Shanghai Union Technology: CSRC raises eight filing supplement requests

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). Shanghai Union Technology Corporation (Shanghai Union Technology) was asked to supplement materials regarding its overseas offering and listing, with its lawyers required to conduct verification and issue clear legal opinions, covering eight requirements.

On equity matters, the CSRC asked the Company to explain the pricing basis of each capital increase and equity transfer, the fairness of certain equity transfers priced at RMB0 or RMB1 and the income tax paid by the relevant transferors, whether such transfers are lawful and compliant and whether there is any benefit transfer, and to issue concluding opinions on the legality and compliance of its establishment and successive equity changes and on its qualifications and valid existence; it must also explain the background and reasonableness of granting equity incentives to external advisers, their basic information, and the comparison of their subscription prices with employee incentive prices and external investors' subscription prices in the same period, together with the pricing basis and fairness.

As 13 shareholders including Ma Jinsong signed a concert party agreement in January 2023, holding approximately 18.12% in aggregate, the Company must explain the agreement's main terms, how effective resolutions are formed when parties disagree, and whether control may change materially upon its expiry, and must explain the basis and reasonableness of its determination that it has "no controlling shareholder and no actual controller" and whether its corporate governance mechanism is sound; it must also explain the background and reasons for Zou Bo's exit, whether any pending disputes or potential controversies exist between Zou Bo and the Company or its other shareholders (including control and intellectual property ownership), and whether Zou Bo engaged in the same or similar business after exiting. In addition, the Company must supplement the progress of its state-owned shareholder identification and the performance of state-owned asset management procedures, explain the estimated proceeds assuming the over-allotment option is exercised in full and whether shares to be involved in the "Full Circulation" are pledged, frozen or subject to other rights defects, explain the details and termination reasons of its earlier A-share listing tutoring, whether it plans to continue pursuing an A-share listing, and whether its business involves AI large models and complies with the Administrative Measures for Generative AI Services.