Project 2025 Tracker / What’s done, what’s next

26. Trade · Notable · Contested — excluded from counts

Delist Chinese stocks that fail PCAOB standards

Attempted

789 26. Trade · from “The Case for Fair Trade”

“Delist any Communist Chinese stocks that do not meet Public Company Accounting Oversight Board standards or, alternatively, close off the Chinese “A shares” stock market to U.S. investment and deregister U.S.-sanctioned Communist Chinese companies.”

What has happened

  1. Attempted

    The SEC approved, on accelerated review, Nasdaq's heightened listing standards for companies primarily operating in China, Hong Kong and Macau - chiefly a $25 million minimum firm-commitment offering. The order recites the Holding Foreign Companies Accountable Act and the America First Investment Policy as the concerns behind it, but it governs who may list in future, not who is delisted, and it does not turn on PCAOB inspection. The order also records the fact that defeats the Quote's own test: the PCAOB "was able to secure complete access to inspect and investigate audit firms in the PRC in December 2022", so the statutory delisting trigger has not been live at any point in the window.

  2. Attempted

    Section 2(l) of the America First Investment Policy memorandum orders the reviews this ask depends on: Treasury, with the SEC and the PCAOB, is to "determine if adequate financial auditing standards are upheld for companies covered by the Holding Foreign Companies Accountable Act", and the Attorney General with the FBI is to give "a written recommendation on the risk posed to United States investors based on the auditability, corporate oversight, and evidence of criminal or civil fraudulent behavior for all foreign adversary companies currently listed on domestic exchanges". No company has been delisted, the A-shares market has not been closed to U.S. investment, and no sanctioned Chinese company has been deregistered.

Research log

What was searched, and what didn’t count as evidence

Research notes

Dated on the order’s own date line (May 14, 2026), not on Federal Register publication (2026-05-19), following playbook 4.

The Quote has three limbs and none was delivered: delist Chinese stocks that fail PCAOB standards; or close the A-shares market to U.S. investment; or deregister U.S.-sanctioned Chinese companies. The first is inoperative on its own terms while the PCAOB retains inspection access. Federal Register full text for the window returns four documents mentioning the Holding Foreign Companies Accountable Act, three of them stages of the same Nasdaq filing (2025-09-19 notice, 2025-12-23 order instituting proceedings, 2026-05-19 approval) and the fourth the SEC’s Registered Offering Reform proposal.

Negative search, 2026-09-03 (read-queue ticket 04). sec.gov is no longer a wall: it opens to the full browser header set, and the Commission’s own HFCAA identification list was read in full at https://www.sec.gov/hfcaa. It is a clean negative and it settles the item’s reading from the statutory list itself rather than from a recital inside a Nasdaq approval order. The page states “There is currently no issuer on the provisional list”; the conclusive list holds about 170 issuers, every identification date on it falls between 2022-03-30 and 2023-02-01 (the last is Leader Capital Holdings Corp., February 1, 2023), and every entry in both the “Current trading prohibition” and “Prior trading prohibition” columns reads “Not applicable”. No issuer has been identified since 2025-01-20; none is under a trading prohibition; none ever has been. The Commission gives the reason in its own words: after the PCAOB vacated its 2021 determinations on 2022-12-15, “until such time as the PCAOB issues any new determination, there are no issuers at risk of having their securities subject to a trading prohibition under the HFCAA”.

The page is Primary and allowlisted, but its own footer reads Last Reviewed or Updated: April 10, 2023 and its last substantive entry is 2023-02-01 — before 2025-01-20 — so it is cited here in the note rather than as frontmatter Evidence, which the gate would reject.

One correction to an earlier framing: the statutory trigger is two consecutive years of identification, not three. The Consolidated Appropriations Act, 2023 (2022-12-29) cut it from three to two, and the Commission’s page says so.

No Commissioner statement and no Treasury/PCAOB report produced under § 2(l)(i) of the America First Investment Policy memorandum was found; the page’s Resources block links only pre-2023 material.

Action
eliminate
Object
Listings of Chinese stocks failing PCAOB standards
ID
2083