CSRC Seeks Supplementary Filing Materials From 5 Firms Pursuing HK IPOs

On 30 September 2026, the CSRC issued supplementary filing requirements to five companies pursuing Hong Kong listings, covering capital and compliance.

NewTimeSpace News: On 30 September 2026, the China Securities Regulatory Commission (CSRC) published its Supplementary Filing Requirements for Overseas Offering and Listing (20 September to 30 September 2026). During the period, the International Cooperation Department of the CSRC issued supplementary filing requirements to five companies, namely Zixun Technology (Fujian) Co., Ltd., POCO Holding Co., Ltd. (300811.SZ), Shanghai Union Technology Corporation, Digiwin Co., Ltd. (300378.SZ) and Huizhou Desay SV Automotive Co., Ltd. (002920.SZ), covering share capital history, compliance and access, and business and funding matters, with lawyers required to verify the matters and issue clear conclusive legal opinions.

Zixun Technology is required to explain the pricing basis and paid-in capital of its historical capital increases and equity or share transfers, including any abnormally priced subscriptions, unpaid capital contributions, capital withdrawal or nominee shareholdings, and to address the compliance of its employee share scheme and option incentive scheme under the CSRC's Regulatory Rules Application Guidelines No. 2 for Overseas Offering and Listing, as well as whether its business scope and actual business involve fields restricted or prohibited under the Negative List for Foreign Investment Access.

POCO Holding (300811.SZ) is required to explain whether it and its subsidiaries actually carry out the property management business within their business scope, whether the industry is classified as "high energy consumption" or "high emission", whether the administrative penalty imposed on Huizhou POCO over a work safety accident constitutes a major violation, the compliance of the overseas investment and foreign exchange registration involved in setting up its overseas subsidiaries, and the necessity of its Hong Kong listing in light of the use of proceeds.

Shanghai Union Technology Corporation is required to explain the pricing basis of its historical capital increases and equity transfers, the fairness of certain transfers priced at RMB 0 or RMB 1, the background and pricing fairness of equity incentives granted to external advisers, the basis for the concert party agreement among 13 shareholders including Ma Jinsong and the determination of "no controlling shareholder and no de facto controller", the background of founder Zou Bo's exit and potential disputes, the progress of state-owned shareholder identification, the reasons for terminating its earlier A-share listing guidance, and whether its business involves large AI models.

Digiwin (300378.SZ) is required to explain the compliance of the overseas investment and foreign exchange management involved in setting up its overseas subsidiaries, whether major borrowing and credit facility contracts may lead to major ownership disputes or changes in major shareholders, all pending litigation and arbitration, the amounts and ratios of proceeds to be used for domestic and overseas investment projects and the relevant approval procedures, the fairness of related-party transactions with Foxconn Industrial Internet during the reporting period, and its property management and cultural and artistic exchange activities.

Huizhou Desay SV Automotive (002920.SZ) is required to explain the compliance of the overseas investment and foreign exchange management involved in setting up its overseas subsidiaries, whether major borrowing and credit facility contracts may lead to major ownership disputes or changes in major shareholders, all pending litigation and arbitration, the necessity and reasonableness of its Hong Kong listing in light of the use of proceeds, and the progress of its intelligent robot business and whether it involves embodied intelligent robots.

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