Can a company issue exchangeable bonds that are exchangeable into its own treasury shares?

As of October 2026, it cannot. According to the Financial Services Commission, the amended Commercial Act completely prohibits the issuance of exchangeable bonds (EBs) whose underlying securities are treasury shares, and accordingly the related provisions were deleted by an amendment to the Enforcement Decree of the FSCMA that took effect on June 30, 2026, with subordinate rules such as the Regulations on Securities Issuance and Disclosure, etc.

revised at the same time. The aim is to prevent exchangeable bonds from being used as an expedient to circumvent the obligation to cancel treasury shares. For details such as the treatment of bonds already issued, check the relevant laws and the company's disclosures.