Key points
- A US rule has barred SK Hynix from announcing a buyback or special dividend since its Nasdaq listing on July 10. The 25 days run out on August 4 in Korea.
- CFO Kim Woo-hyun told the July 29 earnings call the company is reviewing shareholder returns but is restricted from saying more.
- SK Hynix held 87.96 trillion won ($61.5B USD) in cash at the end of the quarter, against 34.94 trillion won ($24.4B USD) at the end of 2025.
- A June report put this year's return near 100 trillion won ($70B USD) with a 40 trillion won ($28B USD) buyback. The company said it has not reviewed those figures.
- Samsung has no such restriction and also gave no numbers. CFO Park Soon-chul said the board is discussing a special dividend and asked shareholders to wait.
SK Hynix is sitting on 87.96 trillion won ($61.5B USD) of cash, and it hasn't been allowed to tell shareholders what it plans to do with any of it. The reason is an American rule. It expires on August 4 in Korea, 25 days after the company listed on the Nasdaq.
The rule is an ordinary one. A company that sells new shares in a US offering has to keep handing out its prospectus for 25 calendar days. The count starts on the first day of trading and it includes weekends. Inside that window the company can't announce anything material that wasn't in the prospectus. A large buyback would count. So would a special dividend. Doing it anyway invites a class action under US securities law. The same rule keeps the banks that ran the offering from publishing research.
SK Hynix's American depositary receipts started trading on July 10 US time. Twenty-five days later is August 4 in Seoul.
That's why the July 29 earnings call went the way it did. Kim Woo-hyun, the chief financial officer, got the shareholder return question and gave an answer that explained itself.
"We are fully aware of the market's high level of interest, and we are currently reviewing various methods of additional shareholder returns," he said.
Then he said why that was all he could give them. "Because of regulatory and procedural restrictions related to the ADR offering, there are certain limits on my saying anything further at this point about new material information that was not disclosed during the offering process."
He'd been more specific in April, before the listing. Back then he said the company would "actively review additional shareholder return methods such as share buybacks and cancellations alongside the dividend, and prepare an implementation plan within the year."
What the market has priced in
The number everyone works from came out in June. Hankyung reported that SK Hynix was preparing a package near 100 trillion won ($70B USD) for the fourth quarter. The buyback piece alone was put at 40 trillion won ($28B USD). That's a little over 2% of the shares, close to the volume of new stock the company issued for the Nasdaq listing.
SK Hynix denied it. The company said it's reviewing various shareholder return measures. Then it added that it "has not reviewed the specific details mentioned in the report, including the size of the shareholder return."
The cash is real either way. SK Hynix ended the second quarter with 87.96 trillion won on hand. At the end of 2025 it was 34.94 trillion won ($24.4B USD). Borrowings came down to 18.59 trillion won from 22.25 trillion. The standing policy is to return half of the free cash flow the company piles up from 2025 through 2027. Last year's total was 2.1 trillion won ($1.5B USD) and the dividend was 3,000 won ($2.10 USD) a share.
Samsung has no such excuse
Samsung Electronics isn't listed in the United States. It had no quiet period to sit through. It held its own call on July 30, one day after SK Hynix, and it didn't give a number either.
Park Soon-chul, Samsung's chief financial officer, said the existing plan stands. "As I said last quarter, we plan to carry out the three-year shareholder return policy as promised," he told analysts.
He said work on the next one is under way. "The board and management are currently holding in-depth discussions on the specific implementation of a shareholder return policy that includes a special dividend, and on the next policy."
Then he asked for patience. "We will share it soon with the shareholders who have trusted us and waited," he said.
What Samsung has actually declared is the quarterly dividend. It's 374 won ($0.26 USD) a share, which comes to about 2.46 trillion won ($1.7B USD). The three-year policy running through this year commits the company to 9.8 trillion won ($6.9B USD) of regular dividends a year. The quarter itself was the best in Samsung's history, 171.5 trillion won of revenue and 89.5 trillion won of operating profit.
The other reading
Not everyone thinks there is a finished plan waiting to be announced.
Han Dong-hee, an analyst at SK Securities, reads the wording as a signal. He said SK Hynix's recent comments are "evidence that it is sufficiently aware of the market's demand for shareholder returns and of the need for them."
SK Hynix put it differently this week. An official called the comments a statement of principle, meaning a review is possible if the market asks for one. The official then said that "no specific shareholder return plan, including a stock split, has been established or finalized at the management or board level at this time."
Both of those can be true at once. A company can know what the market wants and still have no board resolution. The difference matters as soon as the restriction lifts. One reading puts an announcement inside a few days. The other puts it whenever the board gets there, which could be the third quarter results in late October.
Where this leaves the shares
Both stocks are carrying a lot right now. On July 30 Samsung sat 44.7% below its high of 374,500 won. SK Hynix sat 55.7% below 2,987,000 won. Monday's close put Samsung at 239,500 won ($167 USD) and SK Hynix at 1,567,000 won ($1,095 USD). Both fell about 8.8% that session, handing back a piece of Friday's record rally.
Chairman Chey Tae-won already moved on his own. He bought 3,620 SK Hynix shares on July 30, about 4.79 billion won ($3.3M USD) worth. That was the most he could buy without crossing the 50 billion won line that would've forced him to disclose it in advance.
The analysts haven't settled either. The average target across 16 domestic brokerages is 3.22 million won. Getting to that average took 8 of them cutting and 2 raising in the same stretch.
The restriction expires either way. Twenty-five days from July 10, weekends counted, lands on Tuesday.
Sources
- 서울경제, 2026년 7월 30일, on the 25-day prospectus delivery rule, the August 4 expiry and the brokerage target average
- 뉴시스 and FETV, 2026년 7월 29일 and 30일, for Kim Woo-hyun's remarks on the July 29 call and the April call, and the quarter-end cash and debt figures
- 파이낸셜뉴스 and 뉴데일리, 2026년 7월 30일, for Park Soon-chul's remarks on Samsung's call and the dividend figures
- 한국경제, 2026년 6월 16일, for the reported size of the shareholder return package, and SK Hynix's denial of those figures
- 시사저널e, 2026년 8월 3일, for Han Dong-hee's reading and SK Hynix's statement that no plan has been finalized
