Zhitong Finance App learned that on October 30, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (October 26, 2026 to October 30, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 5 companies. Among them, Puying Innovation was requested to provide additional explanations on matters such as previous shareholding changes. According to the Hong Kong Stock Exchange's disclosure on June 30, Shenzhen Puying Innovation Technology Co., Ltd. submitted a listing application to the GEM of the Hong Kong Stock Exchange, and Ed Capital is its sole sponsor.
The China Securities Regulatory Commission requested Puying Innovation to further explain the following matters, and ask lawyers to check and issue clear legal opinions:
1. Regarding successive equity changes: (1) The history of your company involved capital cuts, please explain the reason and rationality of the capital reduction, whether the necessary legal procedures and tax payments have been carried out; (2) the price and pricing basis for the previous capital increases and share transfers, whether there is abnormal share price, whether there is a transfer of benefits, whether there is actual payment of capital contributions, and whether there are any situations where funding obligations have not been fulfilled, capital evasion, and funding methods are flawed; (3) issue a clear concluding opinion on whether the successive equity changes are legal and compliant.
2. Please list the names of the proxy holders in the historical history of your company, the ratio of proxy holdings, the start and end time of the proxy holding, and how to cancel the proxy holding, and further explain the reasons for the formation, evolution, legal compliance, whether there are disputes or potential disputes, whether there are disputes or potential disputes, whether there are any transfers of interests, and whether the proxy holder is a prohibited shareholder under laws and regulations in accordance with the relevant provisions of the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2”, taking into account the position of the proxy holder during the interrogation period.
3. Your company has a fixed pollution source sewage registration qualification. Please indicate whether the projects already built, under construction, or proposed are “high energy consumption” and “high emission” projects.
4. Please explain whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.
5. About the business: (1) The calculation basis for your company's market share in the filing materials, further explain your company's industry position and related basis; (2) further explain your company's business model and core competitiveness based on key customers and suppliers, product functions, pricing basis and specific application scenarios, revenue scale and industry position during the reporting period.
6. Please explain: Your company's internal dividend decisions and implementation of procedures such as tax payment during the reporting period, explain the rationality of implementing dividends based on the company's liabilities, cash flow, etc., and the necessity of current listing financing in the case of dividends.
According to the prospectus, Puying Innovation is a leading enterprise-level financial smart printing and document processing equipment manufacturer established in 2015. It is mainly engaged in the design, R&D, production and sales of mission-specific printers, integrated printing and scanning equipment, intelligent self-service devices and terminals, as well as consumables, components and other products. The company's products are mainly used in banking and finance, for the printing and application of passbooks and vouchers. Currently, it has served more than 186 customers, and its products are sold to more than 54 countries and regions.
According to Frost & Sullivan data, in terms of revenue, the company ranked first in the global financial smart printing and scanning equipment market in 2025; based on cumulative shipments from 2016 to 2025, the company's historical installed volume of high-reliability printing and scanning equipment was 748,518 units, accounting for about 4.9% of the total installed capacity of the relevant global market, ranking first in the industry.