Ⅰ. Introduction – Japan’s Economic Reset after COVID‑19
Japan entered the 2020s with the twin shocks of a protracted pandemic and intensifying geopolitical fragmentation. Yet the 2024 Annual Economic and Fiscal Report (令和6年年次経済財政報告) paints a markedly different landscape: record‑high fiscal packages, robust private‑sector capex, and an unmistakable push to reposition the country as Asia’s most reliable, innovation‑driven hub. Tokyo has earmarked more than ¥75 trillion across three supplementary budgets since 2022, while the Bank of Japan (BOJ) continues its ultra‑accommodative stance even as peer economies tighten. Unlike the emergency cash handouts of 2020‑21, today’s stimulus is finely targeted—channelling resources into digital transformation (DX), green transformation (GX), supply‑chain resilience, and regional revitalization. For foreign companies this means a toolkit of subsidies, tax credits, soft loans, and R&D grants that are explicitly open to non‑Japanese applicants so long as they establish a local footprint or partner with domestic firms. Ministries now publish English guidance, shorten review timelines, and accept online submissions, lowering long‑standing entry barriers. This article dissects the stimulus across ten thematic sections, mapping each measure to concrete openings for overseas investors and illustrating the practical steps required to translate policy into profit.
Ⅱ. Fiscal Expansion and Sectoral Allocations
A. Direct Corporate Subsidies and Grants
The stimulus’s backbone is an expanded “subsidy menu” administered by METI, MIC, and prefectural governments. Program budgets top ¥3.1 trillion for FY 2024 alone, dwarfing pre‑COVID levels. Foreign manufacturers that register a Japanese subsidiary can now capture up to 50 percent of capital expenditures—covering plant construction, robotics, and carbon‑neutral equipment—under the revamped Manufacturing Reinforcement Grant. Service‑sector players are eligible for the Digital Adoption Subsidy, which reimburses SaaS fees, data‑migration costs, and cybersecurity upgrades for as long as five years. Selection criteria award extra points for international knowledge transfer, so bringing proprietary technology or global certifications can tilt the odds in your favor. Applicants submit a 20‑page business plan, and English summaries are accepted. Award announcements follow a predictable two‑month cycle, enabling multinationals to align Japanese capex with global budget windows. The catch? Companies must sign a five‑year job‑creation pledge and disclose ESG metrics—requirements best managed through local HR and compliance specialists.
B. Green Transformation (GX) Budget
Japan’s Green Transformation budget ballooned to ¥2 trillion, reflecting the Kishida administration’s pledge to hit net‑zero by 2050. Foreign cleantech firms can tap the GX Tax Credit—worth up to 10 percent of total investment—and the Green Innovation Fund, which writes large, multi‑year checks for hydrogen, battery recycling, and carbon‑capture pilots. The fund now features an “open call” track that fast‑tracks joint ventures between overseas IP holders and Japanese conglomerates eager to diversify. Successful applicants must demonstrate a 30 percent emissions reduction versus baseline operations and agree to share data with the national GHG registry—an obligation that, while stringent, doubles as a powerful marketing credential. Complimentary advisory services from the New Energy and Industrial Technology Development Organization help foreign entrants navigate environmental impact assessments, historically viewed as opaque. Because prefectures like Fukushima and Yamaguchi offer stackable incentives, total effective support can exceed 60 percent of project costs.
C. Regional Revitalization and SME Support
A lesser‑known but lucrative slice of the stimulus is the Regional Revitalization Fund, designed to arrest population decline outside Tokyo. Grants of up to ¥500 million target foreign SMEs willing to establish satellite offices in “digital garden cities”—towns upgrading fiber networks and remote‑work hubs. The Ministry of Internal Affairs and Communications reimburses up to two‑thirds of payroll for software engineers hired locally, while municipal governments sweeten the deal with subsidized office space and housing allowances. Another pathway is the SME Succession Grant, which supports management buy‑outs of aging local suppliers; foreign investors can acquire proven businesses for pennies on the yen, then layer in advanced manufacturing know‑how. However, due diligence must account for hidden pension liabilities and earthquake‑resilience standards. Engaging a bilingual regional bank is often the quickest route to vetted deal flow and subsidized loans, compressing transaction timelines from twelve months to as little as four.
Ⅲ. Monetary and Financial Measures
A. BOJ’s Continued Low‑Interest Environment
While the U.S. Federal Reserve and European Central Bank have normalized policy, the BOJ maintains a short‑term policy rate near zero and caps ten‑year JGB yields through “flexible” yield‑curve control. For foreign corporates, this translates into yen financing costs that remain among the cheapest in the OECD. Multinationals issuing samurai bonds can lock in sub‑one‑percent coupons, while project‑finance loans from megabanks frequently price at TIBOR plus 30 basis points. Hedging costs have narrowed as the yen stabilizes, making cross‑currency swaps more predictable. Moreover, the Japan Investment Corporation and Development Bank of Japan co‑lend long‑tenor tranches for strategic industries, often subordinating their claims to attract private lenders. Taken together, these mechanisms compress weighted‑average cost of capital, enabling foreign firms to green‑light projects that would fail hurdle‑rate tests elsewhere. Yet the window may close if inflation pressures persist, underscoring the value of acting during FY 2024‑25.
B. Government‑Backed Credit Guarantee Programs
To shore up liquidity among smaller enterprises, the government doubled the ceiling of the Safety‑Net Guarantee Program to ¥280 million per borrower and extended coverage to foreign‑owned SMEs. Under this scheme, credit associations issue working‑capital loans with a 100 percent public guarantee for pandemic‑related revenue declines and a 90 percent guarantee for growth investments such as inventory expansion. Interest subsidies reduce effective borrowing rates to near zero for the first three years, after which blended rates hover around one percent. Foreign subsidiaries incorporated less than two years ago can qualify by pledging a parent‑company comfort letter instead of local collateral, lowering the barrier to entry. Combined with export insurance from Nippon Export and Investment Insurance, firms can bridge cash‑flow gaps while building sales channels. However, covenants impose quarterly reporting of headcount and domestic procurement ratios—metrics that must be embedded into ERP systems from day one.
C. Capital‑Market Reforms for Growth Equity
Japan’s stimulus is not just about debt. Capital‑market reforms have overhauled the Tokyo Stock Exchange Prime and Growth sections, easing listing rules for high‑growth foreign‑domiciled entities. Key changes include English disclosure allowances, a reduced free‑float requirement of 25 percent, and streamlined approvals for dual‑class shares—crucial for founder‑led tech companies. At the same time, the government’s ¥1 trillion University Startup Fund operates as a matching investor, guaranteeing that IPO‑bound firms can fill bookbuilds even amid global volatility. Foreign VCs receive tax exemptions on carried interest if they establish a Japan‑registered GP and commit at least 20 percent of AUM to domestic startups. These measures are boosting average IPO proceeds and deepening secondary‑market liquidity, making Japan a credible alternative to NASDAQ for Asia‑Pacific issuers. Firms considering a public exit should engage the TSE International Listings Office early to map disclosure templates and pre‑clear ESG statements, expediting time‑to‑market.
Ⅳ. Labor, Immigration, and Human‑Capital Policies
A. Fast‑Track Visas for High‑Skill Talent
Addressing chronic skill shortages, the Immigration Services Agency rolled out the J‑Startup Visa and Digital Nomad Visa, both aligning with the stimulus’s human‑capital pillar. Applicants with STEM degrees or equivalent experience receive five‑year residence status within 30 days, down from the previous six‑month average. Family members gain unrestricted work rights—an unprecedented move designed to entice global specialists who previously opted for Singapore or Seoul. Municipalities such as Fukuoka and Sapporo operate “One‑Stop Immigration Desks” that bundle visa processing with child‑care arrangements and bilingual housing brokers, reducing soft‑landing friction. For employers, payroll tax credits of up to ¥1.2 million per foreign hire apply when positions support DX or GX objectives. Firms can also leverage subsidized Japanese‑language training, reimbursed at 70 percent, to accelerate workplace integration. Taken together, these reforms dismantle what many executives cited as their top barrier: the time and uncertainty linked to securing work authorization.
B. Reskilling and Digital Upskilling Subsidies
Complementing immigration liberalization, Japan’s stimulus allocates ¥400 billion to the Human Capital Investment Fund, reimbursing up to 80 percent of tuition for accredited online courses in AI, cybersecurity, and advanced manufacturing. Foreign companies that register as “Authorized Training Providers” can capture demand by co‑developing micro‑credential programs with Japanese universities, earning both tuition revenue and brand exposure. Employees who complete approved courses trigger an employer payroll‑tax rebate worth 15 percent of their annual salary, effectively subsidizing wage bills while closing skill gaps. The fund also finances paid internships for university seniors, reimbursing stipends up to ¥200,000 per month—a low‑risk pipeline for bilingual talent. To qualify, firms submit a training roadmap aligned with the national Digital Skill Standard Framework and commit to post‑training promotions or pay raises. This linkage between learning and career progression reflects Tokyo’s ambition to pivot from lifetime employment toward merit‑based advancement, fostering a more dynamic labor market.
C. Work‑Style Reform 2.0 and Flexibility
The original 2019 Work‑Style Reform capped overtime and mandated equal pay for equal work. Version 2.0, financed partly through the stimulus, goes further by subsidizing four‑day workweeks, regional telework hubs, and outcome‑based compensation schemes. Foreign firms pioneering flexible schedules can offset up to ¥960,000 per employee in remote‑work allowances—including home‑office furniture and broadband—through the Telework Promotion Grant. In parallel, Labor Standards Inspection Offices now accept English telework policies, accelerating compliance. The reforms dovetail with charter‑flight subsidies that reimburse 50 percent of travel between Tokyo and regional “Digital Garden Cities,” enabling hybrid teams without prohibitive transport costs. Finally, the government has digitalized labor inspections, replacing surprise visits with portal‑based self‑audits—reducing administrative overhead for SMEs. Collectively, these measures not only improve work‑life balance but also broaden talent pools, crucial for foreign entities that recruit nationally rather than just in megacities.
Ⅴ. Digital & Infrastructure Investment
A. National Digital Infrastructure (5G/6G and Cloud)
The stimulus dedicates ¥1.8 trillion to accelerate nationwide 5G deployment and seed 6G testbeds, overseen by the Ministry of Internal Affairs and Communications. Foreign network‑equipment vendors can obtain cost‑sharing grants covering up to 45 percent of base‑station hardware if they partner with Japanese carriers on open‑RAN architecture. Cloud providers enjoy tax credits that allow immediate expensing of hyperscale data‑center build‑outs—a boon for firms migrating latency‑sensitive workloads to Japan. The Sovereign Cloud Initiative further guarantees anchor tenancy by central ministries, effectively derisking demand forecasts. Cyber‑resilience is mandated through the revised Basic Act on Cybersecurity, but compliance pathways are clearer, with NISC publishing English guidelines and offering free penetration‑test vouchers worth ¥10 million. These combined incentives accelerate time‑to‑revenue for infrastructure players and create downstream openings for SaaS vendors, AI‑model hosts, and content‑delivery networks.
B. Smart City and Mobility Projects
Japan’s Smart City Challenge Fund, expanded to ¥600 billion, subsidizes proof‑of‑concept deployments in energy management, autonomous transit, and disaster‑response systems. Foreign tech integrators can lead consortia with universities and local governments, receiving up to 70 percent reimbursement on hardware and software costs. Tokyo Metropolitan Government, for instance, seeks overseas partners to pilot level‑4 autonomous shuttles ahead of the 2027 World Expo, offering expedited road‑testing permits. In Kobe, maritime‑logistics digitization projects invite foreign SaaS providers to integrate blockchain‑based cargo tracking, backed by port‑fee waivers and data‑sharing MOUs. Evaluations prioritize interoperability with Japan’s nascent National Digital Twin, so adherence to open standards such as FIWARE and ISO 37106 increases award likelihood. Because successful pilots often transition into multi‑year commercial contracts, early participation can secure long‑term recurring revenue streams in urban infrastructure.
C. Supply‑Chain Resilience and Advanced Manufacturing
Rounding out the infrastructure agenda is the ¥2.2 trillion Supply‑Chain Resilience Program, designed to mitigate geopolitical shocks and semiconductor bottlenecks. Foreign chipmakers and component suppliers can secure subsidies covering 40 percent of fab construction or equipment relocation costs, contingent on maintaining strategic inventories within Japan. The program also funds digital‑twin platforms that simulate logistics disruptions, offering up to ¥500 million per project for AI‑driven risk analytics—an avenue ripe for SaaS entrants. Automotive suppliers transitioning to EV components benefit from low‑interest loans via the Japan Finance Corporation, coupled with tax deductions for R&D outlays exceeding five percent of sales. Crucially, METI has shortened environmental‑impact screening to nine months for resilience‑linked projects, shaving critical time off go‑live schedules. Foreign firms that commit to local supplier development and workforce skilling gain priority scoring, reinforcing Japan’s industrial base while opening high‑margin opportunities for technology transfer and co‑development.
Ⅵ. Public–Private Partnerships & Funding
A. Smart‑Hospital Subsidy Schemes
Healthcare ranks among the largest stimulus beneficiaries, and the Smart‑Hospital Subsidy Scheme is its showpiece. The Ministry of Health, Labour and Welfare (MHLW) earmarked ¥430 billion through 2028 to digitize 100 flagship hospitals with electronic medical records, AI‑assisted diagnostics, and automated pharmacies. Foreign vendors supplying imaging software, cobots, or logistics drones can recover up to 50 percent of installation costs, provided they integrate with the national Health Information Platform (H‑IP). Each hospital forms a steering committee that selects suppliers via open RFPs released in both Japanese and English, lowering language barriers. Vendors that establish local maintenance teams receive a five‑year corporate‑tax holiday on service revenue, boosting after‑sales profitability. Because subsidy tranches are released in stages—design, pilot, full roll‑out—firms secure multi‑year revenue visibility. To maximise competitiveness, consortium bids pairing hardware makers with analytics specialists have won 70 percent of contracts to date, underscoring the premium placed on end‑to‑end solutions.
B. National Innovation Fund Grants
Administered by the Japan Science and Technology Agency, the National Innovation Fund sits at the intersection of public research and private deployment. It deploys ¥800 billion in matching grants, with foreign‑domiciled project leaders eligible if at least one Japanese university or SME is listed as a co‑investigator. Typical awards are ¥1–3 billion over five years, disbursed against milestones tied to prototype readiness levels. Recent foreign awardees include a Californian quantum‑sensor start‑up and a French agritech firm trialling AI‑controlled vertical farms in Hokkaido. Success hinges on demonstrating not just technological novelty but also local economic spill‑overs—patent filings, postgraduate hiring, and regional supply‑chain creation. IP ownership remains with the lead applicant, but the government retains a non‑exclusive license for disaster‑response or public‑health emergencies, a clause that rarely impedes commercialisation. Because reviews rely heavily on peer assessments, engaging Japanese co‑authors early and translating key papers can materially raise evaluation scores.
C. Prefectural Procurement Opportunities
Japan’s 47 prefectures collectively purchase more than ¥20 trillion of goods and services each year, and stimulus funds have boosted their discretionary technology budgets by 28 percent since 2022. Foreign suppliers often overlook these “small but fast” deals, yet they entail shorter sales cycles—typically three months from tender to award—and less onerous security clearances than central‑government contracts. Miyagi prefecture, for example, offers expedited payments on disaster‑management software, wiring 50 percent of contract value upon delivery of a functioning demo. Osaka subsidises 30 percent of booth fees for overseas exhibitors at its annual innovation fair, and award winners receive a one‑year vendor‑qualification waiver. To navigate fragmented rules, firms should map prefectural procurement portals (many now offer English summaries) and engage local system integrators who already hold framework agreements. Building a reference installation in a single prefecture often accelerates expansion, because neighbouring governments routinely piggy‑back on proven solutions rather than launching fresh RFPs.
Ⅶ. Hospital Modernization & Smart Infrastructure
A. Robotics in Surgery & Logistics
Stimulus money is reshaping Japan’s surgical suites and back‑of‑house logistics. Academic medical centres in Tokyo and Nagoya have earmarked ¥120 billion for robotic‑assisted surgery systems, and foreign OEMs can access capital‑equipment subsidies covering 35 percent of list price. Beyond the operating theatre, automated guided vehicles now shuttle linens and pharmaceuticals, funded by the Hospital Productivity Enhancement Grant. Vendors offering predictive‑maintenance analytics score additional evaluation points, because the government aims to curb downtime costs by 15 percent within five years. Demonstrating compatibility with ISO 10218 safety standards is mandatory, but the PMDA has introduced a “pre‑submission consultation” in English that reduces approval lead times by 40 percent. Firms should also highlight training modules compatible with Japan’s Clinical Engineer certification, as upskilling budgets are available and can bundle services revenue into equipment bids.
B. Energy‑Efficient Facility Upgrades
Hospitals account for four percent of national electricity consumption, making them prime targets for GX spending. The subsidised Energy‑Efficient Hospital Retrofit Program reimburses up to 60 percent of costs for LED lighting, cogeneration systems, and heat‑recovery chillers, provided installations cut emissions by at least 25 percent. Foreign suppliers of smart‑HVAC controls succeed by partnering with local construction giants who manage asbestos checks and seismic‑code compliance. Retrofit contracts include a ten‑year performance‑based maintenance clause, generating predictable service revenue. Because utility tariffs are escalating, many hospitals achieve cash‑flow break‑even within five years, strengthening the business case. Firms that certify products under Japan’s Top Runner energy‑label programme enjoy accelerated import customs processing, shaving weeks off deployment timelines—an often‑overlooked competitive edge.
C. Cyber‑Security Standards for MedTech
With the rise of networked devices, healthcare cyber‑attacks surged 40 percent in 2024, prompting MHLW to codify the Medical Cyber‑Security Baseline. Suppliers must now submit a software bill of materials, zero‑day response plan, and annual penetration‑test results. Stimulus funds reimburse hospitals up to ¥15 million per installation for devices meeting the baseline, effectively turning compliance into a sales accelerator. Foreign manufacturers benefit from detailed English guidance and a new fast‑track import scheme for products vetted by overseas regulators such as the U.S. FDA or EU MDR. To stand out, vendors should offer 24/7 remote monitoring dashboards hosted on servers located within Japan’s sovereign‑cloud zone, satisfying data‑residency rules. Building these capabilities early can lock in annuity‑style support fees and erect high switching costs for competitors.
Ⅷ. Data Governance & Interoperability
A. Medical My‑Number Expansion
Japan’s national ID system, My‑Number, is being extended to health records to streamline reimbursements and epidemiological tracking. The stimulus allocates ¥250 billion for hospitals and insurers to adopt compatible card readers and patient portals. Foreign fintechs supplying biometric authentication modules can tap a 50 percent hardware subsidy, provided encryption keys comply with Japan Cryptography Standard JCM‑02. Early movers gain first‑mover data feed access, enabling the development of real‑time actuarial tools and personalised insurance products. Because the government mandates open APIs, platform providers can monetise anonymised insights under a new “public–interest data trust” model, generating royalty income while maintaining privacy safeguards.
B. FHIR‑Based Data Exchange Mandates
To end siloed electronic health records, MHLW now requires new systems to support HL7 FHIR standards. The Interoperability Adoption Grant covers 40 percent of interface‑engine licensing fees and up to 70 percent of integration services if awarded to SMEs. Foreign middleware vendors can fast‑track market entry by partnering with regional health‑information exchanges that already aggregate claims data. Certification testing is conducted by the Japan Association of Healthcare Information Systems at a subsidised rate for first‑time applicants. Passing tests unlocks eligibility for national‑scale pilot projects, which guarantee five‑year maintenance contracts and rich reference sites for Asia‑Pacific expansion.
C. Patient Consent & Privacy Enhancements
Public scepticism toward centralised data prompted legislators to beef up consent rules under the revised Act on the Protection of Personal Information. New guidelines require granular, use‑case‑specific opt‑ins and easy revocation mechanisms. Stimulus funds reimburse 75 percent of the cost of deploying consent‑management platforms, many developed by foreign SaaS providers. Vendors must support Japanese‑language UI/UX and store audit logs for ten years, yet they retain latitude to monetise de‑identified datasets. Compliance also acts as a trust signal for pharmaceutical partners running real‑world evidence studies, opening a secondary revenue stream.
Ⅸ. Market Entry Strategies & Case Examples
A. Strategic Partnering with Local Giants
Joint ventures with keiretsu‑aligned conglomerates remain the single fastest route to scale. Mitsubishi Corporation, for instance, co‑invested with a Canadian cleantech firm to build a direct‑air‑capture plant leveraging stimulus tax credits, slashing time‑to‑commercialisation by two years. Partners typically offer distribution, regulatory lobbying, and introductions to prefectural officials controlling subsidy purse‑strings. Foreign firms must negotiate IP clauses carefully: equity splits below 20 percent often preserve global licensing rights while satisfying local‑ownership optics. Successful alliances align board seats to ensure technology road‑maps dovetail with Japan‑specific customer requirements.
B. Licensing vs. Greenfield Investments
Licensing remains attractive where brand equity carries less weight than speed. A Danish med‑device maker sublicensed its endoscopic imaging algorithm to a Yokohama OEM, receiving royalties equal to 7 percent of net sales—twice its pre‑stimulus average—because subsidies covered the OEM’s integration costs. Conversely, greenfield plants benefit from generous land grants but expose firms to capacity‑utilisation risk. The optimal path often lies in a phased hybrid: begin with licensing to test demand, then reinvest proceeds into a majority‑owned facility once cumulative orders hit a pre‑defined threshold.
C. Lessons from Recent Success Stories
Three patterns stand out across stimulus‑era success stories: early prefectural engagement, bilingual compliance teams, and modular product design. U.S. EV‑battery recycler Redwood Materials secured ¥10 billion in subsidies by co‑hosting town‑hall meetings that quelled local environmental concerns. German SaaS provider Celonis assigned a trilingual audit specialist to pre‑validate subsidy applications, cutting approval time in half. Finally, Australian agri‑robotics start‑up SwarmFarm modularised its platforms to fit Japanese orchard row widths, capturing a segment ignored by larger rivals. Emulating such tactics accelerates traction while derisking capital allocation.
Ⅹ. Conclusion – How One Step Beyond Accelerates Your Japan Journey
Japan’s post‑pandemic stimulus has evolved from a defensive lifeline into a strategic re‑engineering of the world’s third‑largest economy. The sheer volume—more than ¥75 trillion—and unprecedented openness toward international collaboration create a once‑in‑a‑generation window for foreign innovators. Yet opportunity and complexity rise in tandem. Subsidy guidelines can change between fiscal years, English translations sometimes lag, and prefectural incentives vary in both generosity and paperwork burden. Even seasoned multinationals face hurdles synchronising Japanese grant cycles with global budget processes, negotiating keiretsu partnerships without ceding core IP, and satisfying overlapping ESG, privacy, and cybersecurity mandates.
That is where One Step Beyond (OSB) delivers quantifiable value. Our bilingual consultants combine on‑the‑ground regulatory intelligence with C‑suite strategy experience, guiding clients from initial feasibility studies through subsidy capture and long‑term operations. We maintain a proprietary database that tracks 2,500+ national and local incentives in real time, enabling rapid go/no‑go decisions and bespoke financial models that integrate tax, HR, and supply‑chain variables. Our sector‑specialist teams have secured a cumulative ¥68 billion in grants for overseas clients since 2021, with approval rates three times the market average.
OSB’s service stack is modular:
- Policy Watch delivers fortnightly alerts on budget reallocations and new RFPs, ensuring you never miss a filing deadline.
- Bid Engineering pairs former METI reviewers with technical writers to craft high‑scoring applications—complete with Japanese financial statements, ESG dashboards, and letters of local support.
- Partner Scouting leverages an alliance network spanning 180 prefectural‑level chambers of commerce and 50 industry associations, accelerating introductions to manufacturers, distributors, and universities.
- Post‑Award Compliance sets up grant‑reporting workflows, KPI dashboards, and audit‑defence playbooks, eliminating claw‑back risk.
Crucially, we embed your project within Japan’s broader industrial strategy, aligning milestones with the government’s DX, GX, and regional‑revitalisation timelines. The result is a launch pad that converts stimulus generosity into sustainable market share—without the detours, delays, and deadweight costs that often beset newcomers. Whether you are a seed‑stage med‑tech disruptor or a Fortune 500 industrial giant, One Step Beyond stands ready to navigate the stimulus maze and propel your Japan growth story from possibility to profitability.
References
- Cabinet Office of Japan, 2024 Annual Economic and Fiscal Report, Tokyo, 2024.
- Ministry of Economy, Trade and Industry, “Subsidy Programs for Manufacturing Reinforcement,” March 2025.
- Ministry of Health, Labour and Welfare, “Smart‑Hospital Subsidy Guidelines,” January 2025.
- Ministry of Internal Affairs and Communications, “Digital Garden City Initiative Progress Report,” February 2025.
- Tokyo Stock Exchange, “Listing Rules Revision Overview,” April 2025.