Small companies on stock exchanges: how 10 growth markets compare
EditorialBy TrustList Editorial
AIM sets no minimum trading record; India's SME platforms want three years and a profit test. Nomu admits only qualified investors. We compared entry rules, advisers, who may buy and insider lock-ins on ten growth markets.
About Small companies on stock exchanges: how 10 growth markets compare
Small companies on stock exchanges: how 10 growth markets compare
A software company does not have to be large to have shares that anyone can buy. In the past fortnight our reports have covered a Swedish e-commerce consultancy announcing cost cuts as a company listed on Nasdaq First North, a payments company raising equity through a release on the same market, a takeover that will cancel an AIM listing in London, and a Canadian security company whose sale needs the approval of the TSX Venture Exchange. All of them sit on growth markets: exchanges or segments built for companies too young or too small for a main market.
These markets matter to founders as a route to capital and to an exit, to early investors as the moment their shares can finally be sold, and to buyers of software as a source of public information about suppliers that would otherwise publish nothing. We compared the rules of ten of them, read on the exchanges' and regulators' own documents, to see how high the bar to entry is, who has to vouch for the company, who may buy the shares, and how long insiders must wait to sell.
The answer varies more than the shared label "SME market" suggests. London's AIM sets no minimum trading record at all; India's SME platforms require three years and a profit test. Some markets let anyone buy; Saudi Arabia's Nomu admits only qualified investors. Insider lock-ins run from none in the harmonised Euronext Growth rules to three years for Indian promoters.
How we compared them. We read each market's rulebook, listing criteria or regulator notice on 14 October 2026: SEBI's board papers on the 2025 SME reforms and NSE's Emerge criteria, the AIM Rules for Companies of August 2026, Euronext's Growth rule book, Nasdaq's First North rulebook of 1 August 2026, Deutsche Börse's Scale segment overview of July 2026, TSX Venture Exchange Policies 2.1 and 5.4, the Japan Exchange Group's Growth Market criteria, the Pakistan Stock Exchange's GEM Board chapter and June 2026 listing deck, the Capital Market Authority's November 2025 notice on Nomu, and Hong Kong Exchanges' GEM reform conclusions. Some Indian pages were read through archived copies because the live sites refused our requests. We give no market-wide counts of listings or money raised.
The ten markets side by side
| Market | Minimum history before listing | Adviser the company must keep | Who may buy | Insider lock-in in the rules |
|---|---|---|---|---|
| NSE Emerge and BSE SME, India | 3 years; operating profit of Rs 1 crore in 2 of the last 3 years | SEBI-registered merchant banker | Public, minimum application of two lots, above Rs 2 lakh | Promoters' minimum 20% locked for 3 years |
| AIM, UK | None set; the nominated adviser judges suitability | Nominated adviser at all times | Not restricted | 12 months for related parties and employees if the business is under 2 years old |
| Euronext Growth | 2 years of audited accounts | Listing sponsor | Not restricted; public offers possible | None in the harmonised rules |
| Nasdaq First North, Nordics | 12 months of operations | Certified adviser | Not restricted | None required |
| Scale, Deutsche Börse | 2 years of audited accounts, plus 3 of 5 size tests | Capital market partner | Not stated in the overview | Not stated |
| TSX Venture Exchange, Canada | Tier tests on assets, revenue or financing | Not covered here | Public | Principals' shares released over 18 months (Tier 1) or 36 months (Tier 2) |
| TSE Growth, Japan | 1 year as a stock company, 2 years of audited accounts | Not stated on the pages read | Public | Not stated |
| PSX GEM Board, Pakistan | 2 years of audited accounts | Advisor to the issue | Eligible investors with net assets of at least Rs 15 million; public only with a prospectus | Sponsors keep 25% for 3 years |
| Nomu, Saudi Arabia | Not covered here | Not covered here | Qualified investors only | Not covered here |
| HKEX GEM, Hong Kong | 2 years, with cash-flow or revenue and R&D tests | Sponsor, then a compliance adviser | Professional and retail investors | Controlling shareholders: 6 months, then 6 months without losing control |
Three things stand out from the table.
The first is that the gatekeeper differs. In India and Hong Kong the entry test is written into the rules as numbers: profits, cash flow, market value. In London and the Nordics the rules set almost no numbers and put the judgement on an adviser who must stay with the company. AIM's nominated adviser decides whether a company is appropriate for the market, owes its duties to the exchange rather than to investors, and if a company loses its nominated adviser, trading is suspended and the listing is cancelled after six weeks.
The second is that retail access is a policy choice, not a given. India raised the minimum application on SME issues to two lots, worth more than 2 lakh rupees, precisely to keep smaller savers out of risky offers. Pakistan's GEM Board is aimed at investors with net assets of at least 15 million rupees. Saudi Arabia's Nomu remains for qualified investors only; in November 2025 the Capital Market Authority widened that group by halving the trading-volume test for individuals to 20 million riyals of trades in the past year.
The third is that lock-ins protect new shareholders from insiders selling straight after listing, and the strictest markets are the ones open to the widest public. India locks the promoters' minimum contribution of 20 per cent for three years. Canada's escrow releases founders' shares in stages over up to three years. Euronext Growth and First North leave lock-ups to the agreement between the company and its banks.
India: the most rule-bound route
SEBI rewrote its rules for SME listings in 2025 after a surge of small issues. The board's decisions of April 2025 set an operating profit test of 1 crore rupees in two of the last three years, having consulted on 3 crore. Selling shareholders may offer no more than 20 per cent of the issue and no more than half of their own holding. Money raised for general corporate purposes is capped at 15 per cent of the proceeds or 10 crore rupees, whichever is lower, and a monitoring agency is required when the fresh issue exceeds 50 crore rupees. The board rejected proposals for a 10 crore rupee minimum issue, quarterly reporting and a five-year promoter lock-in.
NSE's Emerge platform also requires positive net worth, positive free cash flow to equity in two of three years, and promoters with three years' experience in the business holding at least 20 per cent after the issue. Its rules for moving up to the main board, effective 1 May 2025, require three years on the SME platform, an average market value of at least 100 crore rupees, revenue above 100 crore rupees, net worth of at least 75 crore rupees and at least 500 public shareholders.
UK and Europe: advisers in place of thresholds
AIM changed its rules on 5 August 2026 after a short consultation. The working capital statement in the admission document gave way to disclosure of capital resources, UK accounting standards are now accepted, a new Capital Access Window lets a company suspend its shares briefly to negotiate a fundraising, and the comply-or-explain approach to governance codes was replaced by a disclosure rule. Investing companies still need to raise at least 6 million pounds in cash. Companies report half-yearly within three months and publish audited accounts within six.
For companies that want their shares to trade without a public market, the FCA's PISCES sandbox allows trading events in private company shares for sophisticated, high-net-worth and institutional investors and employees. The FCA's page names four approved operators. It is a way for early investors to sell before any listing, not a way to raise new money.
Euronext Growth asks for two years of audited accounts and at least 2.5 million euros of shares available for trading at first admission, with a listing sponsor at admission and afterwards. First North requires only 12 months of operations, which may be loss-making, working capital for the next 12 months, at least 10 per cent of shares in public hands and at least 300 qualified shareholders, or fewer with a liquidity provider. Shares that holders have promised not to sell for a long period do not count as public, which is why companies agree lock-ups with their investors anyway. Germany's Scale segment asks for two years of history, a 10 per cent free float and three of five size tests, including turnover of at least 10 million euros or at least 20 employees.
Asia, the Gulf and Canada
Tokyo's Growth Market keeps a low entry bar, one year as a stock company and 150 shareholders, but has raised the bar for staying listed. From financial years ending on or after 1 March 2030, a company must reach a market value of 10 billion yen within five years of listing, rather than 4 billion yen within ten; from 31 December 2025, companies listing below that value must publish a growth plan on listing day. A company that falls short may move to the Standard Market.
Hong Kong reformed GEM from 1 January 2024. Alongside the old test of a 150 million Hong Kong dollar market value and 30 million of operating cash flow over two years, it added a route for research-heavy companies: a 250 million dollar market value, 100 million in revenue over two years with growth, and research spending of at least 30 million dollars and 15 per cent of operating costs. Mandatory quarterly reports were dropped, and the lock-up for controlling shareholders was halved.
Pakistan's GEM Board requires a public company with two years of audited accounts, paid-up capital of at least 25 million rupees after the issue, and at least 10 per cent of shares offered. Sponsors must keep 25 per cent of the company for three years. The exchange's June 2026 presentation says there is no profit requirement, although the general public offering conditions it also lists include a two-year profit record, so a company should confirm the test that applies with its adviser.
The TSX Venture Exchange sets tiered tests. For a Tier 2 technology company, one route is net tangible assets of 750,000 Canadian dollars, revenue of 500,000 dollars or arm's-length financing of 2 million dollars, together with working capital for 12 months and at least 200 public shareholders holding 20 per cent of the shares. Founders' shares go into escrow and are released in stages. Shareholders who bought before the listing but are not principals face a one-year hold with 20 per cent released every three months, shortened if the share price holds up.
What early investors and founders should check
For an angel or seed investor, a listing on a growth market is usually the first chance to sell, and the rules decide how soon:
- Read the lock-in that applies to your class of holder. Indian promoters wait three years for the core stake; Canadian principals wait up to three years; AIM related parties of a young business wait 12 months; under the harmonised Euronext Growth and First North rules, the lock-up is whatever the company agrees with its banks.
- Expect thin trading. Growth-market shares often trade little, which is why First North counts qualified shareholders and allows liquidity providers, and why Hong Kong's route to the Main Board tests daily turnover.
- Know the cost of staying listed. A permanent adviser, half-yearly reporting and audited accounts within a few months of year end are ongoing costs a small company carries for as long as it is listed.
- Watch for exits by takeover. Several software companies in our reports are leaving growth markets through a sale rather than moving up to a main market, as with Tribal's AIM listing, which will be cancelled if its sale is approved.
A last word from the investor's side. A 2021 note from the UK broker Freetrade argued that in hot markets companies and their banks both want the highest price, so buyers of new issues often overpay, and advised buying only where there is a profit record and a sensible price. The same caution applies with more force on growth markets, where the entry bar is lower and the shares harder to sell.
Listed companies in our catalogue
Our business news page reports listings, takeovers and filings by listed software and IT companies, including Infomaniak's listing on SIX Swiss Exchange, and our funding guides cover the earlier stages of raising money, from angel tax reliefs to public co-investment.
Sources
- SEBI, Review of SME framework under the ICDR Regulations, board memorandum (January 2025): https://www.sebi.gov.in/sebi_data/meetingfiles/jan-2025/1735725342588_1.pdf
- SEBI, board decisions on the SME framework (April 2025): https://www.sebi.gov.in/sebi_data/meetingfiles/apr-2025/1744257912630_2.pdf
- NSE, Emerge eligibility criteria: https://www.nseindia.com/static/companies-listing/raising-capital-public-issues-emerge-eligibility-criteria
- NSE, circular NSE/CML/67671 on migration to the main board (24 April 2025): https://nsearchives.nseindia.com/content/circulars/CML67671.pdf
- London Stock Exchange, AIM Rules for Companies (August 2026): https://docs.londonstockexchange.com/sites/default/files/documents/AIM%20Rules%20for%20Companies%20-%20August%202026.pdf
- London Stock Exchange, AIM Notice 64 (5 August 2026): https://docs.londonstockexchange.com/sites/default/files/documents/AIMNOT~2.PDF
- Financial Conduct Authority, PISCES (updated 31 July 2026): https://www.fca.org.uk/firms/pisces
- Euronext, Euronext Growth Markets Rule Book, Book I (effective 2 May 2024): https://www.euronext.com/sites/default/files/2024-04/euronext_growth_harmonised_rulebook_i.pdf
- Nasdaq, First North Growth Market Rulebook for Issuers of Shares (1 August 2026): https://www.nasdaq.com/docs/2026/07/01/Nasdaq-First-North-Growth-Market-Rulebook-1-August-2026-TC.pdf
- Deutsche Börse, Segment overview (July 2026): https://www.cashmarket.deutsche-boerse.com/resource/blob/4508482/673c20fc3e0513c69ea9604583c3e3af/data/Segment%20overview%20EN.pdf
- TSX Venture Exchange, Policy 2.1 Initial Listing Requirements: https://www.tsx.com/en/resource/421
- TSX Venture Exchange, Policy 5.4 Capital Structure, Escrow and Resale Restrictions (2 June 2025): https://www.tsx.com/en/resource/445
- Japan Exchange Group, revision to the Growth Market's continued listing criteria (26 September 2025): https://www.jpx.co.jp/english/news/1020/sjcobq00000283qb-att/sjcobq00000283u0.pdf
- Japan Exchange Group, Growth Market initial listing criteria (updated 14 November 2025): https://www.jpx.co.jp/english/equities/listing/criteria/listing/02.html
- Pakistan Stock Exchange, Rule Book Chapter 5A: https://www.psx.com.pk/psx/themes/psx/uploads/Chapter-5A.pdf
- Pakistan Stock Exchange, GEM Board listing presentation (19 June 2026): https://www.psx.com.pk/psx/themes/psx/uploads/Listing-Presentation-GEM-Board-19-06-26.pdf
- Capital Market Authority, Saudi Arabia, news on qualified investors in the parallel market (26 November 2025): https://cma.gov.sa/en/MediaCenter/NEWS/Pages/CMA_N_3929.aspx
- Hong Kong Exchanges and Clearing, Consultation Conclusions on GEM Listing Reforms (December 2023): https://www.hkex.com.hk/-/media/HKEX-Market/News/Market-Consultations/2016-Present/September-2023-GEM-Listing-Reforms/Conclusions-Dec-2023/cp202309cc.pdf
- Freetrade, "Should you buy into IPOs?" (updated 22 July 2021): https://freetrade.io/news/should-you-buy-into-ipos
- TrustList reports on Tribal, Plurilock, Avensia, Trustly and Infomaniak, linked from our business news and news pages.
Categories & features
- India
- United Kingdom
- Europe
- Germany
- Canada
- Japan
- Pakistan
- Saudi Arabia
- Venture Capital
- SME
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