Blog

I DON’T know how many of you are football fans, but many games are played over the Christmas and New Year period.

Every morning when I try to check the scores, I am struck by how every single headline is about the referee – whether a penalty should have been awarded, or whether a red card should have been given.

I’m annoyed – I want to read about the game, not the referee.

This got me thinking about how this applies to market regulation too. People want to read about how the market is performing and what companies are doing. That’s why it’s called The Business Times and not The Regulatory Times.

What can we do to keep the focus on the play and not the refereeing?

The first point is that we need to ask is whether the referee or the regulator is intervening excessively.

I have spoken on previous occasions about the feedback on our trading queries and how they can have a chilling effect on our market. We have fine-tuned our trading queries – which has helped reduce the number of queries – and this year, we will conduct a review of the entire trading query regime.

We have received feedback that we should look not just at our trading queries, but also our public queries in general, because they too can have a chilling effect on the market.

Let me caveat that under our disclosure-based regime, our guiding principle is to require the timely disclosure of material information, and we make no apologies for querying companies on material matters that in our judgment require stronger disclosure.

But in light of the feedback, we will conduct a review of our query regime as a whole to see if we have been applying that materiality principle consistently.

The second point is that market participants must know what is and is not allowed, and the regulator must communicate this clearly and quickly.

Nothing irritates fans more than a lengthy stoppage of play. In the same way, the market also wants to see regular news flow on corporate actions, which in turn will inform trading activity.

So we have published tonnes of guidance, and I personally have written a record number of regulators’ columns to set out our expectations.

There will of course be complex cases where interaction with the regulator is required. We appreciate that time to market is important, and we will see whether we need to change the way we interact with the market in order to speed things up.

In football, when there is a foul, the referee can play advantage and let the action continue if it benefits the team that has been fouled. You can be assured that we have our own version of the advantage rule, for example by granting waivers of our listing rules when the cost of compliance is disproportionate to the benefit.

Finally, we all need to recognise that public action is warranted once bad behaviour crosses the line to challenge the fairness and transparency of our market.

A few weeks ago, there was a game between the top two teams in the English Premier League.

By all accounts it was a fantastic game until the referee issued a red card and sent a player off for a foul. There was a huge debate over whether the referee was at fault for spoiling the game.

This is where I think we must not conflate two issues. The first is unnecessary regulatory intervention, which I agree we must avoid. The second is necessary regulatory intervention, which needs to be conducted regardless of whether it spoils the game or not.

You cannot refrain from issuing a justified red card just because it might disrupt an exciting game.

Public action is a deterrent to future bad behaviour that crosses the line. Plus, let’s face it, allowing such bad behaviour to continue is not sustainable. This will have to remain one of our guiding principles, even as we review the way we regulate.

As Sir Robert Peel, who is considered the founder of modern policing, once said: “The test of police efficiency is the absence of crime and disorder, not the visible evidence of police action in dealing with it.”

The writer is chief executive officer of SGX RegCo. This is an abridged version of a speech he delivered on Jan 22 at the Audit and Risk Seminar 2025 co-organised by the Singapore Institute of Directors, Accounting and Corporate Regulatory Authority, and SGX RegCo.