Singapore's Strategic Play: The SGX-Nasdaq Dual Listing Bridge

A calculated regulatory framework positions Singapore to capture high-value Asian growth companies seeking simultaneous access to U.S. and Asian capital markets.

On 19 November 2025, SGX and Nasdaq announced a landmark collaboration to establish a dual listing bridge connecting both exchanges, providing companies in Asia with market capitalisation of S$2 billion and above with a direct and harmonised pathway to simultaneously access growth capital and liquidity across the U.S. and Asia. Beyond the headline, this initiative represents a sophisticated repositioning of Singapore's equities market, one that could fundamentally reshape where Asian growth companies choose to raise capital and structure their investor base.

Singapore's equities market has faced challenges resulting in fewer high-quality listings and lower trading volumes in recent years. The Monetary Authority of Singapore (“MAS”) announced in August 2024 that it had set up a review group (“Review Group”) to strengthen equities market development in Singapore. The Review Group issued its final report on 19 November 2025, following other measures announced earlier in the year. 

The Review Group's work has been guided by the recognition that there is no single "silver bullet" to revitalise Singapore's equities market—instead, a holistic ecosystem-wide approach is required, spanning demand and supply-side measures, market connectivity and trading initiatives, complemented by regulatory shifts towards a more disclosure-based regime while strengthening investor confidence and protection. The dual listing bridge sits within this broader framework. Issuers will be able to use a single set of offering documents and go through a simplified review process, with the arrangement envisaged to go live around mid-2026.

Strategic Segmentation and Competitive Positioning

The proposed dual listing bridge and its accompanying requirements reveals Singapore's strategic positioning in the competitive landscape for Asian listings and how Singapore hopes to differentiate itself from regional alternatives.

Singapore's distinctive value proposition

The Review Group noted that while many Asian growth companies aspire to list in the U.S., smaller and mid-sized issuers often struggle to sustain investor interest post-listing. Singapore can be a good listing venue for these enterprises, particularly those with a regional nexus and looking to build brand recognition and investor familiarity. This insight is central to Singapore’s competitive positioning.

While the Hong Kong capital markets have experienced a resurgence in 2025, its growth has been driven primarily by a specific segment: mainland Chinese companies, particularly in "hard tech" and "new quality productive forces" sectors, seeking international listings to access global capital whilst maintaining mainland China connections. Hong Kong's structural advantages for this segment are formidable: amongst others, it provides unparalleled access to mainland Chinese capital through the Stock Connect programme, enhanced RMB interest-rate swap access through Swap Connect, deep familiarity with Chinese corporate structures, and established networks of China-focused institutional investors.

Singapore’s dual listing bridge offers what Hong Kong’s model currently may not be able to: harmonised access to U.S. and Asian capital markets through streamlined regulatory processes, free from the geopolitical complexity of Chinese approvals and U.S.-China tensions. For Southeast Asian tech platforms, Indian growth companies, and other non-Chinese Asian enterprises, this bridge fills a critical gap. Current dual listings are costly and duplicative; the proposed framework—one set of offering documents and a simplified review—significantly reduces these frictions.

The threshold as competitive positioning

The S$2 billion threshold reflects a pragmatic competitive assessment. Singapore cannot realistically compete with Hong Kong's structural advantages for mainland Chinese companies, nor match its scale and liquidity. However, for companies of a substantial size and with Asian connections pursuing global ambitions, Singapore offers genuine differentiation and has chosen to focus its resources on this segment. From a legal and advisory perspective, this segmentation creates clear parameters. Companies that satisfy the threshold are availed a differentiated option meriting comparative analysis.

Inverse Opportunities

Further, while the dual listing bridge appears to be principally designed to give Asian high growth companies a seamless pathway into the US markets, it also creates an inverse opportunity – one that resonates with themes highlighted by our colleagues in the UK in “London Calling: Opportunities for US Companies on the London Stock Exchange”, in particular, with the recent changes to the listing requirements in the U.S., smaller U.S. private companies, particularly those with growth potential, are increasingly looking beyond domestic exchanges. London’s appeal – access to international institutional investors, lower ongoing compliance costs, and stronger support for mid-cap growth companies, illustrates that some U.S. issuers are already prepared to consider non-U.S. listing venues to access international capital, diversify investor bases, and benefit from regulatory regimes better suited to growth-stage issuers. Many of the considerations they identify for US companies evaluating a London IPO—market segmentation, cost-efficiency, active institutional investor bases, and listing structures that support scaling—apply equally when assessing Singapore as a complementary or alternative listing venue. 

For U.S. companies with meaningful Asia-Pacific operations, customers or expansion ambitions, an SGX dual listing offers significant advantages. The bridge avoids duplicative prospectuses and regulatory timelines, addressing pain points common in traditional dual or secondary listings. This can provide, amongst others, direct access to Asian institutional investors and growing Southeast Asian capital pools. It also offers regional brand and stakeholder visibility, supporting commercial growth across Asia. Additionally, it provides a neutral alternative to China-centric listing venues, with simpler geopolitical dynamics and strong regulatory alignment with global standards.

Regulatory Efficiency: The Harmonisation Proposition

MAS had earlier announced that it intends to streamline prospectus disclosure requirements for both primary and secondary listings. These regulatory reforms support the dual listing framework and offer material competitive advantage but require careful implementation as it must balance genuine harmonisation, which may require Singapore to accept U.S. regulatory standards in many areas, with maintaining adequate investor protection and market integrity standards. The implementation of the dual listing bridge remains subject to the completion of relevant regulatory processes. In this regard, MAS intends to work with SGX to consult on the regulatory framework for a set of prospectus disclosure requirements comparable to that of the US. These implementation details will be critical — Will Singapore accept U.S. GAAP financial statements without reconciliation? How will differences in continuous disclosure obligations, divergent corporate governance requirements and related party transaction rules be addressed?

The Supporting Infrastructure: A Comprehensive Ecosystem Approach

This initiative is supported by comprehensive infrastructure addressing historical competitive barriers, creating a holistic ecosystem designed to attract and support quality listings.

Capital commitment and liquidity

MAS announced a second batch of six appointed asset managers under the Equity Market Development Programme (“EQDP”), with a combined allocation of S$2.85 billion, bringing the total capital deployed to S$3.95 billion across nine asset managers employing varied investment strategies. A third batch of EQDP managers is expected to be appointed in 2Q 2026, further expanding the diversity of participating asset managers and investment strategies. This capital creates assured demand for new issuances and supports post-IPO liquidity, addressing a critical competitive disadvantage versus deeper liquidity pools on other exchanges. 

Corporate governance and value creation support

MAS will allocate S$30 million to fund two grants: the Equip Grant providing up to S$15,000 per listed company for training in investor relations, media training, corporate strategy or financial management; and the Elevate Grant providing up to S$200,000 per listed company for professional consultancy services to support companies undertaking more extensive strategies and demonstrating growth potential. To address concerns from listed companies about potential legal exposure when providing information about forward-looking plans and projections, MAS will review how to provide regulatory clarity, signalling movement towards frameworks that encourage proactive disclosure whilst protecting against liability for good-faith projections, a material consideration for companies accustomed to U.S. safe harbour provisions. 

Market-making and liquidity enhancement

MAS and SGX plan to develop initiatives to help market makers build capabilities particularly for newly listed stocks and next-tier small- and mid-cap stocks, with details to be announced in 1Q 2026. In addition, SGX plans to modernise post-trade custody to facilitate wider investor adoption of broker custody accounts as well as reduce board lot size for securities trading above S$10 from 100 to 10 units - these measures collectively address practical barriers around liquidity, execution costs, and investor access.

Conclusion: Implications for Companies

For companies and their advisers, the dual listing bridge creates a genuinely new and differentiated option meriting careful and sophisticated evaluation. Notwithstanding the harmonisation envisaged, dual listings still involve substantial costs that must be weighed against tangible benefits in capital access, valuation improvement, strategic optionality, and competitive positioning.

Regulatory compliance and future flexibility: Companies must evaluate dual compliance burdens even with harmonised offering documents. Financial reporting standards, continuous disclosure triggers, corporate governance requirements, and takeover code provisions may differ materially between jurisdictions. The dual listing structure also affects future corporate actions—mergers and acquisitions, capital raising, restructurings, and potential delisting scenarios. Advisers must evaluate these scenarios comprehensively and identify potential longer term issues to be mitigated upfront as far as possible.

Liability exposure: Dual listing may create exposure to regulatory enforcement and private litigation in multiple jurisdictions. U.S. securities law provides extensive private rights of action including class action mechanisms. Companies require enhanced due diligence, comprehensive directors' and officers' insurance, robust disclosure controls, and ongoing access to qualified counsel in both jurisdictions.

Shareholder base management: Dual listing creates distinct constituencies with different investment horizons, liquidity expectations, and governance priorities. Companies must develop sophisticated investor relations strategies addressing both markets whilst managing potential conflicts.

The measures proposed by the Review Group aim to strengthen the competitiveness of Singapore's equities market by addressing supply, demand, and the regulatory environment in a holistic manner, positioning Singapore as a resilient platform for local and regional enterprises to access global growth capital. Early indicators point to renewed interest after the initial measures introduced — average daily turnover in 3Q 2025 rose 16% year-on-year to S$1.53 billion, the highest since 1Q 2021, with IPO activity rebounding to more than S$2 billion in funds raised. However, the bulk of funds raised continues to be concentrated in REITs, and work remains to broaden attractiveness to other types of listings, particularly high-growth companies. Effective implementation of the Review Group’s measures will be critical to achieving intended outcomes - success should be measured not in absolute volumes but in whether Singapore attracts a critical mass of high-quality issuers that validate the market and create demonstration effects.

The proposal for the dual listing bridge represents sophisticated positioning focused on a segment where Singapore can offer differentiated value. While the regulatory framework, commercial infrastructure, and government support mechanisms may be substantial, detailed analysis of regulatory requirements, governance implications, cost-benefit considerations, and strategic fit remains essential.

This article is produced by our Singapore office, Bird & Bird ATMD LLP. It does not constitute legal advice and is intended to provide general information only. Information in this article is accurate as of 21 November 2025.