The revised AIM Rules expand the pool of international issuers able to consider a more proportionate route to London’s growth market.

Published: 3 September 2026
Authors: Ed Nisbet

AIM has long helped ambitious growth companies access capital, pursue acquisitions and accelerate growth. It has attracted companies from a wide range of jurisdictions and sectors, supported by an experienced investor base and adviser ecosystem familiar with the needs of growing businesses.

International companies have not, however, always found it straightforward to access AIM.

The former Designated Market route was intended to provide an accelerated route to admission for companies listed on select overseas markets where regulatory standards were deemed sufficiently high.

In practice, however, many international issuers and advisers did not view it as a genuinely streamlined path into London’s capital markets: the work involved was often only marginally less extensive than on a traditional IPO.

The challenge was not AIM’s underlying appeal, but whether the route into AIM was compelling for companies already subject to established public market regulation elsewhere.

That exposed the weakness of the old approach: an overseas company could have an established public market track record and a robust disclosure regime yet still fall outside the accelerated route because its market was not included within the prescribed Designated Market framework.

The new AIM Express Market route, introduced as part of the revised AIM Rules effective from 5 August 2026, seeks to address both criticisms.

First, it introduces a wider definition of an Express Market (in broad terms, any equity market that is regulated by a member of the International Organisation of Securities Commissions). Second, it introduces a more proportionate admission framework intended to recognise the regulatory scrutiny, disclosure history and public company experience that qualifying overseas issuers have already demonstrated elsewhere.

The significance of the reform therefore extends beyond a change in admission mechanics. AIM is seeking to create a more credible and internationally competitive route for established overseas companies that wish to access London’s capital markets without unnecessarily duplicating work already undertaken in their home market.

What has changed?

The practical effect is that the new regime asks a more commercially relevant question: has the company already demonstrated an appropriate public market track record on a market that meets the Express Market criteria?

Who can benefit from the AIM Express Market route?

For an applicant to meet the AIM Rules definition of ‘express applicant’, it must:

• have been admitted to an Express Market for at least three years
• have satisfied the relevant continuity of business and board requirements
• have a minimum expected market capitalisation on AIM admission of £20 million
• have published in English any relevant admission documentation and the disclosure required in its home jurisdiction.

The formal Schedule One process is also significantly shorter than under the standard admission route: three business days rather than 10 business days. However, companies still need to complete the necessary legal, financial and nominated adviser work required for admission.

Eligibility does not guarantee admission

Meeting the express applicant conditions does not create an entitlement to admission. Applicants must still appoint a nominated adviser, which remains responsible for assessing whether the applicant is appropriate for AIM and advising it on its obligations under the AIM Rules. The Exchange also retains discretion to refuse, delay or impose conditions on an admission where appropriate. The Express Market route should therefore be seen as a means of reducing unnecessary duplication for suitable applicants, not a form of automatic passporting onto AIM.

Will an express applicant need an AIM admission document?

Not necessarily. An express applicant will not be required to produce a separate AIM admission document where its securities are already admitted to an Express Market that is also a specified market under the FCA Handbook and the securities being admitted to AIM are of the same class.

Where those conditions are not met, the company may still qualify as an express applicant but will generally be required to prepare a simplified AIM admission document. As a result, the reforms extend beyond companies quoted on specified markets, but the amount of AIM-specific documentation required will depend on the applicant’s circumstances.

A new route for dual-market applicants

The reforms also introduce a separate dual-market applicant route.

This applies where an applicant:

ü  is being admitted to AIM concurrently with admission to an Express Market

ü  is publishing a document in connection with its admission to that Express Market

ü  is undertaking an equity fundraise of at least £6 million, or the equivalent amount in another currency, as part of its initial public offer in connection with its admission to an Express Market.

The document published for the Express Market admission may serve as the applicant’s AIM admission document, provided it also includes the supplementary information required by Schedule Two, Part Two of the AIM Rules.

For an international business wishing to maintain a strong presence in its home or principal market while also accessing London investors, this creates a more credible framework for a coordinated dual-market IPO.

It allows the company to consider how two markets may support its capital-raising and strategic objectives, rather than necessarily treating the choice of listing venue as binary.

A dual-market strategy will still require careful planning. The company and its advisers will need to assess the compatibility of the relevant admission timetables, disclosure standards, accounting requirements, settlement arrangements and continuing obligations in each market.

Why AIM remains attractive

Against a backdrop of intense competition between global exchanges, the reforms are a reminder of what AIM continues to offer and why a more proportionate route to admission may matter for overseas companies.

Unlike many international exchanges, AIM has long been accustomed to supporting founder-led growth companies, acquisitive businesses and international issuers. For companies seeking access to public capital without necessarily moving into a framework designed primarily for the world’s largest listed groups, that combination remains distinctive.

Few growth markets can point to a comparable track record of capital formation, secondary fundraising activity and support for acquisitive growth companies. AIM has attracted businesses from a broad range of jurisdictions, sectors and stages of development while developing an investor and advisory community experienced in supporting smaller and growing public companies.

For international companies, those benefits may include:

• access to UK and international growth investors
• the potential to enhance the company’s profile beyond its domestic market
• a platform for future equity fundraising
• the ability to use publicly traded shares as acquisition consideration
• a public market platform that may support wider financing opportunities
• a potential liquidity mechanism for existing shareholders.

Which companies should be considering AIM?

The new route may be particularly attractive for:

• international technology companies seeking access to specialist growth investors
• healthcare and life sciences businesses pursuing international expansion
• natural resources and energy companies seeking to broaden their investor base
• founder-led businesses considering public capital as part of their next phase of growth
• acquisitive companies seeking an additional form of transaction currency
• companies planning simultaneous public offerings in London and another jurisdiction
• established overseas-listed issuers seeking greater visibility with UK investors.

Not every company within these categories will be appropriate for AIM or benefit from dual admission. The decision should be based on the company’s objectives, investor proposition, expected trading liquidity, governance arrangements and the costs and obligations associated with maintaining quotations on more than one market.

Part of a wider package of reform

The Express Market route forms part of a broader package of changes intended to modernise AIM, including reforms that:

• permit incorporation by reference within admission documents
• replace the traditional working capital statement with more targeted financial disclosure
• permit the use of UK GAAP and, potentially, equivalent accounting standards rather than requiring accounts to be reported under IFRS
• support founder-led businesses through permitted special voting share structures
• simplify various aspects of the admission process.

Taken together, these changes are intended to reduce unnecessary cost, complexity and duplication while retaining the nominated adviser-led model that has long distinguished AIM from other growth markets.

For further information regarding these reforms, please see our insight.

Time to revisit AIM?

The strategic message from the reforms is clear: AIM has widened the international audience with which it is prepared to engage and created a more proportionate admission framework for companies that have already established their credentials on another public market.

The reforms reduce unnecessary friction, but companies will still need to satisfy the AIM Rules, applicable securities laws and any relevant home-market obligations. For international companies that may previously have dismissed AIM as unavailable, overly complex or insufficiently differentiated from their existing listing, the revised AIM Rules provide a compelling reason to revisit that analysis.

Shoosmiths’ Public Markets team advises companies, investment banks, nominated advisers and other market participants across IPOs, secondary fundraisings, public M&A and ongoing listed company matters. We regularly support transactions involving international operations, cross-border shareholder bases and multi-jurisdictional execution. That cross-border experience is particularly valuable when assessing how AIM fits within an international company’s wider growth, financing and shareholder strategy.

For overseas listed and internationally ambitious companies, the reforms create a timely opportunity to revisit AIM as part of a broader capital markets strategy. We can help assess whether the new Express Market route is available, how it compares with other listing options and the practical steps needed to deliver an AIM admission or dual-market transaction.