DST Sustainable Technology: CSRC requires explanation on shareholding on trust and automotive circulation system filing, among 4 items

On 11 September 2026, the CSRC published the supplementary material requirements for overseas listing filing, requiring DST Sustainable Technology (Shenzhen) Co., Ltd. to supplement 4 items, including the pricing basis of historical capital increases and share transfers and verification of shareholding on trust, the subscription prices of shareholders newly added in the 12 months before the filing application, the impact of certain subsidiaries' failure to complete filing with the national automobile circulation information management system, and foreign investment access and title defects of "full circulation" shares.
Key Highlights:
  • The Company must supplement the prices and pricing basis of its historical capital increases and share transfers, whether there were abnormal subscription prices or any transfer of benefits and whether capital contributions were paid up, and verify whether shareholding on trust existed in its corporate history.
  • The Company must explain the impact of the failure of certain subsidiaries to complete filing with the national automobile circulation information management system on business operations and whether it constitutes an obstacle to the offering.
  • The Company must explain whether the business scope and actual business of the Company and its subsidiaries involve restricted or prohibited areas for foreign investment and whether they will continue to comply with foreign investment access requirements after the offering and "full circulation".

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 DST Sustainable Technology (Shenzhen) Co., Ltd. to provide supplementary explanations on 4 items, with its PRC legal counsel required to conduct verification and issue clear legal opinions.

On equity matters, the Company is required to supplement the prices and pricing basis of its historical capital increases and share transfers, whether there were any abnormal subscription prices or any transfer of benefits, whether capital contributions were paid up and whether there was any failure to fulfil capital contribution obligations, withdrawal of capital contributions or defect in the form of contribution; to explain whether shareholding on trust existed in its corporate history; and to issue a conclusive opinion on whether its establishment and historical equity changes were legal and compliant and on its legal personality and valid existence. The Company is also required to supplement the pricing basis for 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 and rationality of differences from the pricing of concurrent capital increases, and the payment of income tax by the relevant transferors in such share transfers, and to issue a clear conclusive opinion on whether there is any transfer of benefits.

On business and compliance, the Company is required to supplement the impact of the failure of certain subsidiaries to complete filing with the national automobile circulation information management system on business operations and whether such failure constitutes an obstacle to the offering; and to explain whether the business scope and actual business of the Company and its subsidiaries involve areas restricted or prohibited for foreign investment and whether they will continue to comply with foreign investment access requirements after the offering and "full circulation". 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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