Distinguish the ordinary transfer from the streamlined route
HKEX Rule Update No. 144 records that the GEM reform rules took effect on 1 January 2024. This article follows the consolidated Main Board rules linked from the current Main Board directory and focuses on Chapter 9B for ordinary non-mineral issuers. Rule 9B.02 applies Chapter 9A with Chapter 9B's additions, modifications and exceptions. Missing a streamlined condition does not automatically qualify an issuer for the ordinary route; check Chapter 9A separately.
Separate three periods in the evidence file
| Check | What to document | Why the filing date is not enough |
|---|---|---|
| Financial results | Compliance with GEM Rule 18.03 for the three full financial years beginning after initial GEM listing | This is not simply 36 months since listing |
| Control and principal business | Ownership and control and material transactions from the three full financial years immediately before application through the start of Main Board dealings | Check continuity of ownership and control and whether a transaction fundamentally changed the principal business |
| Market capitalisation and turnover | The rule-defined period starting 250 trading days immediately before application and running through the start of Main Board dealings, excluding days of a halt or suspension in the issuer's securities | Monitor through commencement, not just one closing price or an active week |
Rule 9A.02 also requires checks against the applicable Main Board qualifications and conditions on serious breaches, investigations and disciplinary proceedings, each with its own period or checkpoints. Our guide to the three Main Board financial tests explains the admission tests, but a transfer must also be read under Chapters 9A and 9B. Mineral companies have additional conditions outside this article's scope.
Trading data must meet two different tests
Under Rule 9B.03, volume-weighted average market capitalisation over the reference period must meet the applicable Main Board minimum. The rule builds daily capitalisation from the issued share count in the relevant GEM return and the intraday volume-weighted price, then weights each day by its share of the period's trading volume, with adjustments for relevant corporate actions. It is not a simple average of daily capitalisations.
Separately, daily turnover must reach HK$50,000 or more on at least 50% of trading days over the reference period. Suppose 124 of the 250 eligible trading days at application meet HK$50,000. That is 49.6%, below the turnover threshold even if a handful of sessions were especially active. This example is hypothetical. Passing the turnover test does not establish compliance with the capitalisation, financial or other conditions, and the checks continue after application.
The prospectus exemptions do not remove working capital evidence
Rule 9B.04 exempts specified requirements concerning sponsor and, where applicable, sponsor-overall coordinator appointment and obligations, and certain prospectus and publication procedures. Although the Rule 8.21A listing-document statement does not apply, Rule 9B.05 still requires a formal Form G application, an advanced draft transfer announcement and a supported written working capital confirmation. For an ordinary issuer, this covers at least the next 12 months from publication of the announcement. The rule also calls for support from the financial advisers or auditors regarding due and careful enquiry and written evidence of financing facilities. The sponsor exemption does not eliminate financial documentation or professional checks.
Track filing, approval in principle and actual dealings separately
Under Rule 9B.07 the applicant must obtain any required shareholder, board and regulatory approvals. Rule 9B.08 requires an announcement as soon as reasonably practicable and no later than one business day after formal in-principle approval from the Exchange, and at least five clear business days before intended Main Board dealings. Rule 9B.09 requires information including the reasons for transfer, reference-period data and the dates Main Board dealings are to start and GEM dealings are to end. Record the filing, scheduled dates and evidence of actual commencement separately. A transfer is not itself a fresh share issue and should not be counted directly as IPO proceeds.
What a private startup can prepare now
Rather than promise a quick route to the Main Board in a fundraising deck, maintain auditable records of ownership changes, business transactions and cash flows. Jimhang Capital, founded by Justin Zhan, can discuss general venture preparation and resource introductions at justin@jimscapital.cn using a non-confidential description of the project stage and question. This does not suggest the firm acts as a sponsor, underwriter or regulatory adviser.
Site editorial analysis as of 9 November 2026. This is not a report of a new listing, an individual eligibility determination, transaction advice or a listing guarantee.