ISA eligibility assessment note

Japan: Tokyo Stock Exchange market reorganisation and HMRC RSE mapping

Oppl’s position on how HMRC’s stale Japan recognised stock exchange table should be interpreted following the Tokyo Stock Exchange move from Main Board / Mothers structures to Prime, Standard and Growth.

Jurisdiction: Japan Exchange: Tokyo Stock Exchange Recognition date: 22 October 1970 Prepared by: Oppl

1. Summary position

Oppl treats ordinary shares formally listed on the Tokyo Stock Exchange Prime Market, the Tokyo Stock Exchange Standard Market and the Tokyo Stock Exchange Growth Market ('Mothers board') as likely ISA eligible, subject to normal issuer and security-level checks.

Reason: HMRC previously accepted Mothers as a listed market of the Tokyo Stock Exchange. Mothers was the former TSE growth-style market and now sits within the new Prime / Standard / Growth structure.

Proof point: HMRC’s Japan table recognises the Tokyo Stock Exchange and lists the Main Board and Mothers Market as listed markets. JPX confirms that the TSE market structure was reorganised into Prime, Standard and Growth on 4 April 2022.

2. HMRC’s current Japan table

HMRC recognises several Japanese exchanges, including the Tokyo Stock Exchange. The Japan recognition date is 22 October 1970.

HMRC recognised exchange	HMRC listed market position
Tokyo Stock Exchange	Main Board and Mothers Market listed
Nagoya Stock Exchange	Main market listed
Osaka Stock Exchange	Main market, 1st and 2nd sections listed
Sapporo Securities Exchange	Main market listed

Proof point: HMRC’s own table expressly treats both the TSE Main Board and Mothers Market as listed markets. This is the relevant starting point for mapping the old TSE names to today’s Prime, Standard and Growth markets.

3. What changed in Japan

The Tokyo Stock Exchange changed its market structure on 4 April 2022. Before the reorganisation, TSE included the First Section, Second Section and Mothers. These now map into the modern Prime, Standard and Growth market structure.

Old main market

First Section

Main listed companies.

Old growth market

Mothers

Emerging / growth companies.

New structure

Prime · Standard · Growth

Modern TSE market divisions.

Proof point: JPX describes the change as a reorganisation of the Tokyo Stock Exchange market structure, not the creation of an unrelated exchange.

4. Old-to-new segment mapping

Old HMRC / TSE reference	New TSE segment	Oppl ISA treatment	Confidence
TSE Main Board / First Section	Prime Market	Eligible	High
TSE First Section / some Second Section companies	Standard Market	Eligible	High
TSE Second Section	Standard Market	Eligible	High
Mothers	Growth Market	Eligible	High

5. Prime, Standard and Growth conclusions

Prime Market

Oppl status: Eligible. Confidence: High.

Prime is the clearest case. It is the top successor market within the Tokyo Stock Exchange’s reorganised structure and maps clearly to the old Main Board / First Section concept.

Standard Market

Oppl status: Eligible. Confidence: High.

Standard is also a formal listed market of the Tokyo Stock Exchange. It contains companies that sit below Prime but remain within the TSE listed equity framework.

Growth Market

Oppl status: Eligible. Confidence: High.

Growth is the area where the HMRC table is most obviously stale. HMRC has not yet named “TSE Growth Market”, but it did expressly list Mothers as a listed TSE market. We have assessed that Growth should therefore be similarly treated as Eligible.

Position: a company formally listed on TSE Growth is likely ISA eligible where the instrument is an ordinary share and the listing is a formal TSE listing.

6. Practical Oppl rule

Japanese market evidence	Oppl treatment
Listed on TSE Prime	Pass
Listed on TSE Standard	Pass
Listed on TSE Growth	Pass as 'likely' maps to Mothers Growth logic

7. Conclusion

HMRC’s recognised stock exchange table for Japan has not been fully updated for the Tokyo Stock Exchange’s 2022 market restructuring. HMRC still refers to the TSE Main Board and Mothers Market, while TSE now operates Prime, Standard and Growth.

Oppl treats this as a stale naming issue rather than a change in recognised exchange status. JPX confirms that the Tokyo Stock Exchange market structure changed to Prime, Standard and Growth on 4 April 2022. HMRC had already accepted the TSE Main Board and Mothers Market as listed markets.

Oppl therefore treats TSE Prime, TSE Standard and TSE Growth as eligible listed markets of the recognised Tokyo Stock Exchange.

This conclusion applies to ordinary shares formally listed on the relevant Tokyo Stock Exchange equity markets. It remains subject to Oppl’s normal issuer, security type and instrument-level checks.

8. Sources

HMRC recognised stock exchange tablesJapan recognition date and listed market treatment for TSE Main Board and Mothers.
Open source

JPX market structure improvementsJPX explanation of the reorganisation into Prime, Standard and Growth.
Open source

JPX market segments backgroundJPX description of the pre-reorganisation structure and rationale.
Open source

Winston & Strawn overviewMarket reorganisation overview and high-level description of Prime, Standard and Growth.
Open source

Baker McKenzie Cross-Border Listings GuideIndependent summary of TSE restructuring into Prime, Standard and Growth.
Open source