The Rise of Multiple Voting Shares and Loyalty Voting, 2005–2025

Across 28 selected jurisdictions, the 20-year shift away from banning control-enhancing voting structures is clear and unmistakable — even with simplified jurisdictional groupings.

Analysis: Prof. Marco Ventoruzzo (Bocconi University)  ·  Visualisation: ECGI
Selected jurisdictions (28): Australia; Belgium; Brazil; California (US); Chile; China; Delaware (US); France; Germany; Greece; Hong Kong; India; Indonesia; Ireland; Israel; Italy; Japan; Malaysia; Netherlands; Nevada (US); New York (US); Portugal; Singapore; South Africa; South Korea; Spain; Texas (US); United Kingdom.

This visualisation shows a stacked area chart tracking how many of 28 selected jurisdictions allowed multiple voting shares or loyalty voting, versus banning both, at five-year intervals from 2005 to 2025. A full data table is available below the chart. Key legislative milestones are annotated on the chart and also listed in text form below the data table.

Stacked area chart with three bands. The bottom red band shows jurisdictions banning both multiple voting shares and loyalty voting: 16 in 2005, 16 in 2010, 14 in 2015, 9 in 2020, and 4 in 2025. The middle orange band shows jurisdictions where multiple voting shares are allowed: 2 in 2005, 1 in 2010, 3 in 2015, 7 in 2020, and 11 in 2025. The top yellow band shows jurisdictions where loyalty voting is allowed but multiple voting shares are not: 1 in 2005, 2 in 2010, 2 in 2015, 3 in 2020, and 4 in 2025. The total across all three bands is approximately 19 jurisdictions at each data point. Full data in the table below.

Data points at 2005, 2010, 2015, 2020 and 2025. Counts cover a defined subset of the 28 selected jurisdictions (listed above), reflecting those with a clear statutory classification at each time point. National regimes differ significantly in voting ratios, sunset clauses and minority safeguards. Source: Prof. Marco Ventoruzzo analysis; for European jurisdictions see also Hopt & Kalss, ECGI Working Paper 786/2024.

View data table for this chart
Year Ban on both MVS & loyalty voting MVS allowed Loyalty voting allowed Total classified
2005 16 2 1 19
2010 16 1 2 19
2015 14 3 2 19
2020 9 7 3 19
2025 4 11 4 19

Note: counts reflect jurisdictions (listed in the credit above) with a clear statutory classification at each data point; jurisdictions with ambiguous or transitional regimes at a given date are not included in the total. For current country-level detail on European jurisdictions see: Hopt & Kalss, “Multiple-voting shares in Europe: A comparative law and economic analysis,” ECGI Law Working Paper 786/2024 (annex, pp. 65–66), ssrn.com/abstract=4887591.

Key observations
Dramatic shift in 20 years
16 → 4 bans
The number of jurisdictions banning both MVS and loyalty voting fell from 16 in 2005 to just 4 by 2025 — a drop of 75% in two decades.
MVS liberalisation accelerates
2 → 11 jurisdictions
Jurisdictions allowing multiple voting shares grew from 2 in 2005 to 11 by 2025, with the sharpest acceleration between 2015 and 2020 as regulatory competition intensified.
Key legislative milestones
2014–2024
France’s 2014 Florange Act made loyalty shares the default. Italy introduced MVS for unlisted companies in 2014. Germany reversed its 1937 ban in 2023. The EU MVS Directive followed in 2024.
The devil is in the details
Divergent regimes
While the trend is clear, specific national rules on voting caps, sunset clauses, holding periods and minority safeguards vary enormously across jurisdictions.
Legislative milestones annotated on chart
2014 France — Florange Act makes loyalty shares (double voting after 2-year holding period) the statutory default for listed companies.
2014 Italy — Decreto Competitività (Law 116/2014) introduces multiple voting shares for unlisted companies (up to 3 votes per share) and loyalty shares for listed companies (double voting after 24-month holding period).
2018 Hong Kong and Singapore — both exchanges open their markets to dual-class share IPOs, reversing long-standing prohibitions, partly in response to competition for tech listings.
2023 Germany — Future Financing Act (Zukunftsfinanzierungsgesetz) reverses the 1937 ban on multiple voting shares, permitting them with a maximum 10-votes-per-share cap and safeguards for minority shareholders.
2024 European Union — MVS Directive (2024/2810) requires all member states to permit multiple voting share structures for companies seeking admission to multilateral trading facilities (MTFs), as part of the broader EU Listing Act.