"We are looking into the possibility of a third listing," a spokesman said.
SAP will have to wait until China has finalized plans to set up an international board in Shanghai to attract foreign listings.
China has been talking about the launch of an international board on the Shanghai Stock Exchange. It was about to kick off the new board in the second half of last year but the move was delayed by the euro zone debt crisis.
SAP is already listed in Germany and New York.
The group, which competes with Oracle, IBM and Microsoft, wants to invest $2 billion in China by 2015.
It also has a mid-term sales target of 1 billion euros ($1.29 billion) for China, which in the third quarter showed a 40 percent growth in software sales, making it SAP's sixth-largest market.
($1 = 0.7761 euros)
(Reporting by Harro ten Wolde; Editing by Mark Potter)
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