The Shame-and-Showcase List: how TSE polices participation through publication

TL;DR

• The monthly disclosure list, first published January 15, 2024, names every Prime and Standard Market company by its cost-of-capital-disclosure status — Disclosed, Under Consideration, or implicitly Not Disclosed. It is refreshed around the 15th of each month and serves as the operational backbone of TSE's soft-enforcement system.
• A January 2025 rule reclassifies companies stuck in "Under Consideration" for more than six months as "Not Disclosed" — closing the indefinite-future-action loophole.
• By March 13, 2026: ~93% of Prime (1,472 issuers) and ~51% of Standard (807 issuers) had disclosed. The list is now consumed directly by Japanese asset managers and overseas investor databases as a first-pass screen — inclusion is positive visibility; exclusion is a flag.

The mechanism: enforcement by publication

The Tokyo Stock Exchange does not have legal authority to fine or sanction listed companies for failing to disclose cost-of-capital initiatives. The March 2023 request (Post 4.1) is a request — 「お願い」 — not a regulation. So how, in two years, has the disclosure rate in the Prime Market climbed from zero to 93%?

The answer is the monthly disclosure list. It is the operational mechanism that converts soft language into hard pressure. The list works because three independent audiences treat it as authoritative:

• Domestic asset managers use it as a screen for proxy-voting and engagement targets.
• Foreign investors use it as a translated-into-data signal of which companies are "in" the TSE programme and which are not.
• Activists use it as a target list: a Prime Market issuer with no disclosure and PBR < 1 is, almost by definition, a fundable campaign.

The list does not say "this company is bad." It simply publishes who has and has not engaged. In a high-context business culture like Japan's, that is sufficient.

Timeline of the list

What the list contains

The published list (refreshed monthly at https://www.jpx.co.jp/english/equities/follow-up/nlsgeu000006xn3l.html) is a flat table. Each row corresponds to one listed company and contains the following fields:

• Company name (Japanese and English versions)
• Ticker code (4-digit Securities Code)
• Market segment (Prime / Standard)
• Industry (TSE 33 industry classification)
• Status: Disclosed or Under Consideration
• Date of initial disclosure
• Date of most recent update
• Link to the relevant section of the company's most recent Corporate Governance Report

Companies that are neither "Disclosed" nor "Under Consideration" do not appear on the list — they are, implicitly, "Not Disclosed." This is the third state, and it is the one with reputational consequences.

The three-state classification

The three-state system was deliberate. A binary "Disclosed / Not Disclosed" list would have produced compliance theatre — companies disclosing boilerplate just to get on the list. The intermediate "Under Consideration" status acknowledged that some companies genuinely needed time to do the work (e.g., quantifying cost of equity for the first time), while the January 2025 six-month rule prevented that intermediate state from becoming a permanent parking spot.

How to read the list — a worked walkthrough

Below is a representative mock of how a few rows of the list look. This is a mock for illustration; the live list is at the JPX URL above.

The list itself is sparse — it does not score quality, it just records participation. Three observations worth making when you scan a real version:

Observation 1 — Look at the gap between initial disclosure and latest update. A company whose "initial" and "latest" dates are the same has disclosed once and stopped. The TSE November 2024 misalignment booklet flagged this as a top failure pattern. Best-practice disclosers (Hitachi, Marui, Asahi Kasei, Mitsui) update at least annually, often more frequently when MTM revisions occur.

Observation 2 — Industry concentration matters. Banking, with strong FSA pressure and chronic PBR-below-1 exposure, led disclosure at 98.5% by end-January 2024. Industries that lag — historically, smaller-cap services, real estate, and some industrials — are where activists hunt.

Observation 3 — "Under Consideration" with a stale latest-update date is the activist signal. A company with status "Under Consideration" whose latest movement is more than 6 months old is about to be reclassified as Not Disclosed under the January 2025 rule. That is a public, dated, exchange-published flag.

The disclosure-list dashboard: a maintainer's view

Sophisticated IR teams maintain an internal dashboard tracking their own company's status against peers. A minimum viable dashboard contains:

1. Own status — Disclosed / Under Consideration / Not Disclosed, with last-update date.
2. Peer group status — A defined list of 10–20 industry/size peers and their statuses.
3. Days since last update — Both for own company and for peers; longer than 12 months is a flag.
4. Disclosure-quality score — An internal qualitative read against the four expected disclosure dimensions: (i) cost of capital number, (ii) current-situation analysis, (iii) policies and KPIs, (iv) communication with investors.
5. Trigger events — Upcoming MTM, earnings, or governance-report cycles where the disclosure should be refreshed.

We will publish a fuller version of this dashboard as a live component on jpinv.com, refreshed monthly when the JPX list is updated. The Theme 4.3 page on jpinv.com is the maintained version.

Why publication is sharper than regulation

It is worth pausing to note how unusual TSE's enforcement model is. A traditional regulator would say: "If you do not disclose by date X, you will be fined Y." TSE said: "We will publish a list every month of who has and has not disclosed."

The model works because the underlying audience — Japanese institutional investors, foreign asset managers, activists — already cared. TSE did not need to invent enforcement; it merely needed to make participation visible. The list does three things that regulation cannot:

It is cheap. TSE does not need to investigate, prosecute, or sanction. A spreadsheet update each month is the entire enforcement infrastructure.

It is uniformly informative. Every market participant gets the same information at the same time. There is no information asymmetry between large and small investors about who has disclosed.

It is self-escalating. As more peers disclose, the marginal cost of non-disclosure rises — both reputationally and as an activist target. Companies that disclosed early in 2023 created the social proof for the laggards. The 93% Prime Market disclosure rate of March 2026 is the natural consequence of a self-escalating norm, not a regulatory deadline.

This is the model the FSA and METI are now studying for application to other governance areas — most visibly English disclosure (Theme 5.1), where the same monthly-list mechanism has been adopted for the April 2025 mandate.

The companion documents: list + booklets

The list does not stand alone. It is anchored by a growing library of companion documents, each of which serves a specific function:

• "Key Points and Examples Considering the Investor's Point of View" (Feb 2024; updated late 2025) — the qualitative companion. 55 named good-practice case studies showing what TSE considers a substantive disclosure. Covered in Post 4.2.
• "Cases Where Companies Are Not Aligned With Investors' Perspectives" (Nov 2024) — the 10 archetypal misalignment patterns. Covered in Post 4.4.
• "Case Studies of Companies' Initiatives Toward Issue Resolution" (Dec 2025) — process-focused case studies on how companies actually embedded cost-of-capital thinking in their organisations. Covered in Post 4.5.
• "Update to the Request" (Apr 28, 2026) — the formal pivot to "from disclosure to implementation." Covered in Post 4.5.

The four-document architecture is itself instructive. The list publishes who is engaged. The Key Points booklet shows what good looks like. The Misalignment booklet shows what unconvincing looks like. The Issue Resolution case studies show how the work actually gets done. The Update sets the next bar. Each layer reinforces the others; TSE has built a coherent soft-enforcement architecture rather than a single document.

What this means for IR

1. Confirm your status on the list — monthly. Before any investor meeting, check that your company appears on the latest list with the status you expect. Discrepancies (e.g., your CG Report disclosure has not yet been reflected in the TSE list) should be raised with TSE immediately.
2. Never sit in "Under Consideration" past 5 months. The January 2025 six-month rule converts that status into "Not Disclosed." Treat 5 months as your internal deadline; build a buffer.
3. Update your disclosure at least annually. A "Latest update" date older than 12 months is a flag for sophisticated investors. Tie your disclosure refresh to the CG Report annual cycle or the MTM revision cycle — whichever is more frequent.
4. Benchmark against named peers, not industry averages. Build a peer list of 10–20 companies investors would compare you to and compare your status, update frequency, and disclosure quality against theirs. Industry averages obscure the right comparison.
5. Treat the list as a disclosure system, not a one-off filing. The list, the four booklets, and the Update form a coherent expectation set. Your disclosure should explicitly reflect awareness of each of them — what TSE considers good, what TSE considers misaligned, and what TSE expects next.

Sources & further reading

Primary - TSE news release (Oct 26, 2023) announcing the list: https://www.jpx.co.jp/english/news/1020/20231026-01.html - TSE news release (Jan 15, 2024) — first list published: https://www.jpx.co.jp/english/news/1020/20240115-01.html - Follow-Up List hub (EN): https://www.jpx.co.jp/english/equities/follow-up/nlsgeu000006xn3l.html - Latest list PDF (EN): https://www.jpx.co.jp/english/equities/follow-up/nlsgeu000006xn3l-att/follow_up_list_e.pdf - "Status of Disclosure" (Mar 13, 2026): https://www.jpx.co.jp/english/equities/follow-up/uorii50000004sse-att/dh3otn0000006l3i.pdf

Supporting - "Key Points and Examples" (Feb 2024 first edition, EN PDF): https://www.jpx.co.jp/english/news/1020/u5j7e50000001bqd-att/240201en.pdf - TSE news release (Feb 1, 2024) on the Key Points booklet: https://www.jpx.co.jp/english/news/1020/20240201-01.html - TSE news release (Nov 21, 2024) on "Cases Where Companies Are Not Aligned": https://www.jpx.co.jp/english/news/1020/20241121-01.html - TSE news release (Dec 26, 2025) on "Case Studies of Initiatives Toward Issue Resolution": https://www.jpx.co.jp/english/news/1020/20251226-01.html - "Summary of Discussions of the Follow-up Council" (EN): https://www.jpx.co.jp/english/equities/follow-up/01.html

Cross-references

• Theme 3.3 — The March 2025 Cliff: end of transitional measures
• Theme 4.1 — PBR < 1 Is Not a Target — It's a Verdict
• Theme 4.2 — WACC, ROIC, Equity Spread: the new vocabulary
• Theme 4.4 — The Seven Sins of Cost-of-Capital Disclosure
• Theme 4.5 — From Disclosure to Implementation
• Theme 5.1 — The English disclosure mandate (same publication-as-enforcement model)