Chapter 4 · Markets

14 exam questions · IPO, rights, buybacks, watch-list, sukuk, crypto
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Why this chapter matters. 14 exam questions. Wide coverage from IPO mechanics to crypto. Trap zones: share premium 6-month avg / ≤25% deduction, buyback 10% cap / 1-year window / 15+3 day blackout, closed periods 15 days financial / 10 days material, watch-list 1 yr extendable to 3 / action plan every 3 months, 2nd category 6 months suspension OR ≥50% losses, PJSC conversion ≥10% over 2 yrs, and crypto retail cap AED 350k.

4.1 Market infrastructure

The Depository Centre syllabus 4.1

The UAE Depository Centre holds securities deposited by sellers and transfers them to buyers only once cash settlement is confirmed. Together with the exchanges and clearing system, it forms the UAE's "capital market institutions".

Depository — key rules syllabus 4.1

  • Terminal install at listing: within 1 week of listing approval
  • 5%+ shareholder reports made to SCA
  • CSD record retention: ≥ 15 years
  • Bonus share fractions sold within 30 days
  • Pledged securities max market value: 50%

4.2 Listing & IPO

Private → PJSC conversion syllabus 4.2

To convert a private joint-stock company to a PJSC (and list), the company must show net profit ≥ 10% of capital in EACH of the previous 2 financial years. This is a quality screen — recent track record matters.

Trap: candidates often guess 5% or 20% — the rule is 10%, and it must be met in EACH of 2 years (not averaged).

IPO essentials syllabus 4.2

  • Minimum subscription (PJSC): AED 5 million
  • Working capital: 12 months
  • Listing adviser engagement period: 1 year
  • Internal auditor removal notice: ≥ 30 days advance

Qualified investors — two routes syllabus 4.2

Corporate (2 of 3)
Budget ≥ 75m / annual return ≥ 150m / paid-up ≥ 7m AED
Natural person
Net equity ≥ AED 4m + annual income ≥ AED 1m
Distinguish from Ch 3 GP/LP rules (≥ AED 3m income / ≥ AED 7m net equity). These are general qualified-investor rules — different numbers, different purpose.

Foreign issuer — primary listing in home jurisdiction syllabus 4.2

A foreign issuer seeking UAE listing must be primarily listed and supervised in its home jurisdiction by a recognised regulator. The UAE listing is then a secondary listing with adapted disclosure obligations.

Independent directors — ≥ 1/3 of board syllabus 4.2

Listed PJSC boards must have at least one-third independent directors. The independence test (per CG Guide): no employment / no material business relationship with the issuer or controlling shareholder in the previous 2 years.

4.3 Rights issues & share premium

Share premium — 6-month base, ≤25% deduction syllabus 4.3

When a listed PJSC increases capital by issuing new shares above nominal:

  • Base price: 6-month average market price preceding announcement
  • Maximum deduction: ≤ 25% from that average
  • Floor: the resulting figure

The 6-month window smooths volatility; the 25% cap balances issuer flexibility against shareholder dilution protection.

Rights issue — windows syllabus 4.3

Advance notice
20 business days
Rights trading window
10 business days
20 days advance NOTICE vs 10 days TRADING — different purposes, easy to confuse.

4.4 Buybacks

Buyback — three caps syllabus 4.4

Max % of capital
10% of paid-up capital
SCA approval
Within 15 working days
Execution deadline
1 year from approval
Blackout window
15 days before / 3 days after disclosure
Memory anchor: "10 / 15 / 1 / 15+3". Don't confuse the 15-day SCA approval window with the 15-day pre-disclosure blackout — different mechanisms.

4.5 Closed periods & insider rules

Closed periods — the 10/15 pair syllabus 4.5

Material info embargo
10 days before disclosure of material non-financial info
Financial statements embargo
15 days before publication of financial results
Memorise the pair: financial = 15, material = 10. Material info typically gets disclosed promptly (shorter window); financial statements have a fixed publication date (longer pre-window).

Material change disclosure — ASAP syllabus 4.5

Material events (board changes, major contracts, restatements) must be disclosed as soon as practicable — typically before the next trading session resumes. Delaying to the next quarterly results is forbidden.

Major shareholder — 5% threshold syllabus 4.5

Holdings crossing the 5% threshold must be disclosed to the SCA / market. Subsequent material step changes trigger further notifications.

4.6 Watch-list, 2nd category, delisting

Watch-list — 1 year, extendable to 3 syllabus 4.6

Initial monitoring: 1 year. Cumulative cap: 3 years. Action-plan progress disclosed publicly every 3 months. Beyond 3 years, transfer to 2nd category or delisting.

2nd category — two triggers syllabus 4.6

Suspension trigger
6 consecutive months of trading suspension
Losses trigger
Accumulated losses ≥ 50% of capital
The 50% losses figure mirrors the Companies Law point at which the board must escalate to shareholders. Either trigger alone suffices.

Voluntary delisting syllabus 4.6

  • Advance notice: ≥ 90 days
  • Shareholder approval: special resolution (typically 75% of represented shares)
  • Delisting notification: within 30 days of decision
  • SCA approval required

4.7 Sukuk & debt

Debt securities / Sukuk — key thresholds syllabus 4.7

  • Minimum issue size: ≥ AED 10 million
  • Annual audited filings: within 180 days of FY end
  • Paying agent: must be in-state
  • Trustee: required for secured debt
  • Islamic securities prospectus: must include Sharia certification
180-day Sukuk annual filing window is more generous than equity issuers — Sukuk holders are paid coupons not dividends, so less sensitive to precise audited year-end picture.

4.8 Conciliation

Conciliation committee — 15-day decision syllabus 4.8

Conciliation is the SCA's pre-litigation dispute resolution mechanism. The committee must issue its decision within 15 working days. If conciliation fails, parties retain their judicial rights.

4.9 Crypto-asset regulation

Crypto under Decision No. 23 of 2020 syllabus 4.9

The SCA regulates crypto-assets through a dedicated framework covering: token classification (security tokens, commodity tokens), exchanges, fundraising platforms, custody, AML, and sanctions.

Crypto fundraising — retail per-client cap syllabus 4.9

For crypto-asset fundraising platforms, the maximum permitted PER-CLIENT investment by a retail (non-qualified) investor per offering is AED 350,000. Qualified investors face no per-client cap.

Crypto custody — segregation & keys syllabus 4.9

  • Segregation of client assets from custodian's own assets
  • Keys storage: secure, segregated, with disaster-recovery
  • Custodian appointment for security tokens is mandatory

4.10 Cheat sheet — all the numbers

Every Ch 4 threshold in one place exam day

TopicThreshold
IPO minimum subscription (PJSC)AED 5 million
IPO working capital12 months
PJSC conversion — net profit≥ 10% of capital over 2 years (each)
Share premium — base6-month average market price
Share premium — max deduction≤ 25%
Rights issue — advance notice≥ 20 business days
Rights trading window≥ 10 business days
Buyback — max %10% of paid-up capital
Buyback — SCA approval15 working days
Buyback — execution deadline1 year from approval
Buyback blackout15 days before / 3 days after disclosure
Closed period — material info10 days
Closed period — financial statements15 days
Major shareholder disclosure5%
Independent directors — minimum≥ 1/3 of board
Watch-list — initial period1 year
Watch-list — total cap3 years
Watch-list — action plan disclosureEvery 3 months
2nd category — suspension trigger6 consecutive months
2nd category — losses trigger≥ 50% capital
Voluntary delisting — advance notice≥ 90 days
Delisting notificationWithin 30 days of decision
Conciliation committee decision15 working days
Debt / Sukuk minimum issue≥ AED 10 million
Sukuk annual filingsWithin 180 days of FY end
Internal auditor removal notice≥ 30 days advance
Listing adviser period1 year
Crypto retail per-client capAED 350,000
Crypto individual sanction max≤ 2 months
Depository terminal installWithin 1 week of listing
5%+ shareholder reportingPeriodic to SCA
CSD record retention≥ 15 years
Bonus share fractions soldWithin 30 days
Pledged securities — max market value50%
Qualified investor (corporate, 2 of 3)Budget 75m / return 150m / paid-up 7m AED
Qualified investor (natural)Net equity ≥ 4m + income ≥ 1m AED

Drill the heavy stuff

  • 🎯 95 calibrated Ch 4 questions in the bank.
  • 📊 The 75% / 80% / 50% / 10% / 15% / 30% scattershot of % numbers is where most candidates lose marks.

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