Not sure. For a 'Current Information' designation on pinksheets, it just notes that companies 'must meet Pink Sheets Guidelines for Providing Adequate Current Information, but it does not actually list the guidelines. According to Ron, pinksheets is continually making changes in regards to how to comply. FWIW, below is the relevant section of the listing requirements for the Prime tier (bold is mine). It would appear to leave a fair amount of 'wiggle room':
g) Have (i) audited balance sheets as of the end of each of the two most recent fiscal years, or as of a date within 135 days if the Company has been in existence for less than two fiscal years, and audited statements of income, cash flows and changes in stockholders’ equity for each of the fiscal years immediately preceding the date of each such audited balance sheet (or such shorter period as
the Company has been in existence), with each such financial disclosure made in accordance with U.S. GAAP and including all matters of which the Company is aware that are relevant to the Company’s ability to continue as a going concern,
including, without limitation, significant conditions and events and the Company’s plans to mitigate such conditions and events; and (ii) unaudited interim financial
reports, prepared in conformance with U.S. GAAP, including a balance sheet as of the end of the Company’s most recent fiscal quarter, and income statements, statements of changes in stockholders’ equity and statements of cash flows for the interim period up to the date of such balance sheet and the comparable period of the preceding fiscal year;