Where the Malaysia IPO Readiness Checklist covers the full vertical preparation sequence for Main Market listing, this comparison addresses the horizontal question: which of Bursa Malaysia’s three boards is the structural match for a given company?
The answer turns on five structural differences: who can invest, what adviser obligations apply post-listing, what eligibility tests govern admission, what the listing costs, and how migration between boards works. This guide maps each difference across all three boards, drawing on Bursa Malaysia Listing Requirements (consolidated versions cited per section), SC Equity Guidelines R7-2024 (issued December 2024, effective 1 March 2025), MCCG 2021, and the Grant Thornton Malaysia IPO process guide (2025).
Editorial content. Not legal, regulatory, or compliance advice.
Why Three Boards Exist
Bursa Malaysia operates three distinct listing boards because the capital-market problems they solve are structurally different.
Main Market serves established, profitable companies that need large public capital and can sustain the regulatory overhead of full retail investor access, mandatory quarterly reporting, and MCCG 2021 governance compliance. The eligibility threshold reflects this: companies must demonstrate a multi-year profit track record or hold substantial market capitalisation at listing.
ACE Market serves growth-stage companies that are revenue-positive but pre-profit or early-profit. The board removes the profit track record requirement and replaces the SC’s quantitative eligibility gate with a Principal Adviser suitability assessment. In exchange, the Principal Adviser must remain appointed and actively monitor Bursa compliance for a minimum of three years post-listing.
LEAP Market serves early-stage SMEs seeking structured capital formation from sophisticated investors. The board restricts both IPO subscriptions and secondary-market trading to sophisticated investors only (as defined under Schedules 6 and 7 of the Capital Markets and Services Act 2007, expanded under P.U.(A) 41/2024 effective March 2024 to include angel investors, venture capitalists, and private equity firms). In exchange, public spread requirements are lower, disclosure overhead is lighter, and listing costs are smaller.
The structural driver is investor protection proportionality. Retail investors are admitted to Main and ACE Markets where listing requirements and continuing disclosure obligations reduce information asymmetry. LEAP Market excludes retail investors precisely because its companies carry information risk that only sophisticated institutional counterparties are assumed to manage.
Bursa publishes annual IPO statistics in its Annual Report; readers should consult the latest report for board-level breakdown of listing volumes by market.
The Comparison Matrix
The table below summarises the operative regulatory requirements across all three boards; figures reference Bursa Malaysia Listing Requirements (consolidated versions as cited at the top of this guide) and SC Equity Guidelines R7-2024.
Rule-book thresholds are stated in MYR (the denomination of the Bursa and SC source documents); practitioner cost observations are stated USD-primary with MYR equivalents in parentheses.
| Dimension | Main Market | ACE Market | LEAP Market |
|---|---|---|---|
| Investor access at IPO | All retail and institutional investors | All retail and institutional investors | Sophisticated investors only (Schedules 6 and 7, CMSA 2007; expanded March 2024 under P.U.(A) 41/2024 to include angel investors, VCs, PE firms) |
| Investor access post-listing | Unrestricted public trading on Bursa | Unrestricted public trading on Bursa | Sophisticated investors only; retail investors cannot trade on the secondary market |
| Adviser designation | Principal Adviser required to bring to listing | Principal Adviser (PA), a Bursa-registered investment bank | Approved Adviser (AA), a firm registered with Bursa as an AA; need not be an investment bank |
| Post-listing adviser obligation | No mandatory continuing adviser post-listing | Minimum 3 years post-admission (PA must remain appointed and monitor compliance) | Minimum 3 financial years post-admission (AA must remain appointed) |
| Profit track record requirement | Yes: 3-5 full financial years, aggregate after-tax profit minimum MYR 20 million (approx. USD 4.3 million), minimum MYR 6 million (approx. USD 1.3 million) in most recent year; OR Market Cap Test or Infrastructure Test | None | None |
| Market capitalisation floor | MYR 500 million minimum (approx. USD 107 million) under Market Cap Test only; no market cap floor under Profit Test | None confirmed in current ACE Listing Requirements | None |
| Public spread, minimum % | 25% | 25% | 10% |
| Public spread, minimum shareholders | 1,000 public shareholders each holding at least 100 shares | 200 public shareholders | Unconfirmed* |
| Bumiputera allocation at IPO | 50% of public spread allocated to Bumiputera investors at listing for companies deriving over 50% of profits from Malaysian operations (= 12.5% of total shares); source: SC Equity Guidelines R7-2024, Chapter 6 Equity Distribution Requirements, and Bursa Main Market LR | None; best-efforts basis only (Grant Thornton Malaysia, 2025) | None |
| Minimum IPO price | MYR 0.50 per share (approx. USD 0.11) | Unconfirmed* | Unconfirmed* |
| Promoter/pre-IPO moratorium | Promoters: 6-month full lock-up from admission; then 45% aggregate remains for another 6 months; up to one-third of remaining moratorium shares may be released per year on a straight-line basis | Pre-IPO investors who acquired shares below IPO price within 12 months before application: 6-month lock-up from admission | Unconfirmed* |
| Typical total IPO cost (practitioner) | USD 1.1 million to USD 2.2 million (approx. MYR 5 million to MYR 10 million); source: Crowe Malaysia 2023 | USD 430,000 to USD 1.1 million (approx. MYR 2 million to MYR 5 million); source: Crowe Malaysia 2023 | Lower than ACE Market; specific range not publicly documented in reviewed sources |
| Cost as % of funds raised | 5% to 15% of total funds raised (Grant Thornton Malaysia, 2025) | 5% to 15% range; lower absolute amounts given smaller raise size | Similar percentage range; smaller absolute amount |
| Typical timeline | 12 to 18 months from adviser engagement; as short as 9 months for well-prepared applicants | 9 to 15 months from adviser engagement | Potentially shorter; specific observed range not confirmed in reviewed sources |
| Continuing disclosure (post-listing) | Full Main Market LR obligations: quarterly reports, audited annual accounts, material transaction disclosure, RPT shareholder approval, annual report, MCCG 2021 compliance statement, IFRS S1/S2 sustainability disclosure (Group 1 from 2025, Group 2 from 2026) | ACE Market LR obligations: quarterly reports, annual accounts, material transaction disclosure; sustainability disclosure from 2027 (Group 3) | LEAP Market LR obligations; lighter disclosure framework relative to Main and ACE; specific post-listing requirement differences: Unconfirmed* |
| Migration pathway | None above (highest board) | Transfer to Main Market available upon meeting Main Market eligibility; process reportedly streamlined via January 2024 rule change; timeline and current holding period: Unconfirmed* | No published Bursa process for transfer of listing status from LEAP to ACE was identified during research for this guide; see Section 7 |
| Typical company profile | Revenue-stage with cumulative profit record or MYR 500 million market cap at listing; diversified across major sectors | Growth-stage, revenue-positive, no profit requirement; typical market cap at listing MYR 20 million to MYR 200 million (observed, not codified) | Emerging SME; pre-profit acceptable; typically venture-backed or PE-backed; smallest board by market cap and trading volume |
| Governance maturity (typical) | Board with independent majority in line with MCCG 2021; audit committee, nomination committee, remuneration committee established; 30% women director target | Board with at least one-third independent directors; governance consistent with MCCG 2021; lighter continuing-obligation monitoring than Main Market | Governance standards apply via LEAP LR; in practice governance build-out is commensurate with earlier-stage company size |
*Cells marked Unconfirmed could not be verified from a primary Bursa Listing Requirements or SC source at publication date. Readers should verify directly from the current consolidated rule book.
This comparison reflects requirements under MCCG 2021, the current operative corporate governance code as of May 2026. The SC issued a Discussion Paper for MCCG 2026 in December 2025; readers in late 2026 or beyond should verify the current operative version with the SC before relying on specific provisions cited here.
Investor Access
The most consequential structural difference between the three boards is who can buy at IPO and who can trade in the secondary market.
Main Market and ACE Market are open to all retail and institutional investors. The prospectus is registered with the SC and distributed to the public. Retail investors may subscribe to the IPO at the offer price, and any member of the public can buy or sell shares on Bursa after listing. This unrestricted access creates a liquid secondary market and supports price discovery across the full range of participants.
LEAP Market operates under a structurally distinct model. Both the IPO subscription and all secondary-market trading are restricted to sophisticated investors as defined under Schedules 6 and 7 of the CMSA 2007. The March 2024 expansion under P.U.(A) 41/2024 brought angel investors, venture capitalists, and private equity firms within the definition, increasing the pool of eligible participants. Retail investors remain excluded from LEAP regardless of personal wealth level.
The practical consequence for a LEAP-listed company is structural illiquidity in the secondary market relative to Main and ACE. Existing shareholders, including founders and pre-IPO investors, can only exit to other sophisticated investors. The secondary-market trading depth on LEAP is materially smaller than on Main or ACE: by market capitalisation and trading volume, LEAP is a fraction of the other two boards. This is not a temporary market condition; it is a structural feature of the board design.
Companies raising pre-IPO capital from institutional or VC investors who are themselves sophisticated investors may find LEAP’s access restriction unproblematic for initial capital formation. The constraint becomes material when the company, or its investors, need a retail-accessible exit or a broader price-discovery market.
For an illustration of how beneficial ownership disclosure obligations intersect with investor access, see the companion educational guide: What Is Ultimate Beneficial Ownership? All three boards require UBO disclosure for substantial shareholders at listing and on an ongoing basis under continuing obligations.
Sponsor and Adviser Obligations
The three boards assign materially different responsibilities to the advisers who bring companies to listing and who stay on post-listing.
Main Market requires a Principal Adviser (PA) to manage the listing process. Once the company is admitted, no mandatory continuing adviser obligation applies at the board level; the company’s own compliance team and audit committee absorb the post-listing monitoring function, subject to Bursa’s own surveillance and regulatory oversight.
ACE Market mandates a Principal Adviser for a minimum of three years post-admission. The PA is a Bursa-registered investment bank. During those three years, the PA is responsible for actively monitoring the listed company’s compliance with ACE Market LR, advising on material transactions, and notifying Bursa of any compliance concern. If the PA resigns before a replacement is appointed, the company is in breach of listing requirements. The three-year PA obligation is therefore a post-IPO recurring operating cost that should be modelled alongside audit, legal, and compliance overhead.
LEAP Market mandates an Approved Adviser (AA) for a minimum of three financial years post-admission. The AA is a firm registered with Bursa in the Approved Adviser category; it is not required to be an investment bank. In practice, boutique advisory and accounting firms hold AA registrations. The AA plays a role functionally similar to the ACE PA: ongoing compliance monitoring, material transaction advice, and Bursa notification obligations.
The PA and AA post-listing retainer cost varies by selected adviser and company size. Public benchmarks are not available for this obligation in isolation. Companies modelling their post-listing cost structure typically derive this estimate from their selected adviser’s fee proposal, not from a published industry range.
Due diligence on IPO applicants, including SSM registry verification of group subsidiaries and beneficial ownership tracing, is a standard adviser obligation for all three boards. For an overview of Malaysia company data sourcing options available to advisers and legal counsel conducting IPO data-room work, see SSM Direct vs Resellers: Which Should Compliance Buyers Use in Malaysia?.
Eligibility Tests
Eligibility requirements differ substantially across the three boards, and the difference is not simply one of threshold levels: Main Market uses a quantitative regulatory test; ACE and LEAP use adviser-assessed suitability.
Main Market applies three alternative eligibility tests: the Profit Test, the Market Cap Test, and the Infrastructure Test. The Profit Test is the most common route: the company must demonstrate three to five full financial years of audited accounts, aggregate after-tax profit of at least MYR 20 million (approx. USD 4.3 million), and at least MYR 6 million (approx. USD 1.3 million) in the most recent year. For the eligibility requirements in detail, including the Market Cap Test and Infrastructure Test thresholds, refer to the Malaysia IPO Readiness Checklist.
ACE Market applies no profit test and no minimum market cap requirement. The Principal Adviser assesses suitability on behalf of the applicant and takes regulatory responsibility for that assessment. There is no quantitative profit floor to pass. This does not mean there are no standards: a PA will decline mandates from companies that are not commercially viable, cannot demonstrate a credible business model, or are unlikely to meet their continuing obligations post-listing. The suitability assessment is judgement-based rather than formula-based.
LEAP Market follows the same logic: no profit test, no minimum market cap. The Approved Adviser assesses suitability. The absence of a quantitative gate makes early-stage companies eligible in principle; the AA’s judgement is the operative filter.
One practical implication: for ACE and LEAP applicants, the quality and credibility of the Principal Adviser or Approved Adviser selection is itself an eligibility signal. Reputable PAs and AAs are selective about the mandates they accept because they bear post-listing regulatory responsibility for those companies.
Cost and Timeline Across Boards
Public benchmarks for ongoing post-listing cost (continuing PA or AA retainer, audit, sustainability disclosure compliance, MCCG governance overhead) are limited and vary materially by selected adviser and company size. The matrix above covers IPO cost only. Companies typically derive ongoing-cost estimates from their selected adviser’s retainer plus internal compliance overhead, not from a published industry benchmark.
For IPO costs:
Main Market listing costs typically range from USD 1.1 million to USD 2.2 million (approx. MYR 5 million to MYR 10 million) in total, covering adviser fees, reporting accountant, legal counsel, SC registration, Bursa listing fees, and marketing. This range comes from Crowe Malaysia 2023 practitioner data. Timeline from adviser engagement to listing day is typically 12 to 18 months for established companies; well-prepared applicants have completed the process in as few as 9 months.
ACE Market listing costs typically range from USD 430,000 to USD 1.1 million (approx. MYR 2 million to MYR 5 million). This range also comes from Crowe Malaysia 2023 data. The lower absolute cost reflects smaller offering size and a lighter SC filing process, not a proportional reduction across all cost lines. Timeline is typically 9 to 15 months.
LEAP Market costs are lower than ACE Market, primarily because SC registration fees, Bursa fees, and prospectus-preparation scope are smaller. A specific verified cost range is not publicly documented in reviewed sources for LEAP. The savings are not simply half the ACE range: fixed components of any listing (legal counsel, reporting accountant, SC filing) do not scale proportionally to deal size. Advisers’ LEAP retainer proposals will vary by firm. The post-October 2025 Bursa fee schedule revision has not been individually verified here; readers should confirm current Bursa and SC fee schedules directly before modelling IPO costs.
Grant Thornton Malaysia (2025) notes that total listing cost as a percentage of funds raised is typically 5% to 15% across all three boards, with the percentage tending toward the upper end for smaller raises on ACE and LEAP.
Migration Paths
ACE Market to Main Market
An ACE-listed company can apply for transfer to Main Market by demonstrating it meets Main Market eligibility: the Profit Test, Market Cap Test, or Infrastructure Test. The transfer process is distinct from a new IPO: the company transfers listing status without conducting a new public offering, and shareholders do not face a new IPO moratorium.
January 2024 rule changes reportedly streamlined the ACE-to-Main accelerated transfer timeline. A frequently cited practitioner figure is approximately three months from application. This figure has not been independently verified against a primary Bursa rule-change announcement or the current ACE Market Listing Requirements chapter on transfer to Main Market during preparation of this guide; readers should confirm the current timeline and any minimum holding-period requirement with Bursa or their Principal Adviser before relying on it.
Recent Main Market listings accessible via the SC Prospectus Exposure Register (accessed May 2026) include KK Mart Retail Berhad, Big Caring Group Bhd, HI Mobility Berhad, and Cuckoo International (MAL) Berhad, all managed through Maybank IB, RHB IB, or AmInvestment Bank. These illustrate the Principal Adviser profile typical of Main Market transactions.
LEAP Market to ACE Market
Grant Thornton Malaysia describes LEAP as an “entry point” and frames a progression toward ACE and then Main Market as a “growth pathway.” This framing describes commercial intent, not a codified regulatory mechanism.
No published Bursa process for a transfer of listing status from LEAP to ACE Market was identified during research for this guide. The Bursa ACE Market Listing Requirements include a chapter governing transfer to Main Market; no equivalent chapter for LEAP-to-ACE transfer was found in reviewed sources.
LEAP-listed companies seeking access to the broader ACE Market investor base typically do so by delisting from LEAP and conducting a new IPO on ACE. Companies considering LEAP as a stepping stone to ACE should verify the current LEAP-to-ACE pathway directly with Bursa or their Approved Adviser before committing to a board choice.
Choosing a Board
The observed pattern in Bursa Malaysia listing activity, across published prospectuses, Bursa announcements, and practitioner guides, points to three distinct company archetypes that each board serves.
Companies typically pursue Main Market listing when they have a multi-year profit track record that meets the Profit Test, need large public capital from the full retail-and-institutional investor base, and have the governance infrastructure in place: an independent board majority consistent with MCCG 2021, functioning audit, nomination, and remuneration committees, and the capacity to sustain quarterly reporting, sustainability disclosure, and RPT shareholder approval processes. Main Market’s continuing obligation intensity is the highest of the three boards; companies that are not operationally ready for that overhead at listing typically find the process produces governance gaps that delay admission.
Companies typically pursue ACE Market listing when they are revenue-positive but not yet meeting the Main Market Profit Test, need growth capital from a broader investor base than LEAP’s sophisticated-only pool, and are prepared to sustain a three-year Principal Adviser relationship post-listing. The typical ACE applicant has an existing institutional investor or corporate shareholder base, a credible revenue model, and a governance structure that can meet the ACE Market continuing obligations without the full MCCG 2021 independent-majority board.
Companies typically pursue LEAP Market listing when their existing shareholder base includes sophisticated institutional investors (VCs, PEs, angel investors qualifying under P.U.(A) 41/2024) who can participate as primary IPO investors, the full ACE Market listing cost and disclosure burden is disproportionate relative to the capital being raised, and the company regards LEAP as a structured capital-formation step before a future ACE Market listing. The structural fit is clearest where the company does not need retail investor participation in the near term and where its existing sophisticated backers can absorb the structurally limited secondary-market liquidity.
The practitioner heuristic that emerges from reviewing listed-company profiles across the three boards: Main Market for the profit-track company seeking broad capital, ACE Market for the growth company ready for retail access, LEAP for the early-stage company whose investors already qualify as sophisticated.
When LEAP Market Structurally Does Not Fit
LEAP is not a lighter version of ACE Market. It is a structurally different capital-formation mechanism, and there are company situations where it is not an appropriate fit for reasons that go beyond cost or eligibility.
If the company has a consumer-facing brand that depends on retail investor participation, LEAP does not serve that brand purpose. Franchise retail chains, consumer product companies, and any business whose listing narrative includes “investing alongside our customers” cannot deliver that narrative on LEAP: retail investors cannot subscribe to the IPO and cannot trade in the secondary market.
If the company’s existing shareholders (pre-IPO investors, employee warrant holders, founders) need near-term liquidity via a retail market, LEAP does not provide it. The secondary market on LEAP is restricted to sophisticated investors, and the trading depth is materially thinner than on Main or ACE Markets. Exit timelines for pre-IPO investors who need retail-market liquidity should account for this constraint.
If the company needs immediate access to Bursa’s full retail liquidity pool for a large capital raise, LEAP’s sophisticated-only access restricts the subscription pool to a subset of the total institutional investor base. Large raises require Main Market or ACE Market to access the retail tier.
If the company anticipates that its principal customers, partners, or distributors are retail companies or individuals who typically monitor listed-company status as a credibility signal, LEAP’s profile among general business audiences is lower than Main or ACE, partly because retail investors do not encounter LEAP-listed companies through standard Bursa trading platforms.
This section reflects governance expectations under MCCG 2021, the current operative code as of May 2026. The SC issued a Discussion Paper for MCCG 2026 in December 2025; readers should verify the current operative version with the SC.
Editorial Disclaimer
Editorial content. Not legal, regulatory, or compliance advice. Companies considering a Bursa listing should engage qualified Principal Advisers (Main Market and ACE Market) or Approved Advisers (LEAP Market), reporting accountants, and legal counsel. References cited here are to public regulatory and practitioner sources.
Sources cited:
- Bursa Malaysia, Main Market Listing Requirements (consolidated 1 July 2023)
- Bursa Malaysia, ACE Market Listing Requirements (consolidated, amendments through 2024)
- Bursa Malaysia, LEAP Market Listing Requirements (consolidated 5 March 2024)
- SC Equity Guidelines (R7-2024), issued 20 December 2024, effective 1 March 2025
- Grant Thornton Malaysia, Bursa Malaysia Listing Requirements and IPO Process (2025)
- SC Malaysia, Prospectus Exposure Register (accessed 2026-05-23)