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On November 19, 2025, Singapore Exchange ("SGX") and Nasdaq announced a proposed "Global Listing Board" framework enabling companies to file a single prospectus acceptable to both Singapore and U.S. regulators. The initiative, backed by the Monetary Authority of Singapore ("MAS") as part of the broader SGX listing regime modernization, targets implementation by mid-2026, subject to final rulemaking.

Eligibility and Framework Structure

Qualifying Criteria: Companies with minimum market capitalizations of S$2 billion (approximately US$1.54 billion).

Regulatory Uncertainty: Critical questions remain regarding the framework's structure and the rules that will be applicable. For example, it is unclear whether the system will mirror the existing Multijurisdictional Disclosure System ("MJDS"), which permits certain Canadian issuers to rely on Canadian disclosure rules as SEC registrants, or whether full SEC registration and Nasdaq standards will serve as the baseline for SGX dual-listed companies.

Legal and Compliance Considerations

Ongoing Dual Jurisdiction Obligations: Despite harmonized prospectus requirements, issuers are expected to remain subject to compliance obligations in both jurisdictions, including:

  • Differing reporting cadences and governance requirements
  • Separate regulatory interactions and oversight 

U.S. Securities Law Exposure: Nasdaq listing subjects issuers to U.S. securities law liability, including class-action litigation risks, a significant consideration for Asia-based companies unfamiliar with the U.S. litigation environment .

Disclosure Standards Alignment: MAS is pursuing complementary reforms to align SGX's disclosure standards with international (particularly U.S.) practices, though the full extent of SGX's acceptance of U.S.-style disclosures awaits final rule issuance.

Strategic Benefits

For qualifying technology, life sciences, and high-growth enterprises, the framework offers:

  • Access to both U.S. capital market liquidity and Singapore's regional investor base
  • Reduced legal, accounting, and underwriting costs through single prospectus filing
  • Enhanced institutional and retail investor reach across multiple time zones 

The Global Listing Board represents a potentially positive development for trans-Pacific capital access while maintaining regional listing presence. However, companies should await final regulatory guidance before making strategic decisions, given the substantial compliance and legal exposure implications inherent in dual-jurisdiction listings.

To discuss how these developments may impact your U.S. capital markets strategy, please contact Sullivan partners David Danovitch (ddanovitch@sullivanlaw.com or 212-660-3060), Tehila Levi Lati (tlevi@sullivanlaw.co.il or +972 74 7580480) or Eric Victorson (evictorson@sullivanlaw.com or 212-660-3092).