The registration-based IPO system reform centered on the new Securities Law places information disclosure obligations at the core of securities regulation.The determination of the subject of information disclosure obligations and the corresponding personnel responsibilities become the key to the new system.Under the authorization of the Securities Law,the conceptual connotation of information disclosure obligors has been continuously interpreted in a way of continuous expansion.At the same time,the personal liabilities for information disclosure violations have also been further strengthened.However,in light of this trend,the reasonability of the subjects involved in regulatory expansion needs to be carefully examined.Based on the notion of compatibility of the securities liability system with securities activities,it should be clarified that the issuer is the narrowly defined duty-bearer for information disclosure who bears strict liability for information disclosure.Other subjects with different types of obligations to information disclosure should undertake different degrees of fault liability based on their violation of corresponding obligations.
registration-based IPO systeminformation disclosuresubject of liabilityregulatory expansion