🇦🇪Listing Venues for Asian Issuers: HKEX, SGX, STAR, ChiNext, Tokyo, Seoul, New York and Dubai

A listing venue is three things sold as one: a rulebook that decides who may be admitted, a pool of buyers whose money and habits set the price, and a chain of private gatekeepers — sponsor, auditor, underwriter, settlement bank — who decide whether they will put their names to the deal. An issuer with its business in Asia now chooses among a dozen boards that differ on all three, and the rulebook is the part that decides least.

The comparison below puts thirteen boards on the same axes: the two Hong Kong boards, the two Singapore boards, Shanghai's STAR Market and Shenzhen's ChiNext, the Prime and Growth markets in Tokyo, KOSPI and KOSDAQ in Seoul, Nasdaq and the NYSE for Asian companies going to New York, and Nasdaq Dubai as the Gulf alternative. The Hong Kong and Shanghai routes each have their own detailed owners — the HKEX listing guide with eleven internal routes and a full IPO budget, and the Shanghai guide with the five STAR standards and the CDR route. The comparison here does not repeat them; it sets them beside the boards they compete with.

Concept

The practical question is which board a given issuer can reach, keep and exit through. Three features explain most outcomes.

The financial gate is rarely binding. Every venue in the comparison admits a loss-making company by some route: Hong Kong through Chapters 18A and 18C, Singapore through the market-capitalisation test and Catalist, Tokyo through the Growth Market, Seoul through KOSDAQ's technology track, the mainland boards through market-cap-only standards, and New York through its equity and market-value standards. What excludes an issuer is almost always one of the other axes — the place of incorporation, the minimum amount that has to be sold, the lock-up, the cost relative to proceeds, or a gatekeeper's refusal.

Float and lock-up are the hidden price. A board that demands 25% in public hands forces a founder to sell a quarter of the company at the IPO price; a board that counts only the number of freely tradable shares lets the same company list selling a small fraction. A 36-month lock-up of the controlling shareholder turns a listing into a three-year commitment to the valuation achieved on day one.

The veto sits outside the rulebook. None of the listing rules compared here names a nationality or a sanctions list. The refusal comes from the sponsor that must certify the deal, the auditor that must sign the accountants' report, the underwriter that must hold the shares, and the bank that must receive the proceeds. For an issuer with a sanctioned or otherwise high-risk connection the operative question is therefore which gatekeepers a venue forces it to use, and under which sanctions perimeter those gatekeepers operate.

The decision question and what excludes first

The decision is where to raise equity and create a traded share for a company whose operations, revenue or founders sit in Asia. Five filters remove boards before any threshold is read.

1. Place of incorporation. The STAR Market and ChiNext admit companies incorporated in the PRC; a foreign-incorporated group reaches them only as a red-chip under the innovative-enterprise pilot, with thresholds of CNY 10 billion and above. Every other board in the comparison takes a foreign company. HKEX's overseas-issuer regime requires 14 core shareholder-protection standards from 1 January 2022; its published list of jurisdictions records earlier applicants and issuers, rather than a closed list of permitted domiciles.
2. A "China-based" profile in New York. Since the SEC approved Nasdaq's rule on 14 May 2026 (Release No. 34-105494), a company headquartered or incorporated in the PRC, Hong Kong or Macau, or principally administered there, must raise at least US$25 million in a firm-commitment IPO and may use a direct listing only on the Global Select Market. The PCAOB inspection regime and the Holding Foreign Companies Accountable Act apply on top.
3. Deal size against fixed costs. Professional fees are close to fixed, so a small raise pays a double-digit share of its proceeds on a large board; below roughly HK$500 million of proceeds the HKEX economics break before any rule does.
4. Language and accounting. Seoul requires the registration documents in Korean and K-IFRS reporting; Tokyo works in Japanese; the mainland boards require Chinese Accounting Standards.
5. Gatekeeper perimeter. Where a founder, shareholder, customer base or supply chain carries a sanctions or high-risk flag, the boards whose sponsors, underwriters and settlement banks sit inside the US, EU or UK perimeter close first, regardless of the listing rules.

Matrix 1: entry gates

Thresholds from the primary sources linked below, checked in September 2026; KOSDAQ uses KRX’s guide of 29 May 2026. "Public float" is the minimum at listing; "lock-up" is the minimum restriction on controlling shareholders or promoters imposed by the rules, not by the underwriting agreement.

Sources for the thresholds: HKEX routes as set out in the HKEX listing guide; the public float scale under Main Board Rule 8.08 and GEM Rule 11.23, and the free-float test under Rule 8.08A; disposal restrictions under Main Board Rule 10.07, GEM Rule 13.16A and Rule 18C.13; SGX Mainboard Rule 210 (profit test lowered from S$30 million to S$10 million on 29 October 2025, SGX RegCo) and Rule 229 on the moratorium; Catalist Rule 406 and Rule 422; STAR standards as set out in the Shanghai guide; ChiNext Listing Rules (2024 revision), Articles 2.1.1, 2.1.2 and 2.3.4 (SZSE text, PDF); TSE Prime and Growth initial listing criteria; KOSPI official KRX criteria; KOSDAQ KRX 2026 listing review guide (29 May 2026), pp. 12–13 and 52 for financial/distribution alternatives, p. 38 for controller restrictions and pp. 205–207 for foreign technology issuers; Nasdaq initial listing guide; Nasdaq Dubai listing criteria.

Matrix 2: cost, time, oversight and the gatekeeper filter

Exchange fees are the only cost line any venue publishes. All-in costs are shown where an official or aggregated dataset exists and are otherwise left blank.

The HKEX fee scale and all-in estimates follow the HKEX listing guide; the SGX fee ranges are from the exchange’s Mainboard listing-fee tables (initial, annual and admission processing fees; checked 26 September 2026); mainland averages and elapsed times are the datasets used in the Shanghai guide (183 IPOs from January 2025 to June 2026; 335 listings from 2023 to March 2024); the Tokyo fees are the JPX initial listing fee schedule and the two-month standard review is from the TSE Growth New Listing Guidebook; the Nasdaq entry fee is Rule 5910(a), which applies to applications from 1 January 2026.

What the two matrices say

The first reading is that the gate column sorts the boards into three families, and the family matters more than the number. Hong Kong, Singapore Mainboard, Tokyo Prime and KOSPI still test profit or a large capitalisation, but each has a side door for a loss-maker. Catalist, GEM, TSE Growth, KOSDAQ's technology track and Nasdaq Dubai have no profit test at all and replace it with a sponsor, a small float value or a market-cap floor. The mainland boards set the highest numbers of any Asian venue and then add the incorporation filter that no foreign group passes. New York sits in its own family: modest numbers, but a regulatory perimeter — PCAOB inspection, HFCAA and now the US$25 million floor for China-based companies — that falls on the issuer's origin rather than its size.

The float column is where the boards really diverge for a founder. Hong Kong's 25% for companies up to HK$6 billion and the mainland's 25% below CNY 400 million of share capital mean selling a quarter of the company; Singapore steps down to 12% for the largest issuers; Tokyo measures tradable shares, which include existing non-controlling holders, rather than shares sold; New York measures a number of shares and holders and no percentage at all. For a company that wants the listing more than the money, that difference outweighs the entry threshold.

The lock-up column separates two philosophies. The mainland boards bind controlling shareholders for 36 months, Hong Kong for 12 (24 for pre-commercial specialist technology), Singapore and Seoul for six with a stepped release on some routes, and Tokyo and New York impose no rule-based lock-up on the controller at all, leaving it to the underwriting agreement. The longer the rule-based lock-up, the more the board is pricing in the risk that the controller will leave as soon as the price allows. The general mechanics are covered in lock-up.

The cost column is thin because venues publish only their own fees, and those are trivial: the largest in the table, Nasdaq's US$350,000 including the application fee, is a rounding error against a nine-figure raise. The costs that matter are the underwriting commission and professional fees, and the only systematic data are the mainland averages of 9.4–11.5% and the Hong Kong curve that falls from double digits on a small deal to below 3% on a large one. The practical consequence is that for a raise of a few hundred million dollars the choice between Hong Kong and New York is decided by the commission rate — an average base commission of 1.5% on Hong Kong IPOs in 2025 against 5–7% in the United States — more than by any listing fee.

The last column is the one the rulebooks do not show. No board in the comparison prohibits an issuer by nationality, but every board other than the mainland ones routes the deal through gatekeepers exposed to US, EU or UK law. A US underwriter applies the OFAC 50 Percent Rule and program-specific bans; under Executive Order 14071, for example, a US person's purchase of equity in a non-Russian entity that derives 50% or more of its revenue from a Russian subsidiary is prohibited new investment (OFAC FAQ 1055), which removes the entire US buyer base for such an issuer. Singapore's financial institutions are bound by MAS Notice SNR-N01 of 30 June 2025, amended on 26 February 2026. Paragraphs 5.1 and 5.4 restrict assistance with securities issued on or after 14 March 2022 by Russia's Government or Central Bank and entities owned or controlled by, or acting for, them. Japan has run a permission regime for the issue or offering of securities in Japan by designated organisations and their majority-owned subsidiaries since 24 September 2014. The route for how these tests are run is in sanctions screening and the sanctions route map.

Issuer profile and board

Worked example: how much has to be sold to list

Take a company valued at US$400 million at the offer price that wants to list while selling as little as it can, and assume it clears the financial gate everywhere. The minimum public float then sets the size of the deal.

• HKEX Main Board. At about HK$3.1 billion of capitalisation the company sits below HK$6 billion, so 25% must be in public hands: about US$100 million of shares. The separate free-float test under Rule 8.08A also requires at least 10% of the shares, about US$40 million, to be held by the public free of any disposal restriction, so cornerstone and other locked-up shares do not count toward it. Under the ordinary Main Board rule, the controller may not dispose of the existing holding for six months and may not cease to control the company through disposals in the next six.
• SGX Mainboard. At any recent exchange rate US$400 million is above S$400 million and below S$1 billion, so 15% in public hands is enough, about US$60 million, spread over at least 500 holders. On the profit test, promoters are locked for six months.
• STAR Market or ChiNext. 25% of the enlarged share capital unless it exceeds 400 million shares — and the controller cannot sell for 36 months. Only available if the company is a PRC entity.
• Nasdaq Global Market. No percentage test: 1.1 million unrestricted shares worth at least US$15 million and 400 round-lot holders. If the company is China-based, the IPO must still raise at least US$25 million in a firm-commitment offering, about 6% of the company.
• Nasdaq Dubai. 25% on either market, about US$100 million, with no mandatory lock-up on the Main Market.

The spread — from roughly 6% of the company in New York to 25% in Hong Kong, Shanghai, Shenzhen and Dubai — is a direct cost to the founder at the IPO price, and it is invisible in any comparison that reads only the entry thresholds.

Typical mistakes

Choosing on the entry threshold. Every board has a route for a loss-maker; the thresholds filter little and the float, lock-up and gatekeeper columns filter most.

Treating the mainland as an option for a foreign group. The STAR Market and ChiNext admit PRC companies; the red-chip pilot requires CNY 10 billion and above, and the CDR route has produced one issuer since 2019, as set out in the Shanghai guide.

Budgeting New York at Hong Kong commission rates, or the reverse. The gap between an average 1.5% base commission in Hong Kong in 2025 and 5–7% in the United States is larger than any exchange fee in either market.

Ignoring the China-based rules in New York. The US$25 million firm-commitment floor applies by headquarters, incorporation or principal administration in the PRC, Hong Kong or Macau, not only to PRC-incorporated issuers.

Assuming Tokyo or New York have no lock-up. They impose none by rule, but the underwriting agreement will, and a pre-IPO allotment within a year before a TSE listing carries its own holding obligation.

Cleaning the register shortly before filing. Gatekeepers test control, revenue and history, and a late change of ownership draws deeper diligence rather than ending it; the corporate side of such changes is covered in holding structures and national security review.