Establish scope before applying listed-company rules
As checked on 7 November 2026, we reviewed Rules 3.09F, 3.09G and 3.09H in the current Main Board rules PDF linked by the Main Board directory, together with HKEX's director-training explanation. This is not a new policy announced today or a company's listing update.
The discussion concerns issuers to which these Main Board rules apply, not every private startup. Rule 19C.11 separately excludes these training provisions for an overseas issuer with, or seeking, a secondary listing. Special structures, appointments and transitional circumstances require their own checks. Teams preparing for listing can develop records early, but training does not replace listing eligibility, director suitability or other governance obligations.
Maintain two related training records
Rule 3.09F requires each director to receive continuous professional development in every issuer financial year. Rule 3.09G specifies at least five topic areas. There is no uniform minimum annual hours requirement, but this is not permission to undertake no training. HKEX emphasises sufficient quality and learning appropriate to the director's duties.
Rule 3.09H adds minimum hours for first-time directors. The definition includes both people with no previous Main Board or GEM directorship and people who have not held such a directorship within the previous three years. The general minimum is 24 hours within 18 months of appointment. For a first-time director who served on another exchange's listed issuer board within the preceding three years, the applicable minimum is 12 hours, not zero. Read this with the FAQ's commencement and transitional explanations.
| Question | General annual training | First-time minimum hours |
|---|---|---|
| Time basis | Each issuer financial year | Eighteen months from the applicable starting point |
| Hours | No uniform minimum, but sufficient quality and coverage required | At least 24 or 12 hours for the applicable category |
| Topics | At least the five specified areas | Relevant CPD still requires a topic check |
| Record focus | Training actually completed and topic coverage that year | Classification, starting point, completed and remaining hours |
| Common mistake | No minimum means no learning required | Overseas board experience means complete exemption |
This table is our editorial summary, not a substitute for the rules or a calculation of an individual's deadline.
A pre-listing appointment needs more than its contract date
The Directors FAQ, updated February 2026, currently linked from HKEX's governance directory, explains the transition in question 4. General training applies from financial years commencing on or after 1 July 2025. First-time requirements also depend on appointment and listing timing. For directors appointed before the issuer's listing, the 18 months runs from listing. For issuers listed on or after 1 July 2025, first-time directors appointed before that date are also subject to the first-time requirement.
An early appointment contract is therefore not, by itself, an exemption. Nor should every pre-IPO director's period be counted from joining the private company. Question 6 separately addresses reappointment within three years and gaps exceeding three years. Resignation does not simply erase unfinished training. The company secretary and qualified advisers should reconcile the complete service history and formal dates; we do not decide an individual's treatment.
Check topic coverage rather than collecting certificates
The five areas concern board, committee and director responsibilities and effectiveness; Hong Kong legal and Listing Rule obligations and developments; governance and ESG; risk management and internal controls; and industry, business trends and strategies relevant to the issuer. A technology conference may inform industry understanding without covering legal duties or internal controls.
The currently linked April 2026 Corporate Governance Guide allows different modes, including internal training, external training and self-study, without prescribing a universal provider. Training for another professional body or overseas directorship still needs the topic and Hong Kong-specific requirements checked; its name is not enough. The guide explains rather than changes the Listing Rules, which prevail in a conflict.
Create records that can support a real review
Our suggested register records each director's category and supporting rationale, issuer financial year, course or materials, actual dates, mode, duration, provider, topics and supporting evidence. Where one activity spans several topics, explain the allocation rather than adding the same period repeatedly to manufacture hours.
The guide and FAQ also address disclosure and retention of details, including hours, mode, topics and first-time completion or remaining balances. Records should support actual reporting, not a reconstruction from guesses before the annual report. Flexible self-study does not justify invented reading time, and registration alone is not completion. During the relevant period, suitable training may satisfy both general and first-time requirements; that does not mean counting the same elapsed time twice in the total.
Founders can connect governance preparation with financing work by identifying directors' roles, previous appointments and learning responsibilities early. Training progress is not a countdown to an accepted application or listing. Our guide to formal sponsor appointment and listing preparation covers a separate obligation.
The scope of a Jimhang Capital discussion
Jimhang Capital, founded by Justin Zhan, publicly describes connecting founders with Greater Bay Area supply-chain resources. Teams can send a non-confidential description of their business stage and coordination question to justin@jimscapital.cn to discuss possible connections. Support is scoped separately.
This article does not represent Jimhang as an HKEX-approved training provider, licensed sponsor or legal adviser, or claim that reading it earns qualifying training hours. The company and appropriate professionals must check individual training recognition, disclosure and listing matters. No listing or investment return is guaranteed.
Editorial analysis as of 7 November 2026, limited to the checked current materials. Not an individual training determination, official course or exhaustive listing-compliance opinion.