STAR Market Listing, ChiNext and Beijing Stock Exchange

Which board fits: STAR Market, ChiNext or Beijing Stock Exchange?

A STAR Market listing suits companies built on hard technology with heavy research spending; ChiNext suits innovative growth companies, including those applying technology to traditional industries; and the Beijing Stock Exchange (BSE) serves innovative small and medium-sized enterprises that have first been quoted on NEEQ. All three use registration-based review: the exchange examines the application through written inquiry and a listing committee, and the CSRC then decides on registration.

The decisive question is usually not whether the financial thresholds are met but whether the exchange accepts that the company fits the board's positioning. A profitable software company with modest R&D may meet STAR financial tests yet struggle to show the "hard technology" character the Shanghai exchange expects, while the same company could be a natural ChiNext candidate. Choosing the wrong board is one of the main causes of withdrawn applications.

STAR Market listing standards

The Shanghai Stock Exchange's STAR Market opened in 2019 as the pilot for registration-based IPOs. An applicant for a STAR Market listing chooses one of five sets of standards, each combining an expected market value with financial indicators. The figures below follow the exchange's published summary:

The rules contain further conditions, including on scientific and technological attributes, so the current text on the SSE STAR Market site should be checked before any decision.

The 2025 growth tier and later reforms

In June 2025 the CSRC announced a package of STAR reforms, including a Science and Technology Innovation Growth Tier. Unprofitable companies, both existing and newly listed, are placed in the tier and their stock names carry a "U" mark. Existing companies leave the tier on first becoming profitable; newly listed companies face stricter exit conditions set out in the SSE growth tier guidelines, and the exchange generally removes a qualifying company from the tier within two trading days of its announcement. Investors in newly registered growth-tier stocks must sign a dedicated risk disclosure.

The reforms also reopened the fifth standard to more sectors, encouraged (but did not require) issuers to disclose experienced professional institutional investors, and introduced an optional confidential pre-review for applicants whose technical information is sensitive. In June 2026 the SSE published guidelines applying the fifth standard to artificial intelligence large-model companies, requiring at least one model product already in large-scale use.

ChiNext listings

ChiNext, on the Shenzhen Stock Exchange, moved to registration in 2020. Its traditional standards focus on profitability or a combination of market value, profit and revenue, and the exchange has in recent years tightened scrutiny of companies whose innovation is thin. In April 2026 the CSRC introduced a further ChiNext standard with two tracks for high-growth companies:

• Emerging industries: expected market value of at least RMB 3 billion, revenue of at least RMB 200 million in the last year and compound annual revenue growth of at least 30% over three years.
• Future industries: expected market value of at least RMB 4 billion, revenue of at least RMB 200 million, at least RMB 100 million of R&D over three years and cumulative R&D of at least 15% of revenue. Companies listing on this track while unprofitable carry a "U" mark.

The same reform allows local governments, on a pilot basis, to provide the CSRC and the exchange with information on prospective applicants as a reference point for review. ChiNext also applies a negative list of industries it does not normally admit, such as traditional sectors without clear innovation, so a company in those sectors needs a convincing account of how technology changes its business model.

Beijing Stock Exchange listings

The BSE opened on 15 November 2021. It is closely tied to NEEQ: under current rules, an applicant must be an innovation-tier company that has been quoted on NEEQ for a continuous 12 months, measured from first quotation to the BSE listing committee meeting. Financial standards are lower than on the Shanghai and Shenzhen boards and combine market value with profit, revenue growth, R&D or cash-flow indicators. For many specialised SMEs, the NEEQ-to-BSE pathway is a realistic first step into public markets, discussed further on our NEEQ listings page.

The BSE route has a longer runway, because the 12-month NEEQ period must be planned in, but it offers disclosure discipline and a trading history before the public offering. BSE-listed companies that later meet the relevant conditions may also consider a transfer to the STAR Market or ChiNext under the exchanges' transfer rules, which makes the BSE a staging post for some issuers.

STAR Market listing compared with ChiNext and BSE

Three questions usually settle the choice. First, can the company credibly describe itself as hard technology with independent core know-how? If so, a STAR Market listing is the natural target. Second, is the company profitable or on a clear growth path in an emerging or future industry, with a business that applies technology rather than creates it? ChiNext may be the better fit. Third, is the company smaller, with lower market value, and able to wait for the 12-month NEEQ period? The BSE route may then be the most realistic.

Where the answer is unclear, early discussion with the sponsor's internal quality control team can test positioning before a public filing is made. Companies with sensitive technical information may also consider the STAR pre-review, bearing in mind that its opinions do not confirm eligibility or board fit.

The STAR Market listing process step by step

The broad sequence is similar on all three boards. The steps below follow a typical STAR Market listing; ChiNext and BSE applications follow the same logic with their own exchange rules.

1. Readiness review. Test board fit, financial standard, R&D accounting, shareholding history and compliance gaps; decide whether to use the optional pre-review.
2. Restructuring. Convert to a joint stock company, unwind any offshore or VIE structure where needed, and clean up related-party transactions and competing businesses.
3. Tutoring and filing. The sponsor carries out pre-listing tutoring registered with the local CSRC office, then files the prospectus and supporting documents with the exchange.
4. Inquiry rounds. The exchange issues written inquiry letters; responses are published, so each answer becomes part of the public record.
5. Listing committee and registration. The listing committee reviews the application; if approved, the CSRC decides on registration.
6. Offering and listing. Bookbuilding with institutional investors, strategic placement where used, pricing, and the start of trading, followed by lock-up and continuing disclosure obligations.

What reviewers focus on

Exchange inquiry letters tend to concentrate on a familiar set of themes: whether core technology is genuinely the company's own, the independence of the business from controlling shareholders, related-party transactions, revenue recognition and customer concentration, the history of share transfers and pre-IPO investments, and compliance with licensing, data and environmental rules. Sponsors face significant liability and regulators have pursued "listing with defects" cases, so diligence is intense.

Lock-up periods for controlling shareholders and pre-IPO investors are long, and for unprofitable companies reductions by controlling shareholders and management are further restricted until profitability. Valuation adjustment (VAM) arrangements and investor preferred rights granted in earlier funding rounds are normally expected to be terminated or neutralised before filing, which needs to be negotiated with investors well in advance.

Common mistakes

• Capitalising or classifying costs as R&D in a way the exchange will not accept, which can undermine the chosen standard.
• Relying on licensed-in technology without showing independent development capability.
• Leaving investor redemption or anti-dilution rights in place until late in the process.
• Underestimating how long an offshore structure takes to unwind, including foreign exchange registrations.
• Inconsistent disclosure between an onshore prospectus and earlier materials prepared for Hong Kong or US investors.

Readiness checklist before appointing a sponsor

• A clear one-page account of the company's core technology, who developed it and how it is protected by patents, software copyright or trade secrets.
• Three years of audited or audit-ready accounts under PRC accounting standards, with R&D costs tracked by project.
• A complete capitalisation history, including every share transfer, capital increase, nominee arrangement and employee shareholding platform.
• An inventory of investor rights granted in each funding round and a plan to terminate or suspend them.
• Licences, permits, environmental approvals, data compliance records and social insurance contributions for every operating entity.
• A map of related parties, intra-group transactions and any business that competes with the controlling shareholder's other interests.

Life after listing: continuing obligations

A listing is the beginning of a continuing relationship with the exchange and the CSRC. Listed companies must publish periodic reports, disclose material events promptly, follow related-party transaction approval rules and observe restrictions on share reductions by controlling shareholders, directors and senior managers. Under the revised Company Law and CSRC transitional arrangements, A-share companies now use a board audit committee in place of a supervisory board, and independent directors carry defined responsibilities.

For foreign shareholders, the practical consequence is that decisions once taken informally within the group, such as intra-group pricing, guarantees or management appointments, now need board process and often public disclosure. Share disposals after the lock-up must follow the reduction rules, which limit the pace and method of sales and require advance announcements in many cases. Insider dealing and short-swing profit rules apply to shareholders above set thresholds as well as to directors.

Groups should therefore build a listed-company compliance calendar before trading begins and train regional executives who sit on the board. Our listed company advisory and disclosure page explains these obligations in more detail. Enforcement for misstatement has intensified, and the CSRC and courts have used the representative action mechanism for securities misrepresentation, which raises the stakes of a poorly prepared prospectus.

Foreign investors and cross-border issues

Foreign-invested companies can list on all three boards, subject to the foreign investment negative list and any security review. Offshore structures normally need to be unwound onshore, and foreign shareholders' exits are constrained by lock-ups and foreign exchange procedures. Employee incentive plans with foreign participants, and investors holding through offshore funds, need particular attention; see employee equity incentive plans and foreign exchange compliance.

Investor suitability rules restrict which retail investors may trade on each board, which affects liquidity and should inform valuation expectations. Foreign institutional investors can participate in A-share offerings and secondary trading through the qualified foreign investor regime and, for eligible stocks, Stock Connect from Hong Kong.

STAR Market listing or Hong Kong?

Many technology companies weigh a STAR Market listing against a Hong Kong IPO under Chapter 18A or 18C, and some plan for both. The choice turns on where the investor base understands the business, whether foreign investors need a freely convertible exit, US-related risks for some sectors, and how much time the company can spend on a restructuring.

Hong Kong may suit companies with USD-funded shareholders and international ambitions; an onshore listing may give deeper domestic valuation and policy support for strategic sectors. See HKEX Chapter 18A and 18C listings for the alternative. Investors from the US, EU and ASEAN should also check their own sanctions and outbound investment rules before committing to pre-IPO rounds in sensitive technology sectors.

How TRW & Co helps

We help foreign investors, founders and multinational parents understand how a STAR Market listing, a ChiNext IPO or a BSE listing works and how an onshore listing affects their position. We advise on offshore structures, shareholder and investment agreements governed by non-PRC law, and the cross-border steps needed to bring a group onshore, and we coordinate with sponsors and auditors on timetable and diligence. We compare onshore routes with Hong Kong and US listings where both are open. PRC legal opinions, exchange submissions and other Mainland legal work are handled by licensed PRC law firms, with whom we work closely. To discuss an onshore listing, please contact us.