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SRFC Client Alert: SEC Approves Nasdaq’s New $5 Million Market Value of Listed Securities Continued Listing Requirement

July 22, 2026

Overview

On July 22, 2026, the Securities and Exchange Commission (“SEC”) issued an order approving Nasdaq’s new rules requiring listed companies to maintain a Market Value of Listed Securities (“MVLS”) of at least $5 million.

Key Takeaways

  1. New $5 Million MVLS Minimum for All Nasdaq-Listed Companies. Under the new rules, every company listed on the Nasdaq Global Select Market, Nasdaq Global Market, or Nasdaq Capital Market must now maintain an MVLS of at least $5 million as an ongoing condition of listing. This requirement applies across all three Nasdaq tiers.
  2. Immediate Suspension and Delisting for Noncompliance. If a company’s MVLS falls below $5 million for 30 consecutive business days, Nasdaq staff will issue a staff delisting determination, the company’s securities will be immediately suspended from trading and delisting proceedings will commence. Shares will then generally begin trading on the over-the-counter market.
  3. No Cure or Compliance Period. Unlike certain other continued listing deficiencies (which afford companies an opportunity to submit a compliance plan or benefit from a cure period), the MVLS requirement provides no such relief.
  4. No Automatic Stay Pending Appeal; Limited Hearings Panel Discretion. A timely request for a hearing before the Nasdaq Hearings Panel will not automatically stay the suspension of trading. The Hearings Panel may, in its discretion: (a) reverse the delisting determination only if it was made in error, or (b) grant an exception of up to 180 days for the company to demonstrate compliance with Nasdaq’s initial listing standards (which are generally higher than continued listing standards). An adverse decision may be further appealed to the Nasdaq Listing and Hearing Review Council.

You can read the SEC’s order here.

If you have any questions regarding this client alert, please call or e-mail your SRFC attorney.

DISCLAIMER: This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions.