New regulation for voluntary delisting published by ASK
On 21 May 2025, the Self-Regulatory Committee of the Swedish Stock Exchange (“ASK”) published a new regulation, Rules on Delisting of Shares at the Initiative of the Issuer (the “Delisting Rules”), which will enter into force on 1 September 2025. The new rules largely codify ASK’s existing practice but also make it easier for listed companies to voluntarily decide on delisting.
Key points of the regulation
Given that continued listing of a company’s shares is often a prerequisite for smaller shareholders to realise any value from their shareholding, the starting point of the new rules remains that a listed company may only apply for delisting if the company is deemed not to meet the listing requirements of the marketplace.
With this in mind, the Swedish Securities Council has previously stated that, in principle, there must be unanimity among shareholders for a listed company to have the right to voluntarily apply for delisting, i.e., to apply for delisting even though the listing requirements are met. Previously, the Council required that such a decision (1) must be supported by all shareholders in attendance at a general meeting and (2) that they collectively represent at least nine-tenths of all shares in the company. Consequently, a voluntary delisting decision could previously be blocked by just one shareholder holding a single share in the company.
The new rules provide a significant easing of these requirements, in that it is sufficient for a decision on voluntary delisting to be supported by nine-tenths of the shares represented at a general meeting (regardless of the proportion of the company’s total shares represented at the meeting). However, the rules also specify that if there is a shareholder in the company who controls at least three-tenths of the votes, shareholders holding a majority of all other votes in the company must not have voted against the decision. Hence, a major shareholder still cannot push through a delisting decision contrary to the wishes of the minority.
Furthermore, the Delisting Rules specify how and when an application for delisting should be made, depending on the circumstances prompting the measure and the company’s status in relation to the marketplace’s listing requirements. The rules also include requirements regarding the provision of information to both the market and shareholders throughout the process.
How Lindahl can help
Lindahl’s equity capital markets group has extensive experience in guiding listed companies through an ever-evolving regulatory landscape. We offer tailored advice to assist companies in implementing these rules in their specific situations.
Contact us
For more information on how these rules may affect your company, or to discuss how we can support you throughout their implementation, please contact Lindahl’s Capital Markets group.
Do you want to know more? Contact:
Victoria Skoglund
Partner | AdvokatCarousel items
-
Portraits
7/3/2026
Jesper on business-oriented legal advice in energy: "It is not enough for the advice to be correct"
Lindahl's energy team is recognised in Legal 500 for combining deep regulatory expertise with broad commercial legal experience – find out how they support clients in a rapidly evolving sector.
-
Cases and transactions
7/2/2026
Lindahl advises Nolato on the divestment of its Romanian operations
Lindahl acted as legal adviser to Nolato AB in connection with the divestment of Nolato Romania, a high-volume injection moulding business with annual turnover of SEK 60 million.
-
Knowledge
6/29/2026
The scope of the Swedish FDI Act is expanded – is your business affected?
MCF's new regulation (MCFFS 2026:13) expands the scope of the Swedish FDI Act from 15 July 2026. Is your business affected? Read about the key changes.
-
News articles
6/25/2026
Lindahl recognised in IP Stars 2026
Lindahl advances to Tier 2 in Copyright & related rights in IP Stars 2026, retains strong rankings in trade mark law, and sees several lawyers recognised with individual awards.
-
Read more news and insights?