Three years since the implementation of the filing system: technology, healthcare, and consumer companies actively applying for overseas listings

Securities Daily reporter Mao Yirong

On March 31, the “Trial Measures for the Administration of Securities Issuance and Listing by Domestic Enterprises in Overseas Markets” (hereinafter referred to as the “Record-Filing New Rules”) entered its third year of implementation.

To support enterprises in leveraging overseas capital markets for standardized development, and to insist on implementing the requirements of the “streamlining administration, delegating powers, and optimizing services” reform, permission-based management has been changed to record-filing management. Based on publicly released data from the CSRC, Securities Daily reporter statistics show that since the Record-Filing New Rules took effect, as of March 31, 2026, a total of 734 enterprises have submitted record-filing applications. Of them, 471 enterprises received record-filing notices (including initial public offerings and “full circulation”), while another 263 enterprises’ record-filing applications have been accepted by the CSRC.

In terms of listing destinations, the Hong Kong Stock Exchange and the Nasdaq Stock Market have become the two main listing destinations, together accounting for more than 94%, reflecting a highly concentrated regional characteristic of overseas issuance and listings by mainland enterprises. In terms of industry, technology, healthcare, and consumer companies are the primary sectors. In addition, among companies listing in Hong Kong, A-share listed companies frequently appear, and the record-filing types are being advanced in parallel with “direct listing + full circulation.”

Efficiency continues to improve

From the entities that have completed record-filing, consumer-oriented companies such as Mixue Bingcheng Co., Ltd., Zhouliufo Jewelry Co., Ltd., Bamachaye Co., Ltd., Shenzhen Best Fruit Industry (Group) Co., Ltd., and many technology companies have all chosen to list in Hong Kong stocks.

In terms of record-filing type, “direct overseas listing + full circulation” proceeds in parallel. Most enterprises simultaneously apply for “direct overseas listing” and “full circulation.” Data show that among the 471 companies mentioned above, 123 companies both applied for and obtained record-filing notices for overseas issuance and listing and for “full circulation” of domestically unlisted shares. For example, companies including Jitai Technology (Beijing) Co., Ltd., Shenzhen Ledu Robotics Co., Ltd., Shenzhen Maiketian Biotechnology Medical Technology Co., Ltd., and others have already applied for record-filing and obtained the CSRC’s record-filing notices. This indicates that enterprises are not only advancing overseas issuance and listings, but also promoting the overseas circulation of existing shares.

Qi Menglin, Managing Partner of Huashang Law Firm, said in an interview with Securities Daily reporter that since the Record-Filing New Rules were implemented on March 31, 2023, the record-filing work for overseas listings by domestic enterprises has generally run smoothly and in an orderly manner. The record-filing system has become a stable bridge connecting domestic enterprises with global capital markets.

Since the Record-Filing New Rules were put into effect, the overall trend has shown “gradually shortened timelines and normalized record-filing.” Since the second half of 2025, the record-filing speed has accelerated significantly, and most enterprises complete the record-filing within 2 to 4 months.

Looking even further ahead, since 2026 there have been some cases of rapid approval of record-filing. For example, from the CSRC’s receipt of record-filing documents from Shenghong Technology (Huizhou) Co., Ltd. to the completion of record-filing took only 4 days, indicating that mature projects have entered a fast-track channel. In addition, among record-filing matters completed in 2026, more than half were completed within 30 days after receipt, with no records of supplementary materials.

In Qi Menglin’s view, the length of time for record-filing is affected by multiple factors, including the company’s own situation and whether materials are prepared sufficiently, as well as the depth and breadth of regulatory review. As practice deepens, regulatory review has shown a trend toward “penetrating review” and “substantive review.” At the same time, tightened scrutiny in reviews—such as due to adjustments in policies, updates to laws and regulations, and cybersecurity requirements—can also affect the record-filing timeline.

Taking listings in Hong Kong stocks as an example, mainland enterprises are moving to list in Hong Kong, including processes such as waiting to obtain record-filing notices, submitting IPO applications, and passing hearings. A person from a Hong Kong stock investment bank told the reporter that the time invested by enterprises across various preparation stages has objectively played a role in “supply adjustment.” This buffering in terms of cadence prevents the situation of a concentrated surge of new listings when market enthusiasm is high; instead, it helps improve control over the quality of listing projects and is beneficial for their subsequent market performance, thereby keeping the Hong Kong stock market continuously active.

Regulation focuses on compliance bottom lines

According to the Record-Filing New Rules, domestic enterprises conducting overseas issuance and listings should file with the CSRC, and submit relevant materials such as a record-filing report and legal opinion letters, to truthfully, accurately, and completely explain matters including shareholders’ information.

Data from the CSRC website show that as of March 31, a total of 129 issues of publicly released requirements for supplementary materials regarding overseas issuance and listing record-filing have been posted. For each issue, companies that must provide supplementary materials requirements are required to issue the supplementary materials requirements within that week. From practice, regulatory authorities’ requirements for companies to provide supplementary materials are highly concentrated and systematic. The core focuses on the clear and transparent level of the entire chain of overseas issuance and listing by the company, as well as the legality and compliance.

Qi Menglin believes that the regulatory focus on supplementary materials centers on such areas as the substantive compliance of a company’s business scope, tax compliance in cross-border restructurings, penetrating disclosure of shareholder structures such as family trusts, and clear disclosure of the business model and data security.

When submitting supplementary documents, enterprises should return to the essence of the business, provide clear and comprehensive explanations, and avoid regulatory misunderstandings caused by stacking technical terms.

Continuation of the “A+H” listing trend

In terms of listing destinations, the destinations for domestic enterprises to list overseas are highly concentrated. The Hong Kong market remains the first choice, with high industry concentration and primarily technology innovation enterprises. The applicant companies are mainly concentrated in technology innovation fields such as healthcare and information technology. At the same time, companies in areas including biotech, semiconductors, and internet services are also relatively active. Some companies choose the Nasdaq Stock Market as well, mainly smaller and mid-sized technology or consumer goods enterprises.

Further on, the “A+H” listing trend continues. Since the Record-Filing New Rules were implemented, 37 A-share companies have been listed in Hong Kong. Just this year alone, 15 A-share companies have been listed in Hong Kong. In 2024 and 2025, there were 3 and 19 A-share companies, respectively, that landed on Hong Kong stocks.

With the rise of the “first A, then H” model, industry leading companies with market values of one trillion Hong Kong dollars lead the way. By introducing international long-term funds, they have become flagship projects in Hong Kong stocks. At the same time, more A-share companies with smaller to mid market capitalizations are also planning to list in Hong Kong. In this regard, Wang Yajun, Head of Equity Capital Markets at Goldman Sachs Asia (excluding Japan), said that before small and mid market-cap companies decide to list in Hong Kong, they need to clarify the core purpose of listing. If it is to obtain the capability for continuous financing, and if H-share liquidity is insufficient or the market cap is smaller, the scale of subsequent refinancing for such companies will also be constrained.