Percentages travel, names stay home: only Japan and Taiwan reliably put major customers on the record

Asked (summary):For the US, China, Hong Kong, Japan, Korea, Taiwan, Canada, Singapore and Europe, what are the disclosure rules and thresholds for naming major customers and suppliers in public securities filings, where does practice anonymise names even when a share is disclosed, and one example filing per rule or practice.

The comparison covers all nine requested markets, each with one selected rule and one selected example filing — 19 evidence rows in total, with the standalone IFRS 8 background row folded into the Europe column. Thresholds are percentages of revenue or purchases; sources span official rule texts, exchange sites, filing repositories and commentary.

Rule and naming matrix, nine markets

NAME identity mandatory   MAY ANONYMISE identity may be withheld or coded   PERCENTAGES ONLY rule asks for shares, not identity

Market
Customer rule & threshold
Supplier rule & threshold
Identity
Prospectus / ad-hoc
Example filing
US
Reg S-K Item 101: material dependence on one or a few major customers; the explicit 10% naming formulation was dropped in 2020 for larger issuers. ecfr.gov
Names of principal suppliers required where material (Item 101(h), smaller reporting companies).
MAY ANONYMISE
Suppliers may be named; customers often not. GAAP segment notes give 10%+ customer revenue without identity.
Annual report (10-K) business description; segment note runs in parallel.
ScanSource 10-K: no single customer over 5% of net sales FY2017 — no names. scansource.com
China
Annual report: share of sales to the top five customers is mandatory; per-customer identity is encouraged but voluntary (Annual Report Standards No. 2, Art. 21). link.springer.com
Top-five supplier / prepayment balances disclosed, often by code (单位 1–5).
MAY ANONYMISE
Coded labels (客户 1–5) are common in annual and interim reports.
IPO prospectus and exchange review can demand more than the annual-report baseline.
ST Yunsheng 2020 interim: top five receivables 67.14%, all coded 客户 1–5. static.sse.com.cn
Hong Kong
Appendix D2 ¶31: % of revenue from the largest and five largest customers; if the top five are below 30%, a statement to that effect may replace details. en-rules.hkex.com.hk
Same rule for % of purchases from the largest and five largest suppliers.
PERCENTAGES ONLY
Annual reports give percentages plus director / 5%-shareholder interests, not names.
IPO guidance covers the five largest customers and suppliers; only connected parties are named.
ISDN prospectus: five largest suppliers up to 58.3% of purchases, unnamed except connected Maxon entities. links.sgx.com
Japan
Annual securities report (FIEA Art. 24): business partners at 10%+ of revenue disclosed with amounts and percentages. edinetdb.com
No parallel supplier percentage threshold.
NAME
Counterparty names are disclosed in practice.
Annual securities report is the operative filing.
Japan Tobacco names Megapolis Group: ¥268.6bn (12.7%) FY3/2013, ¥358.0bn (14.9%) FY3/2014. jti.co.jp
Korea
K-IFRS 10% customer note in financial statements; single sale/supply contract filings must give contract amount and ratio to revenue. seoulmarkets.com
Supply contracts fall under the same single-contract filing rule.
MAY ANONYMISE
Counterparty may be withheld on its business-confidentiality request; the ratio is still published.
Ad-hoc contract filings (DART) sit beside the financial-statement note.
Spear (KRX 347700): ₩11.58bn special-alloy contract, 12.10% of revenue, counterparty withheld. seoulmarkets.com
Taiwan
10% sales / procurement disclosure practice; financial-institution prospectuses must list principal obligors at 5% of net worth or top-50 credit customers, by name. twse-regulation.twse.com.tw
Reliance on limited equipment and sole-source raw-material suppliers described in prospectuses.
NAME
A code is allowed only for contractual confidentiality or a non-related individual.
Prospectus regulations carry the explicit naming mandates.
TSMC prospectus: ten largest customers 52% / 53% of net sales 2005–06, major customers named. sec.gov
Canada
IFRS 8: fact and amount of any 10%+ external customer in financial statements. accountingexamsmastery.ca
AIF (NI 51-102F2) covers materially dependent sale / purchase contracts; no universal naming percentage.
MAY ANONYMISE
Identity may be omitted; letter labels are common practice.
AIF economic-dependence disclosure sits beside the IFRS note.
Premium Brands MD&A 2024: Customer A 14.4%, Customer B 13.5% of revenue — anonymised. sedarplus.ca
Singapore
Prospectus: issue manager assesses material dependence on customers by dollar value (ABS guidelines ¶3.2(d)); financial statements apply the IFRS 8 10% test. api2.sgx.com
Same material-dependence assessment for suppliers; no universal numeric naming threshold.
MAY ANONYMISE
Dependence is described; identities are not required by a numeric rule.
Prospectus due diligence vs IFRS 8 note give different outcomes.
ST Group FY2026: no customer reached 10% of revenue, so none identified. links.sgx.com
Europe
IFRS 8.34 as EU-endorsed (Reg (EU) 632/2010): fact, amount and segment for any 10%+ customer — but identity need not be disclosed. legislation.gov.uk
No IFRS percentage rule for supplier concentration.
PERCENTAGES ONLY
The standard expressly waives identity; national prospectus rules may add more.
Prospectus Regulation (EU) 2017/1129 business-risk sections can add disclosure.
Verallia 2025 URD: top ten customers under 16%, largest about 4% of revenue — unnamed. companiesmarketcap.com

What the matrix cannot say alone

A disclosed percentage rarely means a disclosed name: seven of nine markets let issuers anonymise or omit the counterparty even while printing its revenue share. sedarplus.ca
Japan is the strongest naming contrast: Japan Tobacco identifies Megapolis Group at 12.7% and 14.9% of revenue in consecutive annual securities reports. jti.co.jp
Hong Kong annual reports can replace all top-five customer and supplier detail with a single statement when the combined share is under 30%. en-rules.hkex.com.hk
Korea publishes the contract-to-revenue ratio (12.10% for Spear) while withholding the buyer on a confidentiality request — concentration without identity by design. seoulmarkets.com

Read the rules carefully

  • Accounting-standard disclosure and securities / business-description disclosure coexist and can yield different naming outcomes: an IFRS 8 note can stay anonymous while a prospectus names the same customer.
  • “Europe” is not one securities-law country: EU-endorsed IFRS 8.34 is the common financial-statement baseline; national prospectus and business-risk rules may add disclosure. IFRS 8 has no supplier percentage rule.
  • The current US Regulation S-K Item 101 is principles- and materiality-based for larger issuers; the superseded explicit 10% naming formulation (replaced in 2020) is not the current universal rule.
  • Hong Kong’s annual-report Appendix D2 rule and its IPO disclosure practice differ; China’s annual-report top-five baseline differs from IPO and exchange-review practice; Canada’s IFRS note differs from NI 51-102F2 AIF economic-dependence disclosure.
  • The Korea rule and example rest on a detailed secondary report identifying DART receipt no. 20260923900306, not a directly fetched DART page. Some selected examples are older (Japan Tobacco FY3/2013–14, TSMC 2005–06, ScanSource FY2017) but remain useful illustrations; filing dates are given where present.

Market cards: citation and example filing

US

Citation 17 CFR § 229.101 (Item 101 of Regulation S-K), paragraph (h)(4)(v) and (h)(4)(vi) · ecfr.gov

Rule sources and availability of raw materials and the names of principal suppliers, and dependence on one or a few major customers

Example — ScanSource, Inc. No single customer accounted for more than 5% of our total net sales for the fiscal year ended June 30, 2017 scansource.com

China

Citation Standards for Contents and Formats of Information Disclosure by Companies Publicly Offering Securities No. 2 - Contents and Formats of Annual Reports (revised edition in 2012), Article 21 · link.springer.com

Rule Listed firms must disclose in their annual reports the proportion of sales to their top five customers to total annual sales (mandatory minimum); disclosure of the identity of and sales to each of the top five customers separately is encouraged but voluntary.

Example — 运盛(成都)医疗科技股份有限公司(ST 运盛,公司代码 600767) Top five receivable debtors total 53,903,853.93 yuan, 67.14% of ending accounts receivable, the largest (客户 1) 24,507,800.00 yuan, 30.53%, fully provided for; top five prepayment objects total 12,487,034.75 yuan, 94.45% of prepayments, the largest (单位 1) 6,401,000.00 yuan, 48.41%; in both tables… static.sse.com.cn

Hong Kong

Citation HKEX Exchange Listing Rules Appendix D2 (Disclosure of Financial Information), paragraph 31 · en-rules.hkex.com.hk

Rule A listed issuer must disclose the percentage of purchases attributable to the largest supplier and to the 5 largest suppliers combined, the percentage of revenue from sales of goods or rendering of services attributable to the largest customer and to the 5…

Example — ISDN Holdings Limited five largest customers: approximately 12.1%, 9.7%, 7.5% and 10.4% of total revenue and largest customer approximately 4.0%, 2.5%, 2.2% and 3.1% of total revenue for the three years ended 31 December 2013, 2014 and 2015 and the six months ended 30 June 2016; five largest suppliers: approximately… links.sgx.com

Japan

Citation Main Customers Disclosed Ranking — Japanese Listed Companies Top 100 (industry filter, 5-year history) | EDINET DB · edinetdb.com

Rule Listed companies disclose the number of major customers in the 'Major Customers' section of their latest annual report; companies without qualifying customers have no disclosure obligation.

Example — JAPAN TOBACCO INC. Business partner Megapolis Group: revenue of 268.6 billion yen (12.7%) for the fiscal year ended March 31, 2013 and 358.0 billion yen (14.9%) for the fiscal year ended March 31, 2014; the JT Group's international tobacco business sells products to Megapolis Group, which runs logistics and wholesale… jti.co.jp

Korea

Citation Korea's single sale/supply contract disclosure rule · seoulmarkets.com

Rule Under Korea's single sale/supply contract disclosure rule, a company must report the contract content, the contract amount, the ratio to its revenue, and the type of goods, but may withhold the counterparty's name (and the counterparty's business) when the…

Example — Spear (KRX: 347700) Single sale/supply contract disclosure (rcept_no 20260923900306) for a special-alloy supply contract ('특수합금 공급계약') worth ₩11,576,320,000, equal to 12.10% of revenue, with the counterparty withheld and described only as '미국 글로벌 우주항공 발사업체' (a US global aerospace launch company) under a… seoulmarkets.com

Taiwan

Citation Article 20, Section 2 (Overview of Operations), Subparagraph 2, Item 3 of the Regulations Governing Information to be Published in Financial Institution Prospectuses for Offering and Issuance of Securities (2017.03.03), prescribed under Article 30, paragraph 2 of the Securities and Exchange Act (Attachment 42) · twse-regulation.twse.com.tw

Rule The prospectus of a financial institution must list the principal obligors — the names of the customers to whom the amount of credit extended represents 5% or more of the company's net worth or who rank among the top fifty customers being extended credit,…

Example — Taiwan Semiconductor Manufacturing Company Limited While we generate revenue from hundreds of customers worldwide, our ten largest customers accounted for 52% and 53% of our net sales in 2005 and 2006, respectively, and our largest two customers accounted for approximately 10% and 8% of our net sales in 2006. sec.gov

Canada

Citation International Financial Reporting Standards (IFRS); Accounting Standards for Private Enterprises (ASPE) · accountingexamsmastery.ca

Rule Entities are required to disclose information about major customers, helping users of financial statements understand the extent of the company's reliance on key customers

Example — Premium Brands Holdings Corporation The Company's sales to a relatively small group of large-format food retailers accounted for approximately 41.7% of its total revenue for 2024 with one such retailer (Customer A) accounting for approximately 14.4% of its total revenue for 2024; the Company also sells, directly or indirectly, to a… sedarplus.ca

Singapore

Citation ABS Listings Due Diligence Guidelines, Section II Recommended Procedures, paragraph 3.2(d) (Major suppliers and customers) · api2.sgx.com

Rule The issue manager should assess whether the Issuer is materially dependent on any particular supplier or customer or groups of suppliers or customers, taking into consideration the proportion (by dollar value) of purchases from the Issuer's suppliers to total…

Example — ST Group Food Industries Holdings Limited No single customer contributed 10% or more to revenue for FY2026 and FY2025; no counterparty is identified because no customer met the threshold links.sgx.com

Europe

Citation paragraph 34 of the IFRS as amended by Commission Regulation (EU) No 632/2010 · legislation.gov.uk

Rule the fact that revenues from a single external customer amount to 10 per cent or more of revenues, the total amount of revenues from each such customer, and the identity of the segment or segments reporting the revenues

Background: the entity-wide IFRS 8 disclosures (paras 31–34) apply across Europe, Canada and Singapore; the 10% customer test must be reported on IFRS measures, with no supplier equivalent. icas-com.uksouth01.umbraco.io

Example — Verallia In its 2025 Universal Registration Document, Verallia discloses that its customer base is not very concentrated, with the top ten customers representing less than 16% of consolidated revenue and the most significant customer approximately 4% of consolidated revenue for the year ended 31 December… companiesmarketcap.com

All 19 evidence rows

MarketRowFiling typeThresholdNaming ruleIssuerSource
CanadaRulefinancial statements10% or more of the entity's total revenues from transactions with a single external customermay be omitted in practice — companies may be reluctant to disclose the identity of major customers—accountingexamsmastery.ca
CanadaExample filingannual securities report (annual MD&A filed on SEDAR+)—counterparty names are anonymised in the disclosure, identified only as Customer A and Customer BPremium Brands Holdings Corporationsedarplus.ca
ChinaRuleannual reportTop five customers; ratio of sales to these customers to total annual sales (no percentage threshold stated)Counterparty names may be omitted — only aggregate sales to the top five customers and the ratio to total annual sales are…—link.springer.com
ChinaExample filingfinancial statementsTop five counterparties by ending balance (前五名); no numeric percentage materiality threshold is stated in the textCounterparties need not be named; they are identified only by coded labels (客户 1–客户 5 for receivable debtors, 单位 1–单位 5 for…运盛(成都)医疗科技股份有限公司(ST 运盛,公司代码 600767)static.sse.com.cn
EuropeRule—10 per cent or more of an entity’s revenuesneed not be named — the entity need not disclose the identity of a major customer or the amount of revenues that each segment…—legislation.gov.uk
EuropeExample filingannual reportTop ten customers represent less than 16% of consolidated revenue; the most significant customer represents…may be omittedVeralliacompaniesmarketcap.com
Hong KongRuleannual reportIf the percentage attributable to the 5 largest suppliers combined or to the 5 largest customers combined is less than…may be omitted—en-rules.hkex.com.hk
Hong KongExample filingprospectus—counterparties need not be named; identities are given only where a counterparty is a connected/related party (Maxon Motor AG is…ISDN Holdings Limitedlinks.sgx.com
IFRSRuleannual financial statementsmajor customers accounting for more than 10% of revenues——icas-com.uksouth01.umbraco.io
JapanRuleannual securities reporttypically customers representing >=10% of revenue——edinetdb.com
JapanExample filingannual securities report10% or more of JT Group's total revenuecounterparty names must be disclosedJAPAN TOBACCO INC.jti.co.jp
KoreaRuleother filing—may be omitted—seoulmarkets.com
KoreaExample filingother filing12.10% of revenuecounterparty name withheld (anonymised) at the counterparty's business-confidentiality requestSpear (KRX: 347700)seoulmarkets.com
SingaporeRuleprospectus———api2.sgx.com
SingaporeExample filingfinancial statements10% or more of revenue—ST Group Food Industries Holdings Limitedlinks.sgx.com
TaiwanRuleprospectus5% or more of the company's net worth, or ranking among the top fifty customers being extended credit, whichever is…Counterparty names must be disclosed—twse-regulation.twse.com.tw
TaiwanExample filingprospectusTen largest customers: 52% of net sales in 2005 and 53% in 2006; largest two customers: approximately 10% and 8% of net…counterparty names are disclosedTaiwan Semiconductor Manufacturing Company Limitedsec.gov
USRule—materiality standard — to the extent material to an understanding of the smaller reporting companyidentity must be named for suppliers — the names of principal suppliers must be given; no naming requirement is stated for major…—ecfr.gov
USExample filingannual securities reportmore than 5% of total net salesno customer names disclosed because no single customer exceeded the 5% thresholdScanSource, Inc.scansource.com

Method: 19 evidence rows — one rule row and one example-filing row per the nine requested markets plus one IFRS 8 background row, folded into Europe. Thresholds measure counterparty share of revenue or purchases (IFRS 8 test: 10% of revenue). Full rule texts and disclosures are shortened for space; each row links its source. Korea evidence is a secondary report citing DART receipt no. 20260923900306.

This report was generated automatically by Keenable SELECT at a user's request, from publicly available web sources linked herein. Keenable does not review, verify, or endorse its contents and makes no representation as to accuracy, completeness, or timeliness; AI-based extraction may contain errors. Nothing in this report is investment, legal, financial, or other professional advice. All trademarks and referenced content remain the property of their respective owners; no affiliation or endorsement is implied. To report an error, rights concern, or request removal: legal@keenable.ai.

Keenable SELECTAsk your own question
Made with Keenable SELECT