The scenario: an 800-million-dollar startup picks its IPO home turf
VietSwift, a Vietnamese logistics startup valued at 800 million USD after its Series C, targets an IPO within three years. Management has decided to place its regional headquarters in Singapore or Hong Kong, with one decisive criterion: the headquarters should sit close to the exchange where the company will list, to tap the fundraising ecosystem, investors and advisers. This article compares the listing requirements and fundraising environments of SGX and HKEX from an investor’s standpoint.
Listing requirements: SGX Mainboard
The Singapore Exchange requires Mainboard candidates to demonstrate a profit track record: profits in recent years above minimum thresholds, or alternatively a minimum market capitalisation test. This approach favours businesses with stable cash flows and real earnings, such as logistics, manufacturing and property companies past their cash-burning growth phase.
SGX is also Asia’s largest REIT market, giving groups with rental assets, warehouses or data centres an extra route to list assets alongside an ordinary share IPO.
Listing requirements: HKEX Main Board
The Hong Kong Exchange sets out three flexible tests in Chapter 8 of its Listing Rules: (1) market capitalisation with profit, (2) market capitalisation with revenue, and (3) market capitalisation with positive cash flow. An applicant needs to pass only one, so fast-growing but not yet highly profitable companies, such as technology and e-commerce players, still qualify if revenue or cash flow is strong enough.
HKEX’s distinctive plus is the Stock Connect bridge to mainland Chinese investors, a source of share demand SGX cannot offer, plus a long tradition of handling the region’s largest IPOs.
Comparing the post-IPO fundraising environment
Follow-on fundraising: HKEX offers depth in placements, convertible bonds and hybrid capital instruments, serving cross-border expansion well. SGX is leaner, with lower disclosure compliance costs, suiting companies that want to stay listed while controlling expenses.
Institutional investors: Hong Kong hosts the region’s densest cluster of investment funds, investment banks and brokerages; Singapore is strong in venture capital, sovereign wealth funds and family offices, an advantage for private funding rounds ahead of an IPO.
Cost and preparation time: listing on HKEX typically demands a larger advisory team and higher costs; SGX is regarded as more practical and less expensive for mid-sized issuers.
The Vietnam angle: domestic companies reaching foreign boards
For Vietnamese companies, a foreign listing must rest on a proper legal structure: a Singapore or Hong Kong parent holding the Vietnamese operating company, consistent with the Law on Investment 143/2025/QH15 (effective 1 March 2026, replacing the Law on Investment 61/2020/QH14) on investor rights and protection, alongside foreign exchange compliance when moving capital and profits across borders. This structure should be built at least 18 to 24 months before the target IPO date to clean up books and related-party transactions.
Conclusion and action plan
VietSwift and peers should choose by financial profile: stable profits and a wish for reasonable listing costs point to SGX; hot growth needing capital depth and mainland Chinese demand point to HKEX. Either way: (1) test early which listing test you can pass; (2) set up the parent in the right jurisdiction early; (3) review related-party transactions with the Vietnamese subsidiary under Decree 255/2026; (4) engage listing advisers at least two years before the IPO.
Frequently asked questions
Which exchange is easier for a not-yet-profitable company, SGX or HKEX?
HKEX is more flexible thanks to the three market capitalisation, revenue and cash flow tests in Chapter 8 of its Listing Rules, letting fast-growing but loss-making companies qualify on revenue or cash flow. SGX weighs the profit track record more heavily.
What investor advantage does a Hong Kong listing bring?
The biggest plus is the Stock Connect link to mainland Chinese investors, combined with a dense community of investment banks and institutional funds that absorbs large IPOs and follow-on offerings well.
What must a Vietnamese company watch at home when listing abroad?
It needs an offshore parent holding the Vietnamese company in line with the Law on Investment 143/2025/QH15, foreign exchange compliance for capital and profit transfers, and a clean-up of related-party transactions under Decree 255/2026 before the IPO.
Where does SGX beat HKEX?
SGX is Asia’s largest REIT market, has lower listing compliance costs, and a strong venture capital and family office ecosystem, ideal for pre-IPO private rounds and asset-listing structures.
FLAT Law Firm stands with investors
FLAT Law Firm advises on cross-border group structuring, setting up parent companies in Singapore or Hong Kong, and legal preparation for Vietnamese companies heading toward an international listing. Contact us to build the right IPO roadmap.
This article has been quality-reviewed by the FLAW AI Legal Council