EHOLY receives CSRC supplementary filing requirements for Hong Kong listing, queried on shareholding entrustment, new shareholder pricing, industry competition and full circulation share defects

NewTimeSpace News: On November 9, 2026, the CSRC disclosed on November 6 its supplementary filing requirements for overseas listings. Between November 2 and November 6, 2026, the International Cooperation Department issued supplementary filing requirements to three companies, among them Guangzhou EHolly Intelligent Equipment Co., Ltd.

For EHOLY, the CSRC requires the company to explain whether there is any other shareholding entrustment (nominee holding) among its existing shareholders and in its historical evolution, including but not limited to its controlling shareholder and actual controller, and to list the names of the entrusting and nominee parties, the entrusted shareholding ratio, the start and end dates of the entrustment and the method of termination. In accordance with the Guidelines on the Application of Regulatory Rules — Overseas Listing No. 2, the company must further explain the reasons for the formation of the entrustment, its evolution, legality and compliance, and whether any disputes exist; and in accordance with Article 8 of the Trial Measures for the Administration of Overseas Securities Offering and Listing by Domestic Companies, it must explain whether the controlling shareholder's equity involves major ownership disputes or tunneling of benefits.

The CSRC also requires EHOLY to explain the pricing basis for new shareholders' capital contributions within 12 months prior to the filing application, the reasons for pricing differences and their reasonableness, and the income tax paid by transferors in the relevant equity transfers, and to issue a conclusive opinion on whether any tunneling of benefits exists. The company must also explain the regulatory regime of its industry, the major players in the industry and its comparison with comparable companies in terms of operations and market position. In addition, it must explain whether the shares held by shareholders participating in the “full circulation” are subject to pledges, freezing or other rights defects. All the above matters must be verified by lawyers, who shall issue clear legal opinions.