Balancing Founder Control and Investor Protection? A Comparative Study of DualClass Share Structures in the United Kingdom and China

In recent years, both the United Kingdom (UK) and China have relaxed regulatory restrictions on dual-class share (DCS) structures in an effort to enhance the attractiveness of their capital markets. However, this shift has also raised concerns about potential abuses of control and its implications for investor protection. From a comparative law perspective, this paper examines the listing regulatory frameworks governing DCS structures in both jurisdictions and explores the institutional logic and market dynamics that shape their respective approaches. Through a detailed analysis of the risks and limitations in current regulatory practices, it argues for a more balanced regulatory model that reconciles the need for control stability with the imperative of safeguarding investor interests. The paper further contends that the regulatory framework for DCS structures should remain adaptive, permitting dynamic adjustments in response to evolving institutional environments and market developments.