Each of Nasdaq Stock Market LLC (Nasdaq) and NYSE American LLC (NYSE American) has recently proposed, and Nasdaq has implemented, changes to its initial listing standards to heighten the financial and other standards required for initial listing, signaling a broader push to strengthen market quality and investor protections.

Effective January 2026, Nasdaq raised the minimum required market value of unrestricted publicly held shares (MVUPHS)¹ under its income standard for companies conducting initial public offerings and certain other underwritten offerings. The new required MVUPHS is $15 million for listings on the Nasdaq Global and Nasdaq Capital Markets, up from $8 million and $5 million, respectively. In addition, Nasdaq amended its “low price requirement” to allow Nasdaq to immediately suspend trading and issue a delisting determination without providing any cure period, which was provided under the prior version of the rule, if a company’s security has a closing bid price of $0.10 or less for 10 consecutive trading days.

Nasdaq has also proposed stricter listing requirements for companies headquartered, incorporated, or principally administered in China, including Hong Kong and Macau, which would, among other things, require that, in the case of an initial public offering, any such company must offer a minimum amount of securities that would result in gross proceeds to the company of at least $25 million. These amendments are not yet effective.

Meanwhile, NYSE American has proposed amendments to align more closely with Nasdaq’s framework, departing from its previously more flexible approach. These amendments include requiring $15-$20 million in unrestricted publicly held shares, imposing a $4 minimum share price for new listings, and mandating that companies meet price and market capitalization thresholds over a sustained 90-day period.

¹ Unrestricted publicly held shares are shares that are not held by an officer, director, or 10% shareholder of the company and which are not subject to resale restrictions (Nasdaq Rule 5005(a)(46)).