萬國法律事務所

Taiwan's financial services regulator recently issued new regulations requiring all TWSE and TPEx-listed companies to file shareholder meeting materials on an accelerated schedule. This change removes the capital-based exemption for smaller-cap companies and imposes a universal disclosure schedule across the market that take effect in 2026.

Taiwan's Financial Supervisory Commission (the Commission) is effecting this change by amending two regulations: the Regulations Governing Content and Compliance Requirements for Shareholders' Meeting Agenda Handbooks of Public Companies (the Shareholder Meeting Agenda Regulations) and the Regulations Governing Information to be Published in Annual Reports of Public Companies (the Annual Report Regulations). The Commission has recently concluded the required public announcement and review process, which generally means that the pending regulations have been substantively finalized.

Under the amended regulations, all TWSE and TPEx-listed companies are required to upload electronic files to the official reporting website that contain [i] the shareholder meeting agenda handbook and supplemental material at least 30 days before the company's general shareholder meeting and [ii] the company's annual report at least 14 days before that meeting. See Shareholder Meeting Agenda Regulations §6(3) and Annual Report Regulations §23(1)(1).

Previously, this reporting schedule applied only to larger listed companies—those with paid-in capital exceeding NT$2 billion or combined foreign shareholding of 30% or more since 2024. After the amendments took effect, the same schedule applies to all TWSE and TPEx-listed companies, including smaller issuers that were previously outside the early-upload regime and permitted to file closer to the time of their regular shareholder meetings. By removing the paid-in capital and foreign shareholding thresholds, the Commission is ensuring that investors in all listed companies, regardless of size, have additional time to review proposals before exercising their voting rights.

From the perspective of regulatory timing, these amendments are part of a phased roll-out as mandated by Taiwan's Corporate Governance 3.0 – Sustainable Development Roadmap and the Sustainable Development Action Plan for TWSE/TPEx Listed Companies.

The Commission is emphasizing that these requirements are enforced beginning in 2026. Companies that were previously subject to more generous filing deadlines must now recalibrate their internal administrative schedules to ensure full compliance with the new disclosure rules.