A KOSDAQ Listing Now Ends on a Number the Company Never Files

 

Every continued-listing regime has to pick a variable. The choice looks technical and is not. It decides who produces the evidence that ends a listing, and therefore how much time sits between that evidence and the exit.

Korea has moved that variable decisively toward price. The minimum market capitalisation for continued KOSDAQ listing was raised from KRW 4.0bn to KRW 15bn early in 2026, then to KRW 20bn from July. A separate rule, also effective July, targets shares trading below KRW 1,000. Both are measured the same way: thirty trading days below the line brings designation as a management issue, and the company must then hold above the line for 45 consecutive trading days inside a 90-day window to avoid a delisting decision.

The counts, as reported on 25 September 2026

Between 12 August and that date, 17 KOSDAQ issuers were designated on the market-capitalisation test. Eight KOSDAQ issuers, excluding SPACs, have had delisting decided this year on that test — none in the first half of the year, all of them in the second. Under the sub-KRW 1,000 rule, 15 KOSPI and 30 KOSDAQ issuers are designated, and those become subject to delisting decisions from mid-October if the 45-day recovery is not met. On the KOSPI, one issuer was decided for delisting on 23 September for failing the market-capitalisation test, following one in the first half, and 13 issuers are designated under the strengthened requirements. The Korea Exchange expects around 50 KOSDAQ delistings in the second half. (Seoul Shinmun, 25 September 2026.)

Read the chain by author, not by outcome

Every record that carries a company toward the exit under this regime is produced by the market and counted by the exchange. The issuer files nothing that bears on it, for the plain reason that an issuer does not file its own share price.

There is one company-authored document in the reporting, and its position is the finding. An issuer whose delisting had already been decided disclosed, on 11 September, a decision to transfer to KONEX — likely the first such case. That filing does not contest the exit. It arranges what comes after it. A securities-industry source quoted in the same report described how the move is received: many companies regard a KONEX transfer as not substantially different from delisting, because KONEX is not a market that draws much investor attention.

So the only record the issuer writes arrives on the far side of the decision. A radar built on the exchange's designation lists is a register of outcomes, not of approach.

Where R-Risk sits, and where it does not

WP — Worsening Probability — is built on records that can move before an outcome: board composition, officer departures, who holds a convertible and on what terms. Those are filed, dated, and attributable to a party. A price-keyed threshold has no lead time by construction, because the trigger and the outcome are the same number. When it moves, the event it might have warned about has already occurred.

The limit belongs in the same paragraph. WP does not assess where a share price goes, and it is not built to. A market-capitalisation delisting can arrive with no relational signal at all — a small issuer can cross the line on a broad repricing, on index flows, or on a float too thin to hold a quote. In those cases WP has nothing to say, and saying so is part of using it correctly.

One piece of the literature

Macey, O'Hara and Pompilio (2008, Journal of Law and Economics 51(4): 683–713) studied the delisting process itself rather than the deterioration behind it. Their mechanism is worth stating plainly: what holders lose is shaped by the venue a security moves to afterwards, because liquidity and attention do not follow a security automatically when it changes market. That is the mechanism the KONEX remark describes in Korean terms — the destination, not the decision, is where the loss is realised.

Asia, the same week

Japan sets the equivalent windows differently. Under the Tokyo Stock Exchange's continued-listing framework, transitional measures ended for criteria record dates falling on or after 1 March 2025. An issuer that fails a criterion enters an improvement period of one year in principle — six months for the trading-volume criterion — and if it still fails, it is designated a Security Under Supervision or a Security to be Delisted for a further six months before the exit. The exchange publishes the list of issuers currently in an improvement period; that list was last updated on 16 September 2026. The structural point is the same in both markets: the exchange counts, the exchange publishes the names, and the issuer's own filings arrive elsewhere in the sequence.

What a reader can check without us

For any KOSDAQ name on a designation list, the exchange's own disclosure states the test and the clock, and both are public. The records worth reading alongside it are the ones the company did author, together with their filing dates: changes in board composition, officer resignations, third-party allocations and convertible issues, and any change in the largest shareholder. Each of those carries a date. The threshold does not.

From this post onward, RaymondsIndex is published as R-Index and RaymondsRisk as R-Risk. Index methodology and values are unchanged.

This article is for information only and is not investment advice or a solicitation to buy or sell any security.

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