Key points

  • Starting in January 2024, the TSE has been publishing a Disclosed Company List every month, targeting companies in the Prime and Standard markets, showing the status of their response to requests.
  • From January 2025 onwards, an item can be listed as “under consideration” for up to six months in principle. You'll also see the date your disclosure was updated and whether you'd like to receive communications from institutional investors.
  • From January 2026 onwards, you will also be able to see a list of each company's disclosures included in their corporate governance reports. It has become easier to compare not only the presence or absence of participation, but also the content.

Why publish the list?

The March 2023 request is not a regulatory requirement. It is not a system in which the TSE examines each company's plan and decides whether it passes or fails, or imposes fines on companies that cannot achieve numerical targets for PBR or ROE.

Therefore, TSE adopted a method of making the status of response visible to market participants. By listing what a company discloses, investors can compare companies in the same industry side-by-side. Companies can also check whether they are the only ones who have postponed their response or whether updates have stopped after the initial disclosure.

With this system, there is no need for TSE itself to score each line on the merits of disclosure. Investors engage in dialogue, exercise voting rights, and make investment decisions based on published information. That comparability drives companies to improve disclosure and implementation.

Changes in the list

period Main changes
March 31, 2023 Publish request to all Prime Standard companies
October 2023 Announcement of policy to publish list of disclosed companies
January 2024 The first list is published. From then on, updates will be made on the 15th of each month as a general rule.
January 2025 Renewal date, request for contact from institutional investors, introduction of 6-month limit for “under consideration”
January 2026 List of disclosures by each company in the CG report
August 2026 Publishes a list of "companies that are making progress" based on an investor survey

The list is created based on the most recently submitted corporate governance report at the end of each month. The list as of the end of July 2026 was published on August 14th. In this way, the latest status is constantly updated, so it is more reliable to check the current TSE file than the number of companies in the article.

Current classification method

Each company selects the content to be disclosed in the “Measures to realize management that is conscious of cost of capital and stock price” section of the CG report.

Treatment on list Selection in CG report meaning
Disclosed “Disclosure of initiatives (first time)” or “Disclosure of initiatives (update)” Discloses initiatives or updates thereof
Under consideration “Disclosure of consideration status” We are considering disclosing specific initiatives. Generally posted for up to 6 months
Not listed Not applicable to the above Cannot be confirmed as disclosed or under consideration on the list

“Disclosed” does not mean that the content is sufficient. Even an abstract explanation of a few lines can be listed as disclosed if it is disclosed in a predetermined format. On the other hand, even if detailed materials are published, if the references and selected items in the CG report are not appropriate, they may not be reflected correctly in the list.

In addition to creating materials, IR personnel also need to check that the CG report and the list display match.

What does the 6 month rule mean?

The initial "under consideration" status was an interim state to allow the company time to conduct a thorough analysis. However, if there is no deadline, specific disclosure can be postponed while it remains under consideration.

Starting from January 2025, the TSE will limit the period for listing items under consideration to six months. This does not mean that you will necessarily improve your PBR within 6 months. The expectation is that companies advance to concrete disclosure of their current analysis, challenges and intended actions.

Even if consideration takes time, it is easier to gain investors' understanding by indicating what is being analyzed, when it was discussed at the board meeting, and by when the next disclosure will be made, rather than simply stating that it is "under consideration."

What you can check on the list

The list includes company name, stock code, market segment, industry, disclosure status, first disclosure date, update date, etc. From 2025 onwards, you will also be able to see which companies would like to be contacted by institutional investors. From 2026 onwards, it will become easier to access the disclosures contained in CG reports.

In practice, the following three points should be considered.

1. Interval between initial disclosure date and update date

Companies that have not updated their information after initial disclosure may have created materials and stopped responding. If medium-term management plans, capital policies, and business portfolios change, disclosures regarding cost of capital will also need to be reviewed.

2. Differences from other companies in the same industry

Even among companies in the same industry and size, there are differences in the specificity of capital cost figures, ROIC management, business-specific improvement measures, and shareholder return policies. The list can be used as an entry point for finding comparison targets.

3. Contents of “Disclosed”

Don't judge based on the condition alone, read the actual description. Confirm that the basis for capital cost, current situation analysis, goals, measures, progress, and updates are based on dialogue.

Materials to supplement the list

TSE not only publishes lists, but also continuously publishes materials for considering the quality of disclosure.

  • Points based on the investors' perspective: Organize what investors value.
  • Case study collection (Prime Standard): Introducing reference cases from actual disclosures.
  • Cases where there is a gap with investors' perspectives: Organized abstract explanations, individual presentation of PBR targets, bias towards shareholder returns, etc.
  • A collection of case studies of companies' efforts to solve problems: Rather than disclosing text, we introduce how problems were solved within the company.
  • 2026 Company and Investor Survey: Visualizing dialogue challenges and companies where investors are evaluating progress.

While a list shows who is disclosing, these materials show what the disclosure conveys and what kind of implementation will be evaluated. Both must be read together.

Strengths and limitations of public discipline

The strength of the publication method is that all market participants can use the same information. It can be used immediately for peer comparisons, investor dialogue, and internal explanations without waiting for administrative action. The more information is disclosed, the more noticeable non-disclosure and suspension of updates become.

On the other hand, there is also the danger that being on the list becomes an end in itself. Status classification does not assurance the quality of disclosure or implementation results. Even if you show numbers, if the assumptions are unclear or if the goals and measures are not connected, investors' evaluations will not be high.

Therefore, it is appropriate to view the list as a starting point for dialogue, rather than a list of successful applicants.

Suggestions for IR personnel

  1. Check your company's visibility in the monthly list. Check for errors in status, date of first disclosure, date of update, and link destination.
  2. If "Under consideration", proceed to the next stage within 6 months. Internally, the deadline is approximately 5 months, which includes updating the CG report.
  3. Determine update policy after initial disclosure. Updated at least once a year, and whenever there are changes to the medium-term plan or capital policy.
  4. Compare 10 to 20 companies in the same industry. Compare not only the status but also the basis of capital cost, goals, measures, and specificity of progress.
  5. Listing is not considered an achievement. Disclosure has meaning only when it is used for dialogue with investors and management execution.

Source/reference materials

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