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AIM’s New Express Market Route Opens the Door for Canadian Mining and Resources Companies

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Overview

Capital Markets Bulletin

The new AIM Express Market route, introduced on 5 August 2026, offers overseas companies admitted to an Express Market, including the TSX, TSXV and the Canadian Securities Exchange (CSE), a more cost-efficient and streamlined path onto AIM. It replaces the former AIM Designated Market regime that was intended to provide a fast-track route to AIM for companies listed on select overseas markets, but which in practice was often as rigorous and time consuming as a traditional IPO.

The AIM Express Market rules recognise the disclosure history and scrutiny already applied by an express applicant’s home market, resulting in a more proportionate AIM admission process that avoids unnecessarily duplicating work already undertaken in their home market. The new approach is intended to create a more credible and internationally competitive route for established overseas companies that wish to access London’s capital markets and is one aspect of a generally more permissive regime under the new AIM Rules for Companies (AIM Rules) published in August 2026.

Eligibility

To qualify as an “express applicant” the issuer must satisfy the following four tests:

  1. its securities must have been traded upon an Express Market (including the TSX, TSXV and CSE - see below) for at least 3 years immediately prior to applying to have those securities admitted to AIM;
  2. there must have been no fundamental change to either its business or its board in the preceding 12 months;
  3. it must expect a market capitalisation of at least £20 million on admission to AIM; and
  4. any relevant admission documentation and all disclosure required under the rules of its home market must be published in English.

It should be noted however that even if these tests are all satisfied, the Express Market route is not a form of automatic passporting onto AIM. The applicant will still need to satisfy a nominated adviser that it is an appropriate company for admission to AIM.

Express Market

The range of eligible Express Markets has been expanded from the previous AIM Designated Market regime, which was limited to the top tier “main board” markets of the designated exchanges. This creates an opportunity for AIM to attract a far wider range of overseas companies.

An “Express Market” is defined as any regularly operating open market for the trading of equity securities that is regulated by, or operated under the oversight of, a regulatory body or entity which is a member of the International Organisation of Securities Commissions (IOSCO).

The TSXV’s oversight by the British Columbia Securities Commission, and the TSX’s oversight by the Ontario Securities Commission, both IOSCO members, qualifies both the TSXV and TSX as Express Markets. CSE is also recognised by the Ontario Securities Commission and is an Express Market. Other Express Markets include markets in Japan, Singapore and Hong Kong, as well as the ASX, NYSE and Nasdaq.

Documentation

Express applicants must still submit a draft Schedule One announcement to the London Stock Exchange (LSE), but only 3 clear business days before admission rather than 20 clear business days under the previous rules. The applicant however will remain subject to due diligence by the nominated adviser and other advisers and so the overall admission timetable will in practice be longer.

The Schedule One announcement must now include supplementary information, including details of the applicant’s Express Market, confirmation of compliance with its home market’s legal and regulatory requirements, details of any material breach in the last 5 years, confirmation of no significant change in its financial or trading position since its last financial period end, and a website address for its latest full year accounts (and 6-month interim accounts if its year end was more than 9 months before admission).

No admission document is required to be published by the express applicant if:

  1. its home market is a “specified market” as defined in the Financial Conduct Authority (FCA) Handbook; and
  2. the shares to be admitted to AIM are of the same class as those traded on its home market.

If these tests are not satisfied the applicant must publish a short form admission document containing the AIM “buyer beware” wording and the information required under regulation 23 of the Public Offers and Admissions to Trading Regulations 2024, being the information necessary for investors to make an informed assessment of the applicant, its prospects and its securities.

As the TSX, TSXV and CSE are all specified markets, no admission document will be required where the same class of shares is admitted.

No Working Capital Confirmation or Lock-ins

Express applicants are no longer required to confirm the sufficiency of their working capital for 12 months from admission, and are exempt from the rule 7 lock-in requirements, under which related parties and applicable employees of issuers within the scope of rule 7 must not dispose of their shares for 12 months after admission. These exemptions are particularly helpful for pre-revenue exploration companies.

Dual Market Applicants

The new AIM Rules also allow companies to seek admission to AIM concurrently with admission to an Express Market, provided the Express Market admission document meets the short form admission document requirements in Schedule Two, Part Two of the AIM Rules and the company raises at least £6 million (or equivalent) of equity on IPO.

This may streamline the admission process to both markets for unlisted companies, although the admission timetables, disclosure standards, accounting requirements, settlement arrangements and continuing obligations of both markets will need to be carefully aligned.

AIM Admission and Continuing Obligations

Like any AIM company, each express applicant must retain a nominated adviser and broker at all times. The nominated adviser will still conduct due diligence, although it may take account of the issuer’s existing public-market record, and must be satisfied that the directors understand the AIM Rules and their disclosure obligations before giving its declaration to the LSE that the applicant is suitable for admission.

Express applicants will also become subject to the UK Market Abuse Regulation (UK MAR), including obligations to disclose inside information promptly, maintain insider lists and notify dealings by directors and senior managers. Issuers listed on the TSX, TSXV or CSE should align their UK MAR and disclosure procedures required under Canadian securities laws and stock exchange rules and release announcements simultaneously in both markets.

Audited annual accounts must be published within 6 months of the financial year end and may be prepared under Canadian GAAP.

Settlement

As Canadian shares cannot be settled directly in CREST, express applicants typically establish a depositary interest facility, allowing their shares to be traded and settled electronically in the UK and moved between the Canadian and UK registers.

Reporting Standards

Mining and oil and gas express applicants will be subject to the AIM Note for Mining and Oil & Gas Companies (MOG Note), which explicitly contemplates the use of Canadian Institute of Mining, Metallurgy and Petroleum (CIM) reporting standards for both mineral resources and reserves and Oil & Gas resources and reserves.

Where a short form admission document is required (which will not be the case for TSX, TSXV or CSE traded companies if they are admitting shares in the same class - see above), it must include a competent person’s report, although applicants should discuss with their nominated adviser whether a suitably updated existing technical report can be used or a derogation is available.

Canadian Mining and Resources Companies

For many Canadian resources companies, London offers a deep pool of specialist mining and natural resources investors, including institutions that may not invest actively in Canada. Admission to AIM can be particularly attractive for companies with international assets or growth ambitions. By reducing the cost and complexity of accessing that market, the new AIM rules make London a much more compelling second-market option for established Canadian mining and resources companies.

Contact the Authors

For more information or to discuss a particular matter, please contact us.

Contact the Authors

Authors

  • Leon Miller, Partner | Capital Markets, London, +44 (0)20 7917 8699, [email protected]
  • Jodi Katz, Partner | Managing Partner, London, London, +44 (0)20 7917 8579, [email protected]
  • Guy Winter, Partner | Capital Markets, London, +44 (0)20 7917 8535, [email protected]
  • Malgorzata Janiec, Associate | Mergers & Acquisitions, London, +44 (0)07 7883 0783, [email protected]
  • Stephen Vincelli, Associate | Corporate/Commercial, London, +44 (0)20 7917 8516, [email protected]
  • Lucinda Patrick-Patel, Senior Associate | Corporate/Commercial, London, +44 (0)20 7917 8553, [email protected]
Leon Miller, Partner | Capital Markets Leon Miller Partner | Capital Markets London +44 (0)20 7917 8699
Jodi Katz, Partner | Managing Partner, London Jodi Katz Partner | Managing Partner, London London +44 (0)20 7917 8579
Guy Winter Guy Winter Partner | Capital Markets London +44 (0)20 7917 8535
Malgorzata Janiec, Associate | Mergers & Acquisitions Malgorzata Janiec Associate | Mergers & Acquisitions London +44 (0)07 7883 0783
Stephen Vincelli, Associate | Corporate/Commercial Stephen Vincelli Associate | Corporate/Commercial London +44 (0)20 7917 8516
Lucinda Patrick-Patel, Senior Associate | Corporate/Commercial Lucinda Patrick-Patel Senior Associate | Corporate/Commercial London +44 (0)20 7917 8553