MBMC Meishun | The Preferred Institution for Chinese Enterprises' Overseas Listings, Originating from Hong Kong, Leading Institution in Overseas Listing Counseling Success Rate for Chinese Enterprises in 2020, Serving Globally As late 2025 rolled around, a seismic policy shift that would rewrite the overseas financing landscape for Chinese enterprises landed in the global capital markets. The U.S. SEC chairman officially announced that starting January 2026, listing rules would be significantly relaxed. Chinese enterprises that had been pushed to the brink three months prior by Nasdaq's $25 million fundraising threshold suddenly found themselves facing a golden window for U.S. listings. From the high-profile listing of CHAGEE against the odds, to the helpless delisting of Lake Shore Bio, these real cases precisely outline the opportunities and life-or-death challenges for Chinese enterprises seeking overseas listings amid policy swings. Who could have predicted that the U.S. capital markets would see such dramatic "policy rollercoaster" action in 2025? In September, Nasdaq suddenly unveiled a "make-or-break threshold": Chinese enterprises seeking U.S. listings must raise at least $25 million. This standard directly pushed countless small and medium-sized enterprises to the edge. Data shows that in the first nine months of 2025, the average fundraising amount for newly listed companies on Nasdaq was only $17.3 million, with just 3 Chinese enterprises meeting the standard, meaning over 90% of firms were ruthlessly locked out. The delisting tragedy of Lake Shore Bio is a classic microcosm of this round of policy tightening. This vaccine company successfully listed on U.S. stocks in 2024, but due to lack of hot concept support and insufficient public float, its stock price hovered below $1 for a long time. Even after implementing a 10:1 reverse stock split as an emergency measure, it failed to reverse the decline, and finally received a delisting notice in September 2025. Another struggling firm is a Shenzhen-based AI startup, which originally planned to raise $20 million to list on Nasdaq, but was forced to suspend its listing process due to failing to meet the new threshold. Its founder admitted, "It feels like the road to listing has been completely blocked." Yet just three months later, the situation took an earth-shattering turn. SEC Chairman Atkins publicly stated, "The current rules have become a serious barrier to small business financing," and announced a series of reform measures including reducing information disclosure, lowering listing costs, and relaxing executive compensation disclosure requirements. This policy reversal rekindled hope for countless enterprises that had paused their listing plans, and also made CHAGEE's decision to stick to its U.S. IPO amid the April tariff storm look extremely forward-looking, making it a successful model during periods of policy volatility. The SEC's relaxation is not an empty promise, with three core measures precisely targeting the "pain points" and "difficulties" that have plagued Chinese enterprises' past U.S. listings, and real cases have already confirmed their actual value: The last round of listing rules was formulated in 2005, meaning small enterprises with a market capitalization of $250 million had to follow the same disclosure standards as industry giants worth $25 billion, with redundant requirements severely dragging down listing efficiency. Hengrui Pharma's overseas experience is highly convincing: during the U.S. listing process of its "Double AI" combination, it received two FDA complete response letters, one of the core issues being cumbersome information disclosure requirements such as production site inspections. Even though clinical data met standards, the repeated supplementary materials caused a significant delay in the listing schedule. Now that the information disclosure rules have been relaxed, Chinese enterprises no longer need to spend months on materials unrelated to their core business, and the listing process will see a qualitative acceleration. The high costs of listing and maintaining listed status have deterred many Chinese enterprises. Before its delisting, Lake Shore Bio was trapped in a dilemma: on one hand, compliance costs for maintaining listing continued to rise, on the other hand, low stock prices blocked financing channels, and it finally had to abandon its listed status. By contrast, the New York Stock Exchange (NYSE) has long opened its doors to small and medium-sized enterprises first — it only requires a public float value of $3 million and pre-tax income of $750,000. In 2025, many small and medium-sized tech enterprises successfully listed on the NYSE using this advantage, with fundraising amounts concentrated in the $15-20 million range, perfectly matching the policy dividends after the SEC's relaxation. Warren Buffett once publicly complained that "existing disclosure rules fuel CEO pay envy," a problem that has grown increasingly severe among U.S. enterprises. In 2024, the average CEO compensation of S&P 500 companies reached $19 million, and Axon CEO Smith even received a sky-high $165 million compensation, thousands of times that of ordinary employees. For Chinese enterprises, relaxing executive compensation disclosure rules is not about encouraging high salaries, but reducing unnecessary lawsuits and public pressure caused by pay transparency, allowing enterprises to focus more on core business development. This is particularly important for Chinese enterprises that prioritize steady operation. The SEC's relaxation has undoubtedly delivered a policy gift to Chinese enterprises seeking U.S. listings, but blind跟风 is not advisable. Successful and failed cases have already provided clear guidance: Path 1: Sprint for the NYSE to seize the low-threshold dividends. The NYSE's relaxed requirements of $3 million public float and $750,000 pre-tax income are extremely friendly to small and medium-sized enterprises. Referencing a new energy startup, it successfully raised $18 million through an NYSE listing in 2025, perfectly matching the policy direction after the relaxation. Its stock price rose by over 30% after listing, achieving double breakthroughs in financing and valuation. Path 2: Restart Nasdaq listing plans and efficiently connect with cornerstone investors. Professionals suggest that preparatory enterprises need to optimize their financing plans in advance, drawing on the capital operation experience of CATL. When it listed on the Hong Kong stock exchange in 2025, it only took 25 days from filing acceptance to approval, setting an industry fastest record. This ability to efficiently connect with capital is equally valuable after the U.S. stock market relaxation. Regulatory relaxation ≠ abandoning compliance: Critics warn that "relaxing information disclosure comes at the cost of investor protection," and the lesson of Sinovac Biotech is worth vigilance for all enterprises. The company once received a delisting notice for failing to submit its annual report on time. Even with policy relaxation, basic compliance obligations must still be strictly fulfilled, otherwise enterprises will eventually难逃 delisting fate. Beware of market liquidity traps: The case of Lake Shore Bio proves that even if an enterprise meets the listing threshold, if it lacks core competitiveness and has insufficient public float, it may still face the困境 of low stock prices. Over 70% of Chinese enterprises listed in the U.S. in 2024 broke their issue price, meaning "gaining a firm foothold" after listing is more important than "successfully listing". Global competition is heating up: The Hong Kong Stock Exchange and Taiwan Stock Exchange are stepping up their efforts to seize high-quality enterprise resources. The Hong Kong Stock Exchange has launched the "Tech Enterprise Special Line". When Hengrui Pharma and CATL listed on the Hong Kong stock exchange, their oversubscription multiples reached 455 times and 151 times respectively; the Taiwan Stock Exchange has introduced relaxation measures such as allowing day trading. Chinese enterprises need to make a权衡 choice between the high valuation of U.S. stocks and the stability of the Hong Kong stock market. The global IPO market has regained growth momentum. In 2025, the number of IPOs increased by 20% year-on-year, and fundraising amount soared by 84%. The SEC's relaxation has made 2026 a critical window for Chinese enterprises to list in the U.S. But opportunities always favor prepared enterprises. Different types of Chinese enterprises should develop differentiated strategies: Innovative small and medium-sized enterprises: If they meet the NYSE's low-threshold requirements, they can accelerate their listing plans, drawing on CHAGEE's "counter-trend" strategy, using policy dividends to achieve financing breakthroughs and accelerate business expansion. Listed Chinese concept stocks: If their market value is close to the $5 million delisting line, they can refer to the market value management experience of Tencent and艾迪精密, stabilize stock prices through share repurchases and introducing institutional investors, and effectively avoid delisting risks. Cautious enterprises: They can choose a "dual-platform layout", following the development model of Alibaba and JD.com, achieving dual listings on U.S. stocks and the Hong Kong stock market, and diversifying risks caused by policy fluctuations in a single market. This global capital competition triggered by the SEC's relaxation is essentially a "value competition" for high-quality enterprises. While policy dividends can lower listing thresholds, the core competitiveness and compliance management capabilities of enterprises are the foundation of long-term development. © 2021 Meishun (Hong Kong) Management Consulting Co., Ltd. and Meishun (Hangzhou) Management Consulting Co., Ltd. All rights reserved. Meishun Meiyin (Hangzhou) Consulting Management Co., Ltd. is the domestic subsidiary of Hong Kong Meishun Management Consulting Company under the same ultimate controlling shareholder. Both companies are under the same Chinese management, and comply with the laws of Hong Kong and mainland China.