ZHIZU IOT: CSRC seeks supplementary materials on shareholder rights, export control

NewTimeSpace News: On 18 September 2026, the International Department of the CSRC issued supplementary material requirements for Zhizu IoT's overseas issuance and listing filing, covering seven items.

Regarding new shareholders, the CSRC requires an explanation of the reasonableness of the subscription prices of shareholders added in the last 12 months and the reasons for differences between them, together with a definitive conclusion on whether such prices are fair and reasonable and whether there is any transfer of benefits. Regarding shareholder relationships, the CSRC requires an explanation of whether shareholders holding less than 5% are related to one another, and if so, whether their shareholdings should be aggregated, with shareholders exceeding 5% to be subject to look-through verification. Regarding special shareholder rights, the CSRC requires an explanation of the complete and specific content of the arrangements, the specific terms of termination and the decision-making procedures performed, whether all shareholders have reached consensus, whether there are any disputes, and whether the arrangements constitute a material obstacle to the overseas offering and listing.

Regarding business and scope of operations, the CSRC requires an explanation of the specific circumstances of the Company's and its subsidiaries' business and scope of operations involving the sale of new energy vehicle battery-swapping facilities, value-added telecommunications services and industrial internet data services, whether such businesses are actually carried on and whether the necessary qualifications and permits have been obtained, and a look-through verification under Guideline No. 2 for Overseas Offerings and Listings of whether the business and scope of operations of subsidiaries and branches involve restricted or prohibited foreign investment sectors; the Company must also explain its business involving "technology import and export", whether its main business involves dual-use items or prohibited or restricted export technologies, the licensing and transfer of intellectual property, and the establishment and implementation of internal export control compliance management systems.

In addition, the CSRC requires an explanation of the performance of regulatory procedures for outbound investment and foreign exchange management in connection with its overseas subsidiaries, together with a definitive opinion on compliance; of the specific projects for which proceeds will be used to establish a localised service network in Southeast Asian markets and whether they comply with outbound investment rules, and of the relevant approval, authorisation or filing procedures, with an undertaking to repatriate all proceeds to the PRC where such procedures are in progress; and of whether the shares to be involved in the "full circulation" are subject to pledge, freezing or other defects in title.

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