AIM reforms create a simpler route to London for Australian resources companies

The most important change is the new Express Market admission route, which is designed to reduce duplication for companies already subject to regulation and disclosure requirements on recognised overseas markets. The revised AIM Rules took effect on 5 August 2026.

For Australian companies, the reforms raise a practical question of whether an AIM admission now offers a more efficient route to UK and European capital?

A new route for established ASX companies

An “express applicant” must have had its securities traded on an Express Market for at least three years, must not have undergone a fundamental change to its business or board in the preceding 12 months and must have an expected AIM market capitalisation of at least £20 million. Its relevant home-market admission documents and disclosures must also have been published in English.

An Express Market is broadly defined by reference to markets regulated by, or subject to the oversight of, an IOSCO member regulator.

For eligible companies, the admission process is streamlined. The draft Schedule One announcement need only be submitted three business days before admission, rather than the usual ten.

More significantly, an express applicant may not need to prepare a full AIM admission document.

Where its home market also falls within the relevant FCA definition of a “specified market”, and the same class of securities is being admitted to AIM, no AIM admission document is required. Otherwise, the applicant prepares a simplified Schedule Two Part Two document containing only the information required under Regulation 23 of POATRs and the AIM “buyer beware” wording.

That could substantially reduce the cost and duplication involved in an ASX/AIM dual quotation.

Why this matters for Australian resources companies

Resources companies are a natural candidate for a secondary London quotation because of the depth of UK institutional and specialist investor interest in mining, energy and critical minerals.

For many Australian resources companies, London offers something different from the ASX. It provides access to a deep pool of specialist mining and natural resources investors, including institutions that may not invest actively in Australia, and can be particularly attractive for companies with international assets or growth ambitions. By reducing the cost and complexity of accessing that market, the new AIM rules make London a much more compelling second-market option for established ASX issuers.

Damion Carruel, Oak Securities

The regulatory cost of accessing that capital has historically been a significant consideration. The Express Market route is intended to recognise the disclosure and scrutiny already applied by an issuer’s home market.

For an established ASX company with several years of audited financial statements, market announcements and technical reporting, that may materially change the economics of an AIM admission.

Australian issuers also benefit from continuity in financial reporting. The AIM Rules expressly permit non-UK companies to prepare annual accounts using Australian International Financial Reporting Standards issued by the Australian Accounting Standards Board.

Resources requirements remain

The reforms do not remove AIM’s specialist regime for mining and oil and gas companies.

The AIM Note for Mining and Oil & Gas Companies remains part of the AIM regulatory framework.

Accordingly, Australian issuers will still need to consider how their existing JORC reporting, technical reports and competent-person work fit within the AIM regime.

The interaction between the new Express Market process and the existing Mining Note will therefore be an important early issue for an ASX applicant and its nominated adviser.

The new rules reduce duplication, but they do not create a regulatory passport from the ASX to AIM.

More flexible rules for acquisitions

The August reforms also make AIM more flexible for acquisitive resources companies.

The threshold for a substantial transaction under AIM Rule 12 has increased from 10% to 25% under the class tests, aligning AIM with the Main Market regime.

An acquisition exceeding 100% under a class test will no longer automatically constitute a reverse takeover. A reverse takeover is now determined principally by whether the acquisition results in a fundamental change in the company’s business, board or voting control.

This may be particularly helpful for exploration and development companies, where class-test calculations can produce disproportionate results.

The Exchange has nevertheless retained oversight. Where a substantial transaction exceeds 100%, is not considered a fundamental change and the company does not intend to seek shareholder approval, the nominated adviser is expected to consult the Exchange.

Easier access to capital

AIM companies can also now request a Capital Access Window.

This allows a company undertaking a fundraising or corporate transaction involving the issue of shares to request a short voluntary suspension while negotiations take place.

For resources companies undertaking strategic placements, cornerstone investments or acquisition financings, this provides additional flexibility.

The reforms also remove the traditional working capital statement from the AIM admission document for ordinary applicants. It is replaced by disclosure of material capital resources, financial commitments, use of proceeds and the directors’ reasonable opinion of the company’s future fundraising needs over the following 12 months.

For exploration and development companies, that approach may better reflect the reality of staged project funding.

What about unlisted Australian companies?

The Express Market route is primarily relevant to companies already quoted on an overseas market.

An unlisted Australian resources company considering AIM as its first public market will still need to follow the ordinary AIM admission process.

For those companies, the strategic question remains whether the ASX, AIM or a dual-market strategy offers the best combination of valuation, investor access and future funding capacity.

The August reforms do not remove that analysis, but they make AIM a more credible option, particularly for companies whose assets or commodity exposure are likely to attract London investors.

A more competitive AIM market

The reforms do not fundamentally change the AIM model. Companies still require a nominated adviser, remain subject to UK market-abuse requirements and must comply with AIM’s specialist resources framework.

What has changed is the level of duplication imposed on established overseas issuers.

For qualifying ASX-listed resources companies, the new Express Market route could turn an AIM admission from a second IPO-style exercise into a significantly more proportionate process.

That is likely to make London more relevant to Australian companies considering where to raise their next round of growth capital.

Key points

• Established ASX-listed companies with at least three years’ trading history and an expected AIM market capitalisation of £20 million or more may qualify for the new Express Market route.
• Eligible applicants may be able to use substantially simplified admission documentation.

• AIM’s mining and oil & gas requirements remain, so JORC and technical reporting will still need to be considered.

• The increase in the substantial transaction threshold from 10% to 25% and a more flexible reverse takeover test should assist acquisitive resources companies.
• For Australian issuers seeking access to UK and European resources investors, AIM is now worth reassessing.

If you are an Australian resources company considering an AIM admission, a dual ASX/AIM listing or broader access to UK and European capital markets, please contact Chris Simmons at DMH Stallard LLP to discuss how the new rules may apply to your business and what an efficient route to London could look like.