Listing in the US was once the preferred route to capital markets for many pre-profit companies. But with the Nasdaq’s proposed new listing rule amendments, submitted in September 2025, that pathway is narrowing. The Nasdaq proposes raising the minimum public float and fundraising thresholds for companies at the IPO stage.
For new listings with principal operations in China, that minimum IPO fundraising requirement sharply increases to USD25 million. Stricter suspension and delisting mechanisms for non-compliant companies are also introduced.
Meanwhile, since the China Securities Regulatory Commission (CSRC) implemented the Interim Measures for the Administration of Overseas Securities Offering and Listing by Domestic Companies in March 2023, more than 300 companies have completed overseas listing filings, yet fewer than a third have listed in the US, with a greater number opting for Hong Kong listing.
Yan Ge
Senior Partner
Joint-Win Partners
The landscape for listing opportunity has also adjusted domestically, with CSRC chair Wu Qing announcing a series of capital market reforms in June 2025. These include establishing a Sci-Tech Growth layer within the Star market, reinstating the fifth set of standards for pre-profit companies, and activating the third set of standards on the ChiNext board to support such firms.
These measures are believed to herald a new dawn for many pre-profit technology and innovation enterprises. In view of the latest developments, this article analyses key distinctions for pre-profit companies considering listing in Hong Kong versus the Chinese mainland, offering an initial reference guide to choice of listing venue and market.
The HKEX
The Hong Kong Stock Exchange launched its new chapter 18C listing rules for specialist technology companies in March 2023. The rules are designed to attract companies from five designated sectors: next-generation information technology; advanced hardware; advanced materials; new energy and environmental protection; and food and agricultural technologies.
Listing applicants are required to show that their products or services possess high growth potential and are backed by significant R&D expenditure.
Specialist technology companies are classified by listing revenue as either “commercial companies” that meet the HKD250 million (USD32.1 million) threshold or “pre-commercial companies” that fall short. While each faces distinct listing criteria, both must demonstrate investment from their own pathfinder independent investors.
Yuan Yao
Partner
Joint-Win Partners
In summary, under the chapter 18C rules, a commercial company must have audited revenue of at least HKD250 million for the most recent financial year, an expected market capitalisation of no less than HKD4 billion, and R&D expenditure representing no less than 15% of total operating expenses.
For a pre-commercial company, the expected market capitalisation requirement rises to HKD8 billion, along with a higher R&D expenditure ratio, no less than 30% for revenue between HKD150-250 million; and no less than 50% for revenue below HKD150 million.
Beijing Stock Exchange
Originating from the Select layer of the New Third Board (NEEQ), the Beijing Stock Exchange (BSE) is dedicated to supporting innovative and growing SMEs. More than half of its listings are classified as “specialised, refined, distinctive and innovative”, with tech enterprises constituting about 80%, and private enterprises nearly 90% of the total. It prioritises strategic emerging industries such as semiconductors, new energy, advanced manufacturing and biomedicine.
Under its listing framework, the BSE allows pre-profit enterprises to apply if they have completed a minimum 12-month consecutive listing on the NEEQ Innovation Layer and maintained net assets of no less than RMB50 million (USD7 million) at the end of the previous financial year. Further details are stipulated in the exchange’s official listing regulations.
ChiNext board
Formal implementation of the ChiNext board’s third set of listing standards was announced by the CSRC at the 2025 Lujiazui Forum in June. This framework targets innovative, not yet profitable firms demonstrating high growth and strategic importance, mandating an expected market capitalisation of at least RMB5 billion and minimum annual revenue of RMB3 billion in the previous financial year.
It is intended to encompass high-technology and strategic emerging industries such as advanced manufacturing, internet, big data, cloud computing, AI and biomedicine.
Shortly after, on 27 June, Shenzhen DapuStor, a developer and vendor of enterprise solid-state drives for data centres, had its IPO application accepted by the Shenzhen Stock Exchange. But up to the end of October 2025, the ChiNext board had not seen a successful listing by any pre-profit company.
Star Market
Shanghai’s Star Market reinstated its fifth set of listing standards in June 2025, expanding application opportunities to include companies in frontier technology sectors such as AI, commercial aerospace and the low-altitude economy in airspace below 1,000 metres.
Under the Star Market listing rules, profitability is mandatory only under the first set of criteria, with the remaining four sets having no such requirement. Details are in the Shanghai Stock Exchange Star Market Listing Rules (revised in April 2025).
Subsequently, in July 2025, the Star Market assigned 32 existing pre-profit companies to a newly established Sci-Tech Growth layer, stipulating that newly listed pre-profit companies would be automatically included upon listing.
This move effectively creates a separate, less restrictive pathway for frontier tech companies in fields such as AI, commercial aerospace and the low-altitude economy.
Takeaways
In the present environment, where overseas listings are subject to filing requirements, enterprises must incorporate this procedure into their schedules, regardless of opting for Hong Kong or US markets. Nevertheless, both markets maintain a shorter review period compared to domestic listings.
Hong Kong, especially, provides high-growth technology firms with a streamlined path to global capital markets, featuring an average listing process of about 260 calendar days, and the possibility of completion within six months.
Confronted with diverse regulatory landscapes across exchanges and board segments, pre-profit tech companies are advised to leverage existing policy opportunities.
A successful market debut can be secured through early preparation tailored to the company’s profile, and with prudent selection of the listing platform and intermediaries.
Yan Ge is a senior partner, and Yuan Yao is a partner at Joint-Win Partners
Joint-Win Partners
Room 6101, Shanghai Tower
479 Lujiazui Ring Road, Pudong New Area
Shanghai 200122, China
Tel: +86 21 6037 5888
Fax: +86 21 6037 5899
E-mail: yange@joint-win.com
yuanyao@joint-win.com
