AIM – LSE publishes feedback on proposed changes to the AIM Rules

The London Stock Exchange (LSE) has issued a Feedback Statement following its Discussion Paper on the future of AIM published earlier this year (read more on our blog here).

The Feedback Statement sets out some immediate operational changes alongside areas for consultation and further reform. The changes that will be implemented immediately through derogations or updates to guidance include:

• Dual‑class shares – these will be acceptable on AIM where they meet the Main Market-equivalent requirements (with appropriate disclosures);
• Related party transactions – the nominated advisor (Nomad) will not need to give a “fair and reasonable” opinion on directors’ remuneration (provided the Nomad is satisfied that there are reasonable protections in place);
• Substantial transactions – derogation requests will be considered to treat an acquisition as a “substantial transaction” (AIM Rule 12), rather than a reverse takeover (AIM Rule 14), where it does not amount to a fundamental change of business;
• Reverse takeovers – the LSE will consider derogation requests not to automatically suspend securities upon notification of a reverse takeover in contemplation, where appropriate disclosure can be made;
• Historical financial information – derogations may be requested to use UK GAAP (FRS 102), which is particularly helpful for UK companies transitioning to AIM, and to allow information to be incorporated by reference; and
• Admission document – an admission document may not be required when listing a new class of securities.

The Nomad role is one of the key areas where the LSE will consult further. The LSE says that the gatekeeper role of the Nomad remains critical to AIM’s success but needs to be recalibrated to be less compliance-orientated. It plans to publish a new technical note for Nomads alongside its consultation on AIM Rule changes in the first half of 2026.