Zixun Technology: CSRC seeks filing supplements on equity and ESOP

NewTimeSpace News: On 30 September 2026, the China Securities Regulatory Commission (CSRC) published its requirements for supplementary materials on overseas offering and listing filings (for the period from 20 September to 30 September 2026). Zixun Technology (Fujian) Co., Ltd. (Zixun Technology) was asked to supplement materials regarding its overseas offering and listing, with its lawyers required to conduct verification and issue clear legal opinions. Five requirements were raised, covering the compliance of its equity history, employee shareholding and option incentives, foreign investment access, core patented technologies and rights defects over shares to be involved in the "Full Circulation".

More specifically, the CSRC asked the Company to explain the pricing basis and paid-in capital of each capital increase and equity (share) transfer, whether any abnormal subscription price, failure to perform capital contribution obligations, capital withdrawal or defective contribution methods exist, whether the foreign investment involved complies with relevant rules, and whether any shareholding on trust or direct or indirect shareholding by entities prohibited by law exists, and to issue concluding opinions on the legality and compliance of the Company's establishment and successive equity changes and on whether there is any benefit transfer. With reference to the CSRC's Guidance on Regulatory Rules Application - Overseas Offering and Listing No. 2, the Company shall explain the background, membership, price fairness and decision-making procedures of its employee shareholding plan - including the subscription price, pricing basis and source of funds where any external persons participate - and elaborate on the exercise price basis and fairness of its option incentive plan and whether reserved equity is set aside. In addition, the Company shall list whether its business scope and actual operations involve restricted or prohibited areas under the Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition) and whether it continuously complies with foreign investment access policies before and after this offering and listing and the "Full Circulation", describe in plain language the core patented technologies, application scenarios and specific functions of its main products or services, explain why several controlled subsidiaries have no actual external business operations, and supplement whether the shares held by shareholders to participate in the "Full Circulation" are pledged, frozen or subject to other rights defects.