MAS and SGX RegCo consult on proposed establishment of Global Listing Board for dual listings on SGX and Nasdaq

22 January 2026

On 9 January 2026, the Monetary Authority of Singapore (“MAS”) and Singapore Exchange Regulation (“SGX RegCo”) published their respective consultation papers seeking feedback on proposed legislative changes and listing rules relating to the proposed establishment of the Global Listing Board for the purpose of dual listings on Singapore Exchange (“SGX”) and Nasdaq. MAS is seeking feedback on amendments to the Securities and Futures Act 2001 (“SFA”) and draft regulations to facilitate dual listings on the Global Listing Board. SGX RegCo is consulting on the listing rulebook for the Global Listing Board. Both consultations close on 8 February 2026.

As part of the Equities Market Review Group’s final recommendations, SGX and Nasdaq Inc. had on 19 November 2025 announced a collaboration to simplify dual listings on both exchanges.

The changes proposed by MAS serve to minimise friction for prospective issuers seeking to undertake a concurrent initial public offering (“IPO”) in the US and Singapore through the dual listing bridge, while retaining MAS’ discretion to take actions against disclosure-related breaches and market misconduct. In addition, MAS has proposed other changes to facilitate the offering process for all listings, including permitting issuers to engage retail investors earlier in the IPO process.

SGX RegCo seeks comments on the listing rules for the Global Listing Board. The proposed listing rules will be cited as the Global Listing Board Rules (“GLB Rules”), a draft of which can be found in Appendix 1 of the SGX RegCo consultation paper.

Changes proposed by MAS to facilitate dual listings on Global Listing Board

MAS has proposed the following changes which will apply only to dual listings on the Global Listing Board:

  • Single set of offer documents for dual listing: Currently, an issuer intending to carry out a concurrent IPO with a view to a concurrent listing on SGX and an overseas exchange will need to prepare a prospectus based on two sets of disclosure requirements. To facilitate the use of a single set of offer documents by an issuer seeking a dual listing on the Global Listing Board, MAS has proposed to streamline the prospectus disclosure requirements by incorporating certain US requirements for both the IPO and post-listing stages via regulations. In this regard, the issuer’s prospectus must contain the information required by US requirements to be included in a US prospectus. The issuer may incorporate by reference certain documents in its prospectus if allowed under US requirements, instead of reproducing all the details within its prospectus. Issuers already listed on the Global Listing Board can make an offer using an offer information statement (“OIS”) lodged with MAS that meets US disclosure requirements, instead of the existing OIS form and content requirements. Similarly, the issuer may lodge the OIS with MAS together with another document, where the information contained in that document is permitted under US disclosure requirements to be incorporated by reference in a prospectus.
  • Adjustments to registration process for prospectuses to be registered earlier: To enable issuers to align the milestones between the US and Singapore in the prospectus registration and fundraising process, MAS has proposed to allow the registration of a Global Listing Board issuer’s prospectus at any time after lodgment of its preliminary prospectus, instead of the current requirement where prospectuses must be exposed to the public for at least seven days before registration can take place. This will allow the Singapore final prospectus to be lodged and registered as soon as the US registration statement becomes effective, even if it is less than seven days after lodgment of the Singapore preliminary prospectus. Issue managers who are preparing an issuer to be listed on the Global Listing Board must still conduct adequate due diligence on the issuer, but MAS will consider additional guidance to provide greater clarity on the level of due diligence that is expected for dual listings. The listing application and prospectus of an issuer seeking a listing on the Global Listing Board will still be subject to approval by SGX and registration by MAS respectively.
  • New safe harbours: MAS has proposed to introduce three safe harbours currently available in the US to provide issuers on the Global Listing Board and other relevant persons with the assurance that they may undertake certain trading-related activities that are conducted primarily outside Singapore, without being exposed to the risks of potential criminal and civil liability for market misconduct under Part 12 of the SFA. The safe harbours will enable such persons to issue forward-looking statements (such as a projection or estimate), repurchase their common stock in the US open market, or carry out pre-determined trades according to a trading plan, without being exposed to civil or (other than in the case of forward-looking statements) criminal liability under Part 12 of the SFA. However, these safe harbours do not provide a valid defence against fraud or dishonesty and will only apply if all the relevant conditions for the equivalent US safe harbours are met.

MAS also seeks views on whether amendments to the rules on stabilising actions in Singapore would be necessary, to support the undertaking of stabilising actions by a stabilising manager on the Global Listing Board in the context of concurrent offerings on Nasdaq and the Global Listing Board.

Other proposed amendments by MAS to facilitate the offering process

MAS has proposed two other amendments to the SFA to facilitate the offering process in general. These changes will be applicable to all offers, including offers by issuers seeking a listing on the SGX Mainboard or the Global Listing Board.

  • Permit all issuers to engage retail investors earlier in the IPO process: Currently, an issuer undertaking an IPO may only disseminate a prospectus, profile statement, or a product highlights sheet to retail investors after it has been registered by MAS, and engagement with retail investors can only take place after prospectus registration. In May 2025, MAS consulted on the policy proposal to allow issuers to, upon lodgment, disseminate the preliminary prospectus and present oral or written material on matters contained in the preliminary prospectus to retail investors. In view of the positive feedback received, MAS has proposed to enable all issuers to engage retail investors earlier in the IPO process with the preliminary prospectus lodged with MAS, subject to certain safeguards. This will enable issuers seeking a dual listing on the Global Listing Board to align the timing of their engagement with retail investors in both the US and Singapore, as issuers in the US are allowed to obtain indications of interest from retail investors prior to effectiveness of their US registration statement.
  • Clarifying treatment of sponsored depositary receipts: MAS has proposed amendments to provide that, for an offer of sponsored Depositary Receipts (“DRs”), the issuer of the underlying instruments of sponsored DRs (to be prescribed by MAS) will be deemed to be the issuer and the person making the offer of sponsored DRs, instead of the depositary, which is typically a financial institution acting as an intermediary. This means the issuer of the underlying instruments will be responsible for registering the prospectus and be subject to the legal requirements as to the contents of prospectuses, and accordingly be exposed to liability in respect of statements and non-disclosure in prospectuses. MAS intends to prescribe sponsored American Depositary Receipts (“ADRs”), so that the issuer of the underlying instrument will be deemed to be the issuer and the offeror of the ADR. This is because sponsored ADRs are the most likely form of sponsored DRs that may be offered in Singapore in conjunction with a dual listing on a US exchange and on SGX.

SGX admission requirements for issuers seeking to list on the Global Listing Board

The draft GLB Rules set out the structure of the Global Listing Board including the matters below.

Quantitative standards

An issuer must satisfy the required quantitative standards to be listed on the Global Listing Board:

  • Market capitalisation: Have a market capitalisation of at least S$2 billion based on the issue price and post-invitation issued share capital; and
  • Satisfy one of the requirements below:
    • Revenue requirement: Total revenue of at least US$90 million in the latest completed financial year;
    • Income requirement: (i) Aggregate income from continuing operations before income taxes of at least US$11 million over the prior three financial years; (ii) positive income from continuing operations before income taxes in each of the prior three financial years; and (iii) at least US$2.2 million income from continuing operations before income taxes in each of the two most recent financial years; or
    • Assets with equity requirement: (i) Total assets of at least US$80 million; and (ii) shareholders’ equity of at least US$55 million.

SGX RegCo will apply the quantitative standards in a similar manner to Nasdaq for Global Select Market (“Nasdaq GSM”) admission. The issuer must also have been approved for listing (in the case of an IPO), or be listed, on the Nasdaq GSM in order to be listed on the Global Listing Board.

Fund raising requirement

Issuers listing on the Global Listing Board will be required to undertake fundraising in Singapore.

Retail brokerage allocation

Unlike IPOs in Singapore, IPOs in the US are not required to ensure that a certain percentage of the shares being offered for sale is reserved for retail investors. SGX RegCo has proposed to require issuers to allocate the lower of 5%, or S$50 million, of the total value of the securities being offered for subscription or sale in Singapore to one or more designated retail brokerages operating in Singapore. Distribution will be done through the retail brokerages during the period between the lodgment of the prospectus and its registration.

Other admission requirements

An issuer must remain listed at all times on the Nasdaq GSM. An issuer will be delisted from the Global Listing Board if it is delisted from the Nasdaq GSM or no longer listed on the Nasdaq GSM.

Issuers must also meet the following requirements:

  • Have at least 500 shareholders worldwide at listing, and an arrangement in place to facilitate the movement of securities between the US and Singapore on a continuing basis.
  • Their financial statements must be prepared in accordance with, or reconciled to, Singapore Financial Reporting Standards (International), International Financial Reporting Standards, or US Generally Accepted Accounting Principles. The annual financial statements must be audited by certified public accountants in accordance with Singapore Standards on Auditing, International Standards on Auditing, US Generally Accepted Auditing Standards, or auditing standards of the Public Company Accounting Oversight Board (United States).
  • Have, at all times, either a Singapore resident independent director or alternatively, a Singapore-based compliance adviser. SGX RegCo would normally accept a lawyer, a corporate finance adviser, or other professional parties, who are familiar with the rules and regulations applicable to an issuer, to be a compliance adviser.

SGX RegCo to retain full discretion over admission and continued listing

SGX RegCo will retain full discretion over the admission and continued listing of securities on the Global Listing Board, applying an approach harmonised with US practices in its review of listings through the dual listing bridge. Thus, an issuer which has received approval to list, or is already listed on Nasdaq, would typically also be considered eligible to list in Singapore through this bridge. The Global Listing Board is a separate board supporting efforts to attract more Asian issuers listing in the US into the Singapore ecosystem, and will not support transfers of listing status from issuers which are currently listed on the existing SGX Mainboard and Catalist.

Requirement to appoint issue manager

An issuer will be required to appoint an accredited issue manager in Singapore for the purposes of managing the listing application on the Global Listing Board. The issue manager will be required to confirm to SGX RegCo that the prospectus disclosure requirements under the SFA, and the admission requirements for the listing of the issuer on the Global Listing Board, have been complied with.

Ongoing requirements for issuers on the Global Listing Board

SGX RegCo has proposed the following ongoing requirements for issuers on the Global Listing Board:

  • Ongoing disclosures: Issuers on the Global Listing Board will be required to ensure that all disclosures made in the US pursuant to their disclosure of material information obligations under the Nasdaq listing rules are announced on SGXNET. SGX RegCo would expect that all filings made on the US Securities and Exchange Commission Electronic Data Gathering, Analysis, and Retrieval (“SEC EDGAR”) system by the issuer will be announced via SGXNET at the same time. Other material disclosures made by the issuer will be required to be released in Singapore via SGXNET within one trading day after the date that they were filed in the US.

Where filings on SEC EDGAR concerning the issuer (such as changes in the shareholdings of insiders, e.g. directors, officers, and individuals who own more than 10% of an issuer’s shares) may be made in the US by the relevant persons obliged to do so independently of the issuer, the issuer will be required to ensure that such filings are also disclosed in Singapore via SGXNET within one trading day after the date they are filed in the US if they concern changes in shareholdings of insiders, and within two trading days for all other filings.

  • Trading halts and suspension: If the securities of the issuer are halted or suspended from trading on Nasdaq and remains halted or suspended prior to the start of trading in Singapore, the issuer must, before the Singapore market opens, request for a trading halt or suspension of its listed securities on SGX.
  • Delisting: The issuer must be listed on the Nasdaq GSM at all times and will be subject to delisting from the Global Listing Board if it is no longer listed on the Nasdaq GSM. Where the issuer remains listed on other tiers or segments of Nasdaq, the issuer will be required to arrange, at its own expense, the transfer of shares for all shareholders with holdings in The Central Depository (Pte) Limited (“CDP”) to an account within US Depository Trust & Clearing Corporation (“DTCC”). Where the issuer applies to delist from the Global Listing Board, it will similarly be required to arrange for the transfer of all CDP shareholdings into DTCC, at its expense.
  • Disciplinary action: SGX RegCo will be empowered to take disciplinary action against an issuer for any breach of the GLB Rules and impose sanctions such as reminders, private warnings, and public reprimand, and/or require remedial actions from the issuer. The issuer will also be subject to the jurisdiction of the relevant authorities in Singapore with respect to potential breaches of Singapore law.

Transitional arrangements

SGX RegCo will allow an eligible issuer applying for a secondary listing on SGX to concurrently apply for a listing on the Global Listing Board, prior to the commencement of the Global Listing Board. The criteria set out in the draft GLB Rules will be applied to the applications for admission to the Global Listing Board. If both listing applications are approved, the issuer will be listed on SGX and be transferred automatically to the Global Listing Board once it becomes operational. Issuers which satisfy the admission criteria in the draft GLB Rules and who are currently secondary listed on SGX, may similarly apply for admission to the Global Listing Board, prior to its commencement. Aside from these issuers, no applications for transfer to the Global Listing Board will be supported.

Reference materials

The following materials are available on the MAS website www.mas.gov.sg and SGX website www.sgx.com: