The China Securities Regulatory Commission (CSRC) issued a notice on April 3 regarding supplementary material requirements for overseas listing filings, covering the period from March 30 to April 3, 2026. The CSRC has requested that XSKY provide additional details on the specifics of its business involving AI large models, including application scenarios and specific functions. According to a filing disclosed by the Hong Kong Stock Exchange on January 27, XSKY submitted its listing application to the exchange, with Huatai International acting as its sole sponsor.
Additionally, the CSRC has asked XSKY to supplement explanations on the following matters and to have its legal counsel review and provide clear legal opinions: 1. Please supplement details on: (1) the prices and pricing basis for all previous capital increases and equity transfers, whether there were any abnormal share subscription prices, whether there was any benefit transfer, whether capital contributions were fully paid, whether there were instances of failure to fulfill capital contribution obligations, capital withdrawal, or flawed contribution methods, and the detailed circumstances of the company’s targeted capital reserve conversion into share capital for certain shareholders, including its legality and compliance; (2) please provide a conclusive opinion on whether the company’s establishment and all historical equity changes were lawful and compliant, as well as the company’s legal status and valid existence.
2. Please clarify: (1) the status of permanent residency abroad obtained by the company’s controlling shareholders, actual controllers, directors, and senior management; (2) whether there was any shareholding by proxy during the company’s historical evolution; (3) please supplement details on the handling of state-owned shareholder identification.
3. Please supplement explanations on: (1) whether the business of domestic entities involved restricted or prohibited foreign investment sectors during the establishment of the company’s red chip and variable interest entity (VIE) structures; (2) a conclusive opinion on the legality and compliance of regulatory procedures, including foreign exchange registration, overseas investment, foreign investment, and taxation, during the establishment and dismantling of the red chip and VIE structures.
4. Please supplement details on the background and internal decision-making procedures regarding the company’s provision of approximately 500 million yuan in interest-free loans to assist shareholder Kaitian Road in subscribing for shares, the subsequent three-party offset of debts and credits with investors such as Jichuang Xinyuan, whether there are any disputes or potential disputes, whether relevant taxes and fees were paid for the related transactions, and the legality and compliance of the above transactions.
5. Please supplement explanations on whether the business scope and actual operations of the company and its subsidiaries involve sectors restricted or prohibited for foreign investment, and whether they will continue to comply with foreign investment access requirements after the proposed listing and the implementation of the "full circulation" mechanism. Clarify whether the shares held by shareholders intending to participate in "full circulation" are subject to pledge, freeze, or other encumbrances.
According to its prospectus, XSKY specializes in providing enterprise-level AI storage solutions, helping companies efficiently integrate data, decision-making, and operations on a large scale. Data from CIC indicates that the top five distributed AI storage solution providers in China accounted for a combined market share of 52.3% based on installed capacity in 2024, with XSKY holding a 10.4% market share. The company is the second-largest distributed AI storage solution provider in China and the largest independent provider in this segment.
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