On 22 June 2026, the U.S. Securities and Exchange Commission (SEC) published Nasdaq’s Amendment No. 1 to its proposed rule introducing a new continued listing requirement based on a company’s Market Value of Listed Securities (MVLS).
The proposal has not yet been approved by the SEC. However, Amendment No. 1 provides valuable insight into how Nasdaq’s continued listing framework may evolve and the standards listed companies may be expected to meet in the future.
The Proposed US$5 Million MVLS Requirement
The proposed rule would require companies listed on the Nasdaq Global Market (including the Nasdaq Global Select Market) and the Nasdaq Capital Market to maintain a minimum Market Value of Listed Securities (MVLS) of US$5 million.
If a company’s MVLS remains below US$5 million for 30 consecutive trading days, Nasdaq would issue a Staff Delisting Determination immediately. This means there is no usual grace period for the company to fix the issue before the delisting process starts.
The proposed MVLS requirement would operate alongside Nasdaq’s existing continued listing standards. Companies would still need to satisfy all other applicable requirements relating to bid price, shareholders’ equity, public float, corporate governance and ongoing disclosure obligations.
Why Nasdaq Submitted Amendment No. 1
Nasdaq originally filed the proposed MVLS rule with the SEC in January 2026. During the SEC’s public consultation process, the proposal received comments from listed companies, law firms, industry associations and other market participants.
While many commenters supported introducing a minimum MVLS requirement to strengthen investor protection and overall market quality, others argued that the original proposal provided insufficient flexibility for companies experiencing temporary business or market-related challenges.
In response, Nasdaq submitted Amendment No. 1. Rather than withdrawing the proposed US$5 million MVLS requirement, Nasdaq retained the proposed threshold while revising the role of the Nasdaq Hearings Panel. The amendment allows the Panel, where appropriate, to grant a discretionary exception of up to 180 days, giving eligible companies an opportunity to demonstrate that they satisfy Nasdaq’s initial listing requirements before delisting proceeds.
What Changed Under Amendment No. 1
The amendment introduces one key change: greater discretion for the Nasdaq Hearings Panel.
Original Proposal | Amendment No. 1 |
Staff Delisting Determination issued after 30 consecutive trading days below the MVLS threshold. | No change. |
Very limited opportunity for relief once the delisting process began. | The Hearings Panel may grant an exception of up to 180 days if appropriate. |
No specific recovery mechanism. | The company must demonstrate that it satisfies all applicable initial listing requirements before the exception expires. |
Importantly, the amendment does not create an automatic 180-day compliance period. Any extension remains entirely at the discretion of the Hearings Panel and will only be granted where the company can demonstrate a credible path to meeting Nasdaq’s higher initial listing standards.
Why This Matters
Although the proposal applies to existing listed companies, its implications extend beyond post-listing compliance.
For listed companies, the proposal highlights Nasdaq’s increasing focus on long-term market quality rather than relying solely on traditional financial thresholds. Boards and management teams may need to place greater emphasis on maintaining sustainable market value, investor confidence and long-term business performance.
For companies preparing for a U.S. IPO, the proposal reinforces that achieving a successful listing is only the beginning. Long-term compliance planning, corporate governance and market support are becoming increasingly important components of remaining listed on a national securities exchange.
Looking Ahead
The proposed MVLS requirement has not yet been approved by the SEC, and companies are not currently required to comply with the proposed rule.
Regardless of the final outcome, Amendment No. 1 demonstrates Nasdaq’s continued focus on investor protection, market integrity and the quality of its listed companies. Businesses considering a U.S. IPO, as well as existing Nasdaq issuers, should continue monitoring the proposal and assess how evolving listing standards may affect their long-term capital markets strategy.
How Hexcellence Consulting Can Help
Maintaining a Nasdaq listing requires more than meeting the initial listing requirements. Companies must also adapt to evolving regulatory expectations throughout their life as a public company.
At Hexcellence Consulting, we advise companies on U.S. IPO readiness, listing strategy, post-listing compliance, corporate governance and ongoing regulatory developments. By helping management teams understand regulatory changes before they become effective, we enable businesses to strengthen compliance, reduce regulatory risk and build a stronger foundation for long-term success in the U.S. capital markets.
