On October 21, 2025, Hibiki Path Advisors (“we”) submitted a public comment to the Tokyo Stock Exchange (the “TSE”) regarding the consultation titled “Revision to the Growth Market’s Continued Listing Criteria and Related Revisions” in Japanese. The full translated text of our submission is set out below.
Please note that this comment responds to the TSE’s policy direction to revise the Growth Market’s continued listing criteria from “market capitalization of JPY 4 bn or more after 10 years from listing” to “market capitalization of JPY 10 bn or more after 5 years from listing.”
Consistent with our white paper, Merits and Challenges of Being Publicly Listed in the Era of Unsolicited Takeovers, we reiterate that the true purpose of public listing is realized when management earns market support by achieving a higher valuation and comparative advantages, enabling dynamic growth via M&A and financing.
In this context, we have often observed Growth Market issuers—who should be best positioned to chart and execute dynamic strategies—failing to capture the benefits of being public and slipping into a negative spiral of limited investor attention. We welcome the TSE’s willingness to directly address this problem and submit this comment to express our support for that stance.
We hope that the capital-market reforms led by the TSE will raise corporate value across issuers and contribute to national wealth creation. In parallel, we will continue to provide our investee companies (not limited to Growth Market issuers) with opportunities to re-examine the true merits of being public and to act accordingly (Y. Shimizu, M. Matsumoto).
This post does not constitute a solicitation for an offer to acquire or recommend the purchase or sale of specific securities, or advice on investment, legal, tax, accounting, or any other matters.