USI — The new identity infrastructure for Hong Kong's securities market
What is USI and why does it matter?
Under the current system, many investors hold listed securities through intermediaries (banks/brokers) and the Central Clearing and Settlement System (CCASS). HKSCC Nominees Limited is recorded as the registered owner, while investors hold only beneficial interest. This means investors must rely on intermediaries to exercise shareholder rights — attending meetings, voting, and receiving dividends.
USI changes this fundamentally.
USI is a unique electronic profile assigned to each securities holder at the Approved Securities Registrar (ASR) level. It enables investors to hold and manage securities in their own names electronically, without paper certificates, through the UNSRT (Uncertificated Securities Registration and Transfer System).
For the first time, retail and institutional investors can be direct registered holders in a fully digital environment — breaking the intermediary barrier that has defined Hong Kong's market infrastructure for decades.
What shareholders need to set up a USI profile
Individual Holders
Requirement | Details |
Identity Document | HKID / Foreign ID / Passport |
Name | English name (mandatory) + Chinese name (optional) |
Personal Details | Date of birth; Gender; ID type, number & expiry date |
Contact | Address; Email address; Mobile number |
Banking | HKD bank account details |
Verification | Signature specimen |
Corporate Holders
Requirement | Details |
Identity Document | LEI registration document / Certificate of Incorporation / Business Registration Certificate / Other equivalent identity document |
Name | English company name (mandatory) + Chinese (optional) |
Corporate Details | ID document type, number & expiry; Place of incorporation |
Contact | Address; Email address; Mobile number |
Banking | HKD bank account details |
Authorisation | Board resolution with authorised signatories |
What this means for listed companies
The issuer's role in USM implementation
Issuers are not passive observers in the USM implementation. They bear direct responsibility to:
1. Proactive communication
Inform existing registered holders about USI profile requirements, the process for establishment, and the consequences of not acting. This includes pre-IPO investors, controlling shareholders, and any holders currently on the paper register.
2. Assist pre-IPO investors and controlling shareholders
For companies already listed, the transition requires:
- Helping pre-IPO investors and controlling shareholders establish USI profiles at the ASR
- Coordinating the surrender of existing physical share certificates for conversion to uncertificated form
- Ensuring board resolutions and authorised signatory documentation are in order for corporate holders
3. Listing document disclosure
Under Appendix G1 of the Main Board Listing Rules (or Appendix F1 of GEM Rules), issuers must include:
- A statement that holders wishing to hold/manage paperless securities in their own name must establish a USI profile at the ASR
- A hyperlink to the ASR's website explaining the USI profile establishment process and consequences of not establishing one
4. Ongoing shareholder data management
USI transforms the issuer-shareholder relationship. With registered holders identifiable directly through the ASR system, issuers gain:
- Direct penetration — investors hold shares in their own name on a paperless basis
- Bilateral electronic communication — issuers communicate directly with registered holders through the ASR system
- Real-time push — major announcements and AGM notices delivered instantly
- Governance upgrade — registered holder identity becomes more transparent, facilitating shareholding structure analysis and improving institutional and retail shareholder engagement
Before vs. after USM: The shareholder experience
Aspect | Before USM | After USM (with USI) |
Ownership evidence | Physical share certificate | Electronic record in USI profile |
Transfer method | Paper instruments + manual processing | Electronic transfer via UNSRT |
Corporate actions | Require physical certificates | Managed electronically through USI |
Deposit to broker | Surrender physical certificate | Electronic instruction via UNSRT |
Three scenarios for IPO timing
Scenario | Submission Date | Listing Date | Listing Document Disclosure Requirement |
Listed before USM | Before 16 Nov 2026 | Before 16 Nov 2026 | No USM disclosure needed; must complete USM onboarding within 5 years |
Applied before, listing after USM | Before 16 Nov 2026 | After 16 Nov 2026 | Must include USM disclosure in the final draft listing document |
Applied after USM | After 16 Nov 2026 | After 16 Nov 2026 | Must include USM disclosure in the application proof from the outset |
The Governance Opportunity
USI is not just compliance infrastructure — it is a governance upgrade.
When shareholders hold directly via USI profiles rather than through CCASS nominees, issuers gain unprecedented visibility into their shareholder base. This enables:
- More accurate shareholding analysis — understand who actually owns your company
- Targeted investor relations — communicate directly with registered holders rather than through intermediary chains
- Higher AGM participation — combined with hybrid meetings and e-proxy, USM removes friction from shareholder engagement
- ESG alignment — paperless operations support carbon reduction and sustainability reporting
For companies with significant retail shareholder bases or cross-border institutional investors, USM represents a step-change in the quality of shareholder engagement.
Key takeaways
The shift from paper certificates to USI profiles is the most significant change to Hong Kong's shareholder infrastructure in a generation. Listed companies that move early — communicating clearly, supporting shareholders through the transition, and leveraging the governance benefits — will build stronger investor relationships and reduce operational risk.
Those that wait will face compressed timelines, confused shareholders, and potential regulatory scrutiny.
Vistra's share registration team supports over 1,400 Hong Kong-listed companies. Our technology platform provides 24/7 shareholder data management, USI profile facilitation, and AI-powered corporate governance solutions. Contact us for a USM readiness assessment.
Read more about what listed companies must do before USM goes live on 16 November 2026.
Or Understand the USM and Vistra’s IPO & Share Registry services at IPO & Share Registry Services | Vistra
The contents of this article are intended for informational purposes only. The article should not be relied on as legal or other professional advice. Neither Vistra Group Holding S.A. nor any of its group companies, subsidiaries or affiliates accept responsibility for any loss occasioned by actions taken or refrained from as a result of reading or otherwise consuming this article. For details, read our Legal and Regulatory notice at: https://www.vistra.com/notices. Copyright © 2026 by Vistra Group Holdings SA. All Rights Reserved.
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