Shenzhen Pu Ying Innovation Technology has been asked by the China Securities Regulatory Commission to provide supplemental explanations regarding its historical equity changes and other matters as part of its planned Hong Kong listing.
The CSRC's International Department issued the supplementary material requirements for overseas offering and listing filings covering the period from October 26 to October 30, 2026, applying to five companies including Pu Ying Innovation.
According to disclosures filed with the Hong Kong Stock Exchange on June 30, Shenzhen Pu Ying Innovation Technology submitted a listing application to the Hong Kong Stock Exchange's Growth Enterprise Market, with Eddid Capital serving as its sole sponsor.
The CSRC has requested that Pu Ying Innovation provide supplementary explanations on the following matters, with lawyers conducting verification and issuing clear legal opinions:
First, regarding historical equity changes: (1) the company has undergone capital reductions in its history, and it must explain the reasons and reasonableness of such reductions, whether necessary legal procedures were followed, and the tax payment situation; (2) the pricing and pricing basis for each capital increase and equity transfer, whether there were abnormal share subscription prices, whether there was any tunneling of benefits, whether capital contributions were fully paid, and whether there were circumstances of unfulfilled capital contribution obligations, withdrawal of capital contributions, or defective contribution methods; (3) provide a clear conclusive opinion on whether each historical equity change was legal and compliant.
Second, the company is required to provide a table listing the names of both parties to nominee shareholding arrangements throughout its corporate history, the proportion of equity held under nominee arrangements, the start and end times of such arrangements, and the methods of termination, and further explain the reasons for the formation of equity nominee arrangements, their evolution, legality and compliance, whether there are disputes or potential disputes, whether there is any tunneling of benefits, and whether the nominee shareholder was a party prohibited from holding shares under laws and regulations (including whether there was any violation of non-compete provisions), in accordance with the relevant provisions of the Regulatory Rules Application Guidelines No. 2 for Overseas Offering and Listing.
Third, the company holds a fixed pollution source discharge registration qualification, and it must explain whether its completed, under-construction, and planned projects constitute "high energy consumption" or "high emission" projects.
Fourth, the company must explain whether the shares held by shareholders participating in the "full circulation" arrangement are subject to pledges, freezing, or other defects in rights.
Fifth, regarding business operations: (1) the basis for calculating the company's market share in the filing materials, and further explanation of the company's industry position and relevant basis in comparison with comparable listed companies in the same industry; (2) further explanation of the company's business operating model and core competitiveness, taking into account major customers and suppliers during the reporting period, product functions, pricing basis and specific application scenarios, and the consistency between revenue scale and industry position.
Sixth, the company must explain the internal decision-making process for dividend distribution during the reporting period and the fulfillment of tax payment procedures, and explain the reasonableness of implementing dividends given the company's liabilities and cash flow situation, as well as the necessity of this listing and fundraising given the dividend distribution.
According to the prospectus, Pu Ying Innovation is a leading manufacturer of enterprise-level financial smart printing and document processing equipment founded in 2015, primarily engaged in the design, research and development, production, and sales of mission-critical specialized printers, print-scan integrated devices, intelligent self-service equipment and terminals, as well as consumables, components, and other products.
The company's products are mainly used in the banking and financial sector for passbook, deposit slip, and voucher printing and applications. It has served more than 186 customers and its products are sold to over 54 countries and regions.
According to Frost & Sullivan data, the company ranked first in the global financial smart printing and scanning equipment market by revenue in 2025. From 2016 to 2025, based on cumulative shipments, the company's historical installed base of highly reliable printing and scanning equipment reached 748,518 units, accounting for approximately 4.9% of total global installed base in the relevant market, ranking first in the industry.
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