From the OTCM guidelines I've seen, securities on the Pink Limited tier have 16 months from the end of their last annual filing period (which was 12/31/2022 for JPEX) before they are downgraded to Expert Market (EM).
That 16-month period will lapse on April 30, 2024 for JPEX. OTCM has also recently instituted a 15-day grace period after the 16-months have passed and late filers can still avoid EM if they file an annual report before the end of the 15-day "grace period". I own a ticker that recently went through this process. Unfortunately they filed their annual report after the grace period ended and were immediately downgraded to EM. Fortunately they were on the EM market for only one day and are now back to Pink Limited.
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