Nasdaq Proposes Significant Changes to Initial and Continued Listing Standards

Sheppard Mullin Richter & Hampton LLP
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Sheppard Mullin Richter & Hampton LLP

On September 3, 2025, The Nasdaq Stock Market LLC (Nasdaq) announced proposed changes to its listing standards. According to Nasdaq, these proposed changes respond to the rising complexity and volatility in today’s capital markets, especially in the context of emerging companies and cross-border listings.

Key Proposed Enhancements

  • Minimum Market Value of Publicly Held Shares: A new $15 million minimum public float is proposed for companies seeking to list under the net income standard.
  • Accelerated Suspension & Delisting Process: Companies falling below a $5 million market value of listed securities — while also failing other compliance criteria — will be subject to swifter suspension and delisting.
  • Special Rules for China-Based Companies: Companies principally operating in China would now face a $25 million minimum initial public offering (IPO) proceeds threshold for new listings.

When asked about the rationale for these changes, John Zecca, Nasdaq’s Executive Vice President and Global Chief Legal, Risk & Regulatory Officer, highlighted the increasing need for tighter controls on liquidity and trading behaviors, particularly among microcap companies and those operating principally in China. Recent episodes of volatility and social media-driven “meme stock” activity have increased the urgency for a listing framework that can better handle these risks.

The official filings related to the proposed changes may be accessed via the following links:

Next Steps and Implementation Timeline

Nasdaq has submitted these proposed rule changes to the United States Securities and Exchange Commission (“SEC”) for review. If approved, the exchange has proposed that the revised initial listing standards be implemented promptly.

Companies already in the initial listing process would have a 30-day period to complete their applications under the current requirements; thereafter, all new listings would be required to comply with the updated standards. For the accelerated suspension and delisting procedures, Nasdaq has proposed a 60-day implementation period following approval by the SEC.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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