Nasdaq Proposes New "Fast Entry" Rule for the Nasdaq-100 Index
11 February 2026
Many market watchers are looking forward this year to several potential large new IPOs by major technology companies, such as Anthropic, OpenAI and SpaceX. In February 2026, Nasdaq, the sponsor of the Nasdaq-100 Index (the "NDX"),1 proposed a new "fast entry" rule that could enable the early inclusion of these types of companies into the index. The rule change is designed to ensure that NDX investors need not wait a significant amount of time before gaining exposure to these stocks after they effect an IPO and list on the Nasdaq.
A rule change of this kind would impact the exposure of structured products and investment funds that track the NDX (and proprietary indices that are based in part on the NDX).2
Nasdaq's consultation, which sets forth the proposal, may be accessed here. The current NDX methodology may be accessed here.
Current Schedule for Inclusion
Under the current NDX index methodology, new constituents are typically added to the NDX at the time of the annual reconstitution, which occurs in December of each year, if they have been publicly traded for a "seasoning period" of at least three months. This feature of the rules means that there could be a significant delay before a major company that has recently completed an IPO and listed on Nasdaq is added to the NDX, even if investors want or expect exposure to that company in order to reflect the then-current characteristics of Nasdaq activity. If one or more of these anticipated IPOs occurs, and the issuer lists on Nasdaq, it could take some time before the company is included in the NDX, even if its market capitalization and trading volume would exceed that of many current NDX constituents.
Proposed Fast Entry Rule
To address these types of situations, Nasdaq proposes to create a "fast entry" rule to enable newly-listed Nasdaq companies to potentially enter the NDX. Under the proposal, a newly-listed Nasdaq company will be evaluated for index inclusion. If its market capitalization would rank within the top 40 current constituents in the NDX (approximately $100 billion as of year end), the company would be announced as a "fast entry” addition to the index, subject to five trading days' prior notice, and would then be added after 15 trading days. The relevant company would be exempt from the NDX's current seasoning requirements (typically, more than three months of trading) and liquidity requirements (typically, a three-month daily traded value of at least US$5 million). If adopted, this "fast entry" rule would also apply to any company that changes its listing to Nasdaq from an ineligible exchange.
The inclusion of the new company would not require the removal of another security from the NDX. Instead, the number of constituents of the NDX would be increased until the next annual reconstitution. (As a result, the Nasdaq 100 can consist of more than 100 members.)
Additional Proposed Methodology Revisions
Nasdaq has also proposed a few additional changes to the NDX methodology. These proposed revisions relate to, among other things:
- To evaluate a company's entire market capitalization, including both listed and unlisted shares, for purposes of index eligibility and ranking.
- Revisions to the NDX rules relating to including and weighting securities with a low free float (i.e., less than 20% free float instead of the current 10% threshold).
- Adjustments to its rules relating to removing securities with smaller market capitalization from the NDX.
The details relating to these proposals may be found in the linked page set forth above.
Timetable
The proposed NDX rule changes are subject to public comment until February 27, 2026. To the extent that any of the rule changes are adopted, Nasdaq expects that the new methodologies will be implemented only after the scheduled March 2026 quarterly index rebalance. This timetable would potentially permit the inclusion of these expected IPOs into the NDX during 2026 if the companies list on Nasdaq, and have the substantial market capitalizations that many anticipate.
- The NDX is an equity index that includes 100 of the largest U.S. and non-U.S. non-financial companies listed on The Nasdaq Stock Market, based on market capitalization. The NDX is the underlying index for a number of major ETFs, and a significant amount of structured notes and structured CDs, issued both in and outside of the U.S., are linked to the NDX or those ETFs.
- In addition, pricing supplements, FWPs, underlier supplements and other disclosures that describe the NDX index methodology are likely to require some revisions to reflect a rule update of this kind.
