The Texas Stock Exchange (TXSE) commenced live trading on July 10, 2026, following formal approval from the SEC on September 30, 2025. The exchange employed a phased symbol rollout: designated test securities traded from July 6 through July 9, live trading in five National Market System (NMS) securities began on July 10, and all NMS symbols are expected to be available by the end of July. ETP listings are anticipated to commence in September 2026, with corporate listings following in October 2026. The launch is significant for multiple reasons: the TXSE is the first fully integrated national securities exchange (combining trading, corporate listings, and ETP listings) to receive SEC approval and open operations in over two decades; it is headquartered in Dallas, Texas, embedding itself in one of the fastest-growing economic regions in the United States; capital-markets participants recognize that the launch introduces additional choice in listing venues and trading infrastructure, challenging the longstanding duopoly of the New York Stock Exchange (NYSE) and the Nasdaq Stock Market (Nasdaq); and it is backed by $275 million from investors, making it the most well-capitalized equities exchange ever approved by the SEC.
Goal and Potential Benefits
The TXSE is intended to capitalize on the Southwest’s strong economic and demographic growth by expanding access to public capital markets for companies in the region. As Texas and neighboring states continue to attract corporate relocations and a growing base of mid-cap and emerging growth companies, the exchange aims to support long-term shareholder value by offering a listing venue aligned with companies’ growth trajectories, governance preferences, and capital needs.
A central goal of the TXSE is to introduce meaningful competition to the long-standing exchange duopoly, creating potential benefits for both issuers and investors. Through a fully electronic trading platform, the exchange seeks to enhance efficiency while reducing operational and compliance costs. The TXSE’s listing standards and corporate governance requirements are structured to enhance accessibility while maintaining substantive requirements largely consistent with the NYSE and Nasdaq, particularly for companies seeking a streamlined alternative.
The TXSE is expected to operate within a federal securities law regime substantially similar to that governing the NYSE and Nasdaq. Its corporate governance requirements and exemptions align closely with established NYSE and Nasdaq frameworks, though TXSE has expressed an intent to adopt a more business-friendly model, particularly for emerging growth companies. Its rules resemble the Nasdaq Global Select Market’s approach with respect to issuer notification obligations, disclosure of material information, shareholder approval requirements, and audit committee composition. Like NYSE and Nasdaq, TXSE offers phase-in periods for newly public companies, granting up to one year to meet board and committee independence requirements.
Distinctions from Duopoly
Despite substantial alignment with the NYSE and Nasdaq, the TXSE differentiates itself in several important respects. Most notably, the TXSE features a single-tier listing structure, in contrast to the multi-tiered frameworks of the NYSE and Nasdaq, signaling an intent to focus on mid- to large-cap issuers. The TXSE also requires a mandatory confidential pre-application review, a requirement not imposed by NYSE or Nasdaq, along with quantitative standards that can be more stringent, including a minimum bid price of $4.00 per share for both initial and continued listing (compared to $1.00 for continued listing on NYSE and Nasdaq).
Certain aspects of the TXSE’s regulatory and enforcement approach remain under development. Unlike the NYSE and Nasdaq, which have long-established compliance programs, interpretive guidance, and disciplinary processes, the TXSE is still finalizing how its listing standards will be interpreted, monitored, and enforced. It remains to be seen how the TXSE will implement its enforcement mechanisms, exercise regulatory discretion, and coordinate oversight with the SEC and other exchanges as operations expand.
Dual Listing
The TXSE may initially focus on attracting companies already listed on the NYSE or Nasdaq to dual list. NYSE Texas, a Dallas-based trading venue operated by NYSE’s parent company, has already embraced this model, and over 100 companies, including Halliburton, AT&T, IBM, and Whirlpool Corporation, are now dual listed on both the NYSE and NYSE Texas with minimal additional regulatory burdens. While the TXSE’s attractiveness as a dual-listing venue will depend on its fee structure and operational track record, it has already signaled international ambitions: Nicole Chambers, the TXSE’s Global Managing Director of Listings, promoted the exchange as a dual-listing destination for companies listed on the Mexican Stock Exchange (Mexbol), stating that the TXSE “would like to be able to give Mexican companies, and companies from other countries, access to public markets in the United States in the most friendly way possible.” If the TXSE offers dual listing with low incremental costs and few additional burdens, it could serve as an attractive entry point for domestic and international companies seeking access to the Texas market without sacrificing the benefits of their primary listing.
Considerations for Issuers
Companies evaluating a TXSE listing should consider several factors. First, eligibility: the TXSE’s single-tier structure and relatively high quantitative thresholds (including the $200 million market cap or $10-12 million earnings test, $4.00 minimum bid price, and distribution criteria) may exclude smaller or early-stage issuers that would otherwise qualify for Nasdaq’s Capital Market tier. Second, regulatory maturity: unlike the NYSE and Nasdaq, which have decades of interpretive guidance, published FAQs, and established compliance practices, the TXSE’s framework is still developing, which may create uncertainty around how listing standards will be interpreted and applied. Third, fee structure: the TXSE has committed to competitive listing and compliance fees, but specific fee schedules have not yet been publicly disclosed, making cost comparisons difficult at this time. Fourth, liquidity: as a newly launched exchange, the TXSE’s trading volume and market depth remain unproven, which may affect price discovery and investor confidence. Finally, governance environment: issuers seeking to limit shareholder activism may find Texas’s recent legislative reforms attractive. However, under the Texas Business Organizations Code, SB 1057’s heightened shareholder proposal thresholds are available only to “domestic corporations” (i.e., corporations incorporated in Texas) that also either have their principal office in Texas or are listed on an approved Texas-based exchange. Accordingly, a Delaware-incorporated company listing on the TXSE would not be eligible to opt into SB 1057 without first reincorporating in Texas.
Path Ahead
The approval and launch of the TXSE marks a significant development in U.S. capital markets. Issuers considering a TXSE listing (whether primary or dual) will need to carefully evaluate how the exchange’s evolving rules, fee structures, and enforcement practices compare to those of existing venues. Our firm will monitor its progress closely. Whether the TXSE ultimately emerges as a meaningful competitor to the NYSE and Nasdaq, a preferred dual-listing venue, or a niche alternative will depend on how effectively it executes its regulatory vision and delivers on its stated goals.
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We are available to discuss any questions you may have concerning the foregoing matters.
Gabe Steele, Bryan Gales, Gabriella Joseph, Ashley Qamar, and Nicholas O’Connor
This memorandum is provided for information purposes only and is not intended to provide legal advice. Such advice may be provided only after engagement for advice and analysis of specific facts and circumstances and consideration of issues that may not be addressed in this document.