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The Legal Dispatch Room

SGX shifts towards a more market-driven, disclosure-based regulatory regime

New measures put in place to streamline listing process and maintain oversight post-listing

The Singapore Exchange Regulation (SGX RegCo) announced in October 2025 significant measures marking a shift towards a more market-driven, disclosure-based regime. These changes, which follow recommendations aimed at boosting liquidity and raising investor interest in the Singapore equities market, affect listing requirements, ongoing compliance, and regulatory enforcement.

For companies looking to list:

SGX RegCo will lower entry barriers to widen the diversity of listed companies.

Profit Test Threshold: The profit test threshold for new listings has been lowered from S$30 million to S$10 million. This move makes it easier for companies establishing themselves to list on SGX and access funding.

Pre-Revenue Companies: Admission requirements have been refined for specific industries. The minimum operating track record for pre-revenue life science companies has reduced from 3 years to 2 years. Such companies must have been primarily engaged in laboratory research and development of their identified products for at least 1 year.

Key criteria relating to governance and financial health will be retained, including the requirements for companies to (i) obtain unmodified audit opinions to ensure compliance with financial reporting standards, and (ii) provide confirmations that they have obtained approvals and comply with laws and regulations that would materially affect business operations.

For listed issuers:

Cessation of Public Trading Queries: SGX RegCo will no longer issue public trading queries to companies. Feedback indicated that these queries often created a "chilling effect" on the market and impeded price discovery.

Material Disclosure Queries: SGX RegCo will still issue disclosure queries to companies concerning material issues. If an issue is not material, SGX RegCo will now engage privately with the company to advise on improvements.

"Trade with Caution" Alerts: SGX RegCo retains the ability to issue “trade with caution” alerts if it believes the market is not fair, orderly, or transparent, particularly if there is evidence of misconduct that the market should be aware of. These alerts are valid for 2 weeks.

Removal of Financial Watch List: The financial watch list is scrapped. Although the list was intended to motivate companies to turn around, SGX RegCo observed that it unintentionally affected a company’s ability to conduct business and made recovery more difficult. However, companies are still required to announce if they have recorded 3 consecutive financial years of losses. SGX RegCo also strongly encourages these issuers to communicate their future plans and specific actions to improve financial performance.

Trading Suspensions: Trading suspensions will now be considered only where there is clear evidence of going concern issues. Companies suspended solely due to doubts about their ability to continue as a going concern may apply to resume trading provided (i) they are not undergoing formal insolvency or restructuring proceedings, and (ii) their boards confirm, with basis stated, that they can continue as going concerns. 

Conclusion

SGX RegCo’s decision to deploy more nuanced engagement strategies signal a deliberate effort to balance enterprise and regulation, with a view to ensuring Singapore remains a competitive and attractive centre for equity issuance while maintaining necessary guardrails for investors.

If you would like to explore how these developments could impact your business, please get in touch.