (EU) 2024/2809, part of the EU Listing Act package, was published in the Official Journal of the EU on 14 November 2024 and became effective on 4 December 2024. The measure updates the EU Prospectus Regulation. Certain elements took effect immediately, while others carry lead‑in periods of 15 or 18 months—specifically from 5 March 2026 and 5 June 2026, respectively. Transitional rules permit, until their expiry, prospectuses approved up to 18 months after 4 December 2024 to remain governed by the EU Prospectus Regulation as it stood at the point of approval. For more information, see: The EU Prospectus Regulation—essentials. UK—The UK’s prospectus framework is presently grounded in the EU Prospectus Regulation, retained in domestic law post‑Brexit as the UK Prospectus Regulation. The UK has been reassessing its regime as part of broader initiatives to reform UK capital markets and improve the UK’s appeal as a listing venue. In this context, the UK Prospectus Regulation will be replaced by the Public Offers and Admission to Trading Regulations 2024 (the POATRs), with all detailed...

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Web page updated on 21/05/2026

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