Lingka Technology: CSRC requires explanation on subscription prices of new shareholders and advertising business operations, among 5 items

On 11 September 2026, the CSRC published the supplementary material requirements for overseas listing filing, requiring Hangzhou Lygo Technology Co., Ltd. to supplement 5 items, including the rationality of subscription prices of shareholders newly added in the 12 months before the filing application, shareholding on trust in its corporate history, the operations and revenue of its advertising design and agency businesses, and the compliance of its option incentive plan.
Key Highlights:
  • The Company must explain the rationality of the subscription prices of shareholders newly added in the 12 months before the filing application, the reasons for price differences and whether there were abnormal subscription considerations, and verify shareholding on trust under Guideline No. 2.
  • Its business scope includes advertising design, agency, production and publication, and the Company must explain whether product placement is involved and the revenue scale, proportion and customers during the reporting period, as well as the necessity of including market research, e-commerce, consultancy and cultural exchange activities in its business scope.
  • The Company must supplement in its filing report the number of shares to be issued and the proportion thereof in the post-offering total share capital, the specific use of proceeds and their domestic and overseas proportions, and whether any proceeds will be invested in overseas projects and the relevant approval, verification or filing procedures performed.

NewTimeSpace News: On 11 September 2026, the International Cooperation Department of the CSRC published the supplementary material requirements for overseas issuance and listing filing for the period from 7 September 2026 to 11 September 2026, requiring Hangzhou Lygo Technology Co., Ltd. to provide supplementary explanations on 5 items, with its PRC legal counsel required to conduct verification and issue clear legal opinions.

On equity changes, the Company is required to supplement the rationality of the subscription prices of shareholders newly added in the 12 months before the submission of its overseas issuance and listing filing application, the reasons for differences in such prices and whether there were any abnormal subscription considerations; it must also explain whether shareholding on trust existed in its corporate history and, if so, conduct verification in accordance with the requirements on shareholding on trust under the Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing No. 2.

On business operations, the Company is required to explain the specific operations of its and its subsidiaries' business scope involving advertising design, agency, production and publication and whether such business involves product placement, and if so, further explain the revenue scale, proportion and customer information during the reporting period; it must also explain the operations of its business scope involving market research, e-commerce, social and economic consultancy services and the organisation of cultural and artistic exchange activities and the necessity of including them in its business scope. The Company must also, in accordance with the guidelines on the content and format of filing materials, supplement in its filing report the number of shares to be issued in the offering and the proportion thereof in the total share capital after the offering, the specific use of proceeds and the proportion for domestic and overseas use, whether the proceeds will be invested in overseas investment projects and whether the necessary approval, verification or filing procedures of the competent authorities have been performed; and explain the basic contents of its option incentive plan, the basic information of the grantees, the principles for determining grant and exercise prices, whether reserved interests are set aside and whether there is any transfer of benefits, and issue a conclusive opinion on compliance. In addition, the Company must supplement whether the shares held by shareholders intending to participate in the "full circulation" are subject to pledge, freezing or other title defects.

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