HKSI Paper 1 Accessing public capital question: Starfield Robotics Ltd seeks a Chapter 18C listing in November

HKSI Paper 1Accessing public capital

Starfield Robotics Ltd seeks a Chapter 18C listing in November 2026. Revenue from its specialist technology segment was HK$180 million in its latest audited year, and its expected market capitalisation is HK$6.5 billion. Can it list?

A No: every Chapter 18C applicant needs a market capitalisation of at least HK$10 billion
B Yes: revenue above HK$150 million makes it a Commercial Company under Chapter 18C
C Yes: as a Commercial Company it exceeds the HK$4 billion minimum that now applies
D No: below HK$250 million revenue it is Pre-Commercial and needs at least HK$8 billion

Show the answer and explanation

Answer: D. No: below HK$250 million revenue it is Pre-Commercial and needs at least HK$8 billion

Under Rule 18C.03(4), a Commercial Company needs revenue of at least HK$250 million from its specialist technology business in its most recent audited year; any other applicant is a Pre-Commercial Company. Rule 18C.03(3) sets minimum market capitalisations of HK$6 billion (Commercial) and HK$10 billion (Pre-Commercial), temporarily reduced to HK$4 billion and HK$8 billion for listings from 1 September 2024 to 31 August 2027 (SFC and SEHK joint announcement, 23 August 2024). Starfield's HK$180 million makes it Pre-Commercial, so HK$6.5 billion falls short of HK$8 billion. HK$150 million is a revenue tier in the R&D expenditure test, not the commercial threshold, and HK$10 billion is the unmodified Pre-Commercial figure, not a rule for every applicant. Source: Main Board Listing Rules r.18C.03(3)-(4); HKEX Guide for New Listing Applicants ch. 2.5 para 10; SFC and SEHK joint announcement, 23 August 2024 (as at October 2026).

Common mistake

Candidates check the market value against the lower Commercial figure without first classifying the company by its HK$250 million revenue.

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Original study material mapped to the public HKSI Paper 1 syllabus. Unofficial, not endorsed by HKSI Institute or the SFC. Verify figures and rules against current guidance before relying on them.