AIM Express Market route: a faster route to London for international companies

For international companies considering a secondary listing in London, the new AIM Express Market route could provide a faster and more streamlined path to market. Introduced as part of the updated AIM Rules for Companies, the route is designed to reduce the documentation, timetable and duplication traditionally associated with admission to AIM. This article explains which companies may qualify, how the process works and the potential opportunities it offers.

What is it?

As a part of the new regime that came into force on 5 August 2026, the Express Market route replaces the former AIM Designated Market route (ADM route), which continues to be available on a transitional basis until 5 February 2027. The Express Market route is intended to make AIM more accessible to companies already trading on established public markets, whether overseas or on other UK markets such as the Aquis Stock Exchange (AQSE). These established markets are defined as “express markets” in the AIM Rules 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)

For qualifying international companies, the Express Market route is intended to materially reduce the documentation, timetable and duplication traditionally associated with obtaining a secondary admission on AIM. LSE has made the concept of an ‘Express Market’ significantly broader than the former ADM route framework, as IOSCO membership is almost universal among securities regulators and has over 200 members across three categories. The list of qualifying Express Markets is expansive when compared to the shorter list of qualifying markets under the former ADM route.

Who can use the AIM Express Market route?

For a company already traded on certain established public markets, it can qualify as an express applicant if it satisfies a number of pre-conditions. As mentioned above, companies must meet the definition of “express market” provided in the AIM Rules and should engage advisers early on to discuss whether their home market will be eligible for the Express Market route.

If an international company is traded on an eligible market, they must then meet the following requirements:

have had its securities traded on an eligible Express Market for at least three years immediately before its application;
have undergone no fundamental change to its business and/or board during the preceding 12 months;
have an anticipated market capitalisation of at least £20 million on admission to AIM; and
have the relevant home market admission documentation and required disclosures published in English and available on their website.

As with any AIM admission, the applicant is also required to appoint, and retain, a nominated adviser (Nomad) and a broker.

What are the requirements for Admission to trading

Under the new Express Market route, LSE has looked at what can be done to simplify or streamline the admission process and in doing so the AIM Rules now allow for simplified processes for qualifying companies looking for a second listing on AIM.

Admission Document

One of the most significant benefits of the new regime is the potential to dispense with a separate AIM admission document. However, this only to Company’s who meet certain criteria.

The ability to dispense with a separate AIM admission document requires the applicant’s securities to:

(i) already be admitted to an Express Market which also qualifies as a “specified market” for FCA purposes; and
(ii) the securities being admitted to AIM are of the same class as those already traded on that market, the company may not be required to prepare a separate AIM admission document.

This distinction is important because an Express Market and an FCA specified market are not necessarily the same thing. FCA specified markets are a subset of express markets and include UK regulated markets, EU regulated markets, SME growth markets, recognised overseas investment exchanges (ROIEs) such as ASX, NASDAQ, SIX Swiss Exchange, the Stock Exchange of Hong Kong and Singapore Exchange, and third country markets considered equivalent to UK regulated markets under UK European Market Infrastructure. While there are a lot of express markets that are also specified markets, there can be instances where a company may qualify for the Express Market route but still need to produce an admission document if its express market is not a specified market or the class of securities to be traded differ.

Where the admission document exemption is not available, an express applicant must instead prepare a simplified AIM admission document. The content of this simplified admission document must satisfy the necessary information test under regulation 23 of the Public Offers and Admissions to Trading Regulations 2024 (POATR). While simplified, this document is not subject to a lower disclosure standard than a regular AIM admission document, though the disclosures are reduced in scope compared with a conventional AIM admission document.

Reduced or specific legal and financial due diligence

The new regime is intended to recognise that an established international public company may have already undergone substantial regulatory scrutiny and thus reduce duplication of disclosures when applying for a second listing on AIM.

Under the AIM Rules for Nominated Advisers, Nomads are given discretion to take the company’s existing public market history into account when determining the scope of due diligence required, rather than simply replicating the exercise that might be undertaken on a conventional IPO. The Nomad will take a reasonable level of assurance and places reasonable reliance on the express applicant having been traded on an express market and therefore being subject to regulatory public market obligations and scrutiny.

A shorter admission timetable

These reforms are looking to significantly shorten the admission timetable for qualifying express applicants. In addition to the reduced documentation discussed above, an express applicant can provide the relevant Schedule One information to the LSE only three business days before its expected admission to AIM compared to the previous timetable of 10 days.

This represents a substantial reduction compared with the timetable under the former AIM Designated Market route.

Express applicants also benefit from an exemption from the mandatory lock-in requirements contained in AIM Rule 7 – again reducing potential documentation

Taken together, the reduced timetable, potentially lighter admission documentation and modified due diligence process these reforms could represent short and more efficient admission timetable, which may also reduce the admission costs as well.

Fundraising by express applicants

An express applicant can also undertake a fundraising at AIM admission. An express applicant can make a public offer of transferable securities where that offer is conditional on admission of the securities to trading on AIM, without the need for an FCA-approved prospectus or an AIM admission document. The paragraph 6, Schedule 1 exception to the public offer prohibition under POATR is not contingent on an MTF admission prospectus being published.

Therefore, it is possible for express applicants, who are not required to produced any AIM admission document, to still make a public offer, potentially enhancing the attractiveness of a secondary AIM listing.

The new Dual Market Applicant route

The reforms also introduced a separate Dual Market Applicant route.

This is aimed at companies seeking admission to AIM and an overseas Express Market at broadly the same time, rather than companies that already have the three-year public-market track record required for the Express Market route.

A qualifying dual-market applicant may be able to use the disclosure document prepared for admission to the overseas market as the basis for its AIM admission documentation, supplemented by the AIM specific information required under the rules.

If the applicant is an investing company, it must raise at least £6 million in cash via an independent equity fundraising on or immediately before admission.

This route may be particularly relevant and of interest to international businesses planning a dual-market IPO from the outset and seeking access to both London and another major market.

What should companies do next?

International companies considering an AIM admission should engage with advisers early on in the process. As there are various potential benefits to this new regime, that should make it easier for international companies to seek a second listing on AIM, but key is ascertaining whether potential applicants will meet the relevant eligibility criteria that would allow them to dispense with a separate admission document and to reduce their pre-admission due diligence. As these benefits could present very real cost benefits for applicants allowing them to more easily gain access to the market and deep pools of capital in London.

In particular, international companies need to consider and discuss with their advisers:

whether their existing overseas market qualifies as an Express Market;
whether that market also is an FCA specified market;
whether the securities being admitted to AIM are of the same class as those already traded on their home market ;
how the company’s existing governance disclosure arrangements compare with AIM requirements; and
whether any corporate, regulatory or transaction-specific matters need to be addressed before admission.
whether the company has had its securities traded on the express market for the requisite three-year period;
the adequacy of settlement arrangements for the company’s securities, including whether depositary interests may be required for overseas issuers; and
whether any fundraising is planned at AIM admission.

In short, the AIM Express Market route presents an exciting opportunity for the appropriate international issuers to explore options to seek a London listing.

How can we help?

Blake Morgan is a full-service national law firm with offices in London, Cardiff, Oxford, Reading, Southampton and Manchester. Our Equity Capital Markets team is experienced in advising clients with matters relating to UK equity capital markets. If you would like to discuss anything in this article, or need any further guidance, please contact Blake Morgan’s Equity Capital Markets team.

This article provides general information it does not constitute legal or regulatory advice and should not be relied upon as such. Specific advice should be obtained based on your circumstances.