Once a prospectus has been approved by the competent authority of one EU member state, it may be ‘passported’ to other EU member states so that the securities in respect of which the EU Prospectus was approved can be offered in those other member states using the same prospectus (subject to complying with any translation requirements). This also means that retail investors across the EU benefit from the same disclosure standards and investor protections.
In the UK, an IPO generally requires the company’s shares to be listed on an approved stock exchange or trading venue (such as a UK regulated market or primary Multilateral Trading Facility). A UK prospectus will need to be prepared for admission of the shares to the relevant market.
In the UK, companies may also use Public Offers Platforms (POPs) rather than on traditional stock exchanges. POPs are online platforms managed by POP operators, authorised by the Financial Conduct Authority (FCA. Each POP operator sets its own rules about what information the company launching the IPO must disclose. When an IPO takes place on a POP, a formal prospectus may not be required, but the POP operator will review the company’s disclosures and information contained in the prospectus filed with the exchange commission in another market, before the offer proceeds and produce a disclosure summary together with any additional information that it might deem appropriate.