The Introduction of Aquis Support Services – 19 January 2026

What is “Aquis Support Services” and why the change?

In September 2025, Aquis Stock Exchange launched a consultation on the introduction of "Aquis Support Services" - an alternative to the current retained Corporate Adviser regulatory model for Issuers on the Access and Apex segments of Aquis (together the Aquis Growth Market). The consultation also sought views on whether eligibility criteria for Issuers admitted to the Aquis Growth Market should be met on an ongoing basis as opposed to only on admission.

Under the existing framework, Issuers admitted to the Aquis Growth Market are required to retain a Corporate Adviser at all times. Aquis queried in its consultation (at the request of some of its Issuers) whether the scope and the responsibilities (and the associated costs) remain appropriate for all Issuers, noting that some may not require the full range of services typically offered post-admission. “Aquis Support Services” is therefore an alternative model by which Issuers can elect to pay an annual fee to Aquis to receive direct advice from an Aquis approved law-firm (with whom the Issuer will enter an engagement letter directly) in certain circumstances. For example, a participant could use an Aquis approved law-firm to review regulatory announcements, in relation to any request for suspension, restoration or withdrawal of the Issuer’s securities, or admission of new securities of the same class already admitted to trading. Issuers will still be required to appoint a Corporate Adviser in relation to an IPO, a transaction which could amount to a reverse takeover and where it appears that there has been, or may be, a breach of the rulebooks by an Issuer.

Aquis received responses from a wide range of stakeholders, including Issuers, Corporate Advisers, law firms (including Charles Russell Speechlys), non-executive directors, and market makers. Issuers broadly welcomed the additional choice and potential cost savings. However, respondents also raised important concerns.

What’s new?

A summary of the key changes to be implemented by Aquis following the consultation is set out below. These changes are effective from 19 January 2026.

Introduction of Support Services as an alternative to Corporate Advisers

Issuers may now elect to either retain a Corporate Adviser on an ongoing basis or utilise Aquis Support Services. This is an either/or requirement, on an ongoing basis.

Panel of law firms to form the Aquis Support Services

Aquis will ultimately establish a panel of law firms from which Issuers can select their support services provider (following a pilot period with a single firm and a competitive tender process for the appointment of panellist firms).

Scope of Support Services

Services will include (amongst other things) guidance on Aquis rulebooks, liaison with Aquis Regulation and review of regulatory announcements. Aquis have stressed that the relationship between the support services law firm and the Issuer will be ongoing and continuous and that the engagement letter between a law firm and Issuer will embed requirements for disclosure and reporting of important information and events by the Issuer, mirroring current arrangements with Corporate Advisers.

Panel law firm duties

Panel law firms will have duties and responsibilities to Aquis similar to those of Corporate Advisers, and firms that fail to perform will be removed from the panel.

Mandatory Corporate Adviser engagement

An Issuer must appoint a Corporate Adviser when publishing an admission document or prospectus, when entering a potential reverse takeover, or when required by Aquis due to a potential breach of rules.

Continuous eligibility requirement

Eligibility criteria are to apply on an ongoing basis, not just at admission, to ensure Issuers remain suitable for a public market.

Ongoing compliance monitoring

Aquis will monitor ongoing compliance with eligibility criteria including minimum market capitalisation and free float requirements over a period (akin to how Apex Issuers are currently assessed biannually to determine if they still meet Apex’s eligibility requirements).

Consultation feedback – how this may play out…

Several themes emerged during the consultation.

First, there was a strong preference for Issuer choice. Rather than being assigned a single law firm, respondents wanted participants to select from a panel of approved providers. Aquis has confirmed that it will establish a panel of legal firms (following a pilot period with a single firm) which should ensure quality and cost efficiency.

Concerns were also raised about the risk that the Aquis Support Services model could result in more reactive, event-driven engagement with Issuers, with the onus on Issuers to get in touch with a law firm (Corporate Advisers typically have proactive oversight over Issuers). In our response, we noted the potential difficulties in share price monitoring, timely disclosure, website compliance, and corporate governance oversight if it’s the preserve of the Issuer to initiate contact with lawyers. Aquis has emphasised in its response that the Issuer-law firm relationship should be ongoing and continuous and said that the engagement letter between the Issuer and support services law firm will embed the requirement on Issuers to disclose and report important information and events in the same manner as they do with Corporate Advisers. Aquis believe this framework will ensure that high standards and investor support are maintained.

Respondents generally endorsed the proposal for ongoing eligibility criteria for both the Access and Apex market segments. Aquis confirmed that compliance with minimum market capitalisation and free float requirements will be monitored over a period, addressing respondent concerns that Issuers would be at risk of suspension if, for example, there is an unexpected reduction in free float pursuant to a buyback or director share award. Eligibility will therefore be a monitored, time-sensitive discipline rather than an admission-only exercise.

Looking Ahead

The introduction of Aquis Support Services is a promising development for growth companies seeking a more tailored and cost-effective approach to regulatory compliance. However, the success of this model will depend on well-defined responsibilities (the devil will be in the detail of the legal adviser’s engagement letter) and mechanisms to ensure that Issuers do not inadvertently fall into non-compliance. The coming months will reveal how the market embraces this change and whether further refinements prove necessary. Watch this space.