China's securities regulator has requested additional disclosures from Nali New Materials regarding the pricing rationale behind its historical capital increases and equity transfers, alongside verification of paid-in capital contributions, according to a filing released on August 28.
The China Securities Regulatory Commission (CSRC) issued supplementary documentation requirements for five companies pursuing overseas listings during the period of August 24-28, 2026. Among them, the regulator directed Nali New Materials to provide detailed explanations on whether capital injections were fully paid, whether any instances of unpaid capital obligations, capital withdrawal, or defective contribution methods exist, and to furnish a clear conclusive opinion on the legality and compliance of its establishment and historical equity changes.
As disclosed in the Hong Kong Stock Exchange filing on May 28, Yangzhou Nali New Materials Technology Co., Ltd. has submitted an application for a main board listing in Hong Kong, with BNP Paribas serving as the sole sponsor.
The CSRC has requested Nali New Materials to address the following matters, with legal counsel required to verify and issue explicit legal opinions:
Clarification on equity restructuring
First, regarding equity changes: (1) The company must explain the pricing basis for each historical capital increase and share transfer, confirm whether contributions were actually paid in full, and assess whether any situations exist involving failure to fulfill capital contribution obligations, capital withdrawal, or defects in contribution methods. A definitive conclusion on the legality and compliance of its establishment and all historical equity changes must be provided. (2) The company must clarify whether any shareholding arrangements involving nominee holdings exist in its corporate history.
Investor structure review
Second, concerning shareholder matters: (1) The company must disclose whether any domestic entities holding more than 5% of its shares, after looking through to the ultimate level, include parties prohibited from holding equity under relevant laws and regulations. (2) The progress of the state-owned shareholder identification process for Jiantou Investment must be reported. (3) The company must explain the reasonableness of entry prices for new shareholders added within the past 12 months, identify reasons for any pricing discrepancies among these investors, and provide a clear opinion on whether any interest transfer arrangements exist.
Employee incentive plan compliance
Third, pertaining to equity incentives: (1) In accordance with the requirements of the Regulatory Guidelines for Overseas Listings and Issuances (Category No. 2), the company must verify whether five former employees retain equity interests as stipulated under the employee stock ownership plan charter or agreements, and update the progress on share transfer procedures and industrial and commercial registration changes for the shareholding platforms involved. (2) A definitive legal opinion must be issued regarding the legality and compliance of the employee stock ownership plan's implementation and whether any benefit transfers are involved.
Sector policy consistency check
Fourth, the company is required to explain whether its business operations fall within sectors subject to overcapacity controls by the National Development and Reform Commission or the Ministry of Industry and Information Technology, and whether it complies with the national "anti-involution" policy requirements, with supporting evidence to be provided.
Listing and capital raise details
Fifth, regarding the proposed listing: (1) The company must estimate the total expected fundraising amount if the over-allotment option is exercised in full. (2) It must clarify whether any shares of shareholders participating in the "full circulation" arrangement are subject to pledges, freezes, or other title defects.
According to its prospectus, Nali New Materials is a globally leading new energy materials company focused on the research, development, and manufacturing of advanced functional current collectors. It supplies advanced functional current collector products and technical solutions to battery manufacturers and electric vehicle makers.
Based on data from Frost & Sullivan, Nali New Materials ranked third globally among functional interface current collector manufacturers by shipment volume in 2025. As of December 31, 2025, the company ranked first globally among composite current collector manufacturers, with an annual production capacity of 62.9 million square meters for atomic-layer-deposited current collectors—a specialized composite current collector treated through atomic layer deposition to enhance safety performance, increase energy density, and reduce costs.
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