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 Overseas (hereinafter referred to as the “Record-filing New Rules”) entered its third year of implementation.

By supporting enterprises in taking advantage of overseas capital markets for standardized development, and by insisting on fully implementing the requirements of the “streamlining administration, delegating power, and optimizing services” reform, permissions-based management has been changed to a record-filing-based management approach. Based on publicly available data released by the CSRC, Securities Daily reporter statistics show that since the Record-filing New Rules were implemented, as of March 31, 2026, a cumulative total of 734 companies have submitted record-filing applications. Of these, 471 companies have received record-filing notification letters (including initial public offerings and “full circulation”), and the record-filing applications of another 263 companies have already been accepted by the CSRC.

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

Efficiency continues to improve

Judging from the entities that have completed filing, consumer companies such as Mieshi Bingcheng Co., Ltd., Chow Tai Fook Jewellery Co., Ltd., Bama Tea Industry Co., Ltd., Shenzhen Baiguoyuan Industrial (Group) Co., Ltd., and many technology enterprises all chose to list in Hong Kong-listed markets.

In terms of filing type, “direct overseas listing + full circulation” runs in parallel. Most companies 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 notification letters for overseas issuance and listing and for “full circulation” of shares that have not been listed in the mainland. For example, Tai Ji Technology (Beijing) Co., Ltd., Shenzhen Ledong Robotics Co., Ltd., Shenzhen Maiketian Biotechnology and Medical Technology Co., Ltd., and others have already submitted their record filings and received CSRC record-filing notification letters, indicating that companies are not only advancing overseas issuance and listing, 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 work of record-filing for overseas listings by domestic enterprises has generally operated in a stable and orderly manner, and the record-filing system has become a stable bridge connecting domestic enterprises with the global capital markets.

Since the Record-filing New Rules took effect, the overall trend has been “gradually shortening processing time and normalizing record-filing.” Since the second half of 2025, the filing speed has increased markedly, and most companies complete filing within 2 to 4 months.

Looking even further, since 2026 there have been some cases of rapid approval of filings. For example, from the CSRC’s receipt of filing documents for Shenghong Technology (Huizhou) Co., Ltd. to completion of the record-filing took only 4 days, showing that mature projects have entered a fast-track channel. In addition, among filings completed in 2026, more than half of the projects were completed within 30 days after acceptance, 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 enterprises’ own circumstances and whether the materials preparation is sufficiently thorough, as well as the depth and breadth of regulatory review. As practice deepens, regulatory review is showing a trend of “penetrating” and “substantive” assessment. At the same time, tighter scrutiny may also be introduced for issues such as adjustments to policies, updates to laws and regulations, and cybersecurity reviews, which will also affect record-filing timelines.

Taking Hong Kong listings as an example, mainland enterprises are moving to list in Hong Kong, including processes such as waiting to obtain record-filing notification letters, submitting the IPO application filing, and passing the hearing. A Hong Kong equity investment banking professional told the reporter that the time invested by companies in various preparation stages has objectively played a role of “supply adjustment.” This kind of buffer in pacing helps avoid a situation where new shares surge all at once when market heat is high; instead, it helps improve quality control of listing projects, and is beneficial to their subsequent market performance, thereby helping the Hong Kong market remain continuously active.

Regulatory focus on compliance bottom lines

Under the Record-filing New Rules, domestic enterprises that issue and list securities overseas should file with the China Securities Regulatory Commission, and submit relevant materials such as a record-filing report and legal opinion letters, honestly, accurately, and completely explaining matters such as shareholder information.

According to data from the CSRC’s official website, as of March 31, the CSRC has cumulatively issued and disclosed public requirements for supplementary materials for overseas issuance and listing filings for 129 periods. For each period, companies that are required to submit supplementary materials must produce the supplementary materials requirements for that week. From a practical perspective, regulators’ requirements for companies to provide supplementary materials show highly concentrated and systematic focus, with the core revolving around the clear transparency and legal compliance of the full chain of overseas issuance and listing by enterprises.

Qi Menglin believes that the regulatory focus on supplementary materials centers on aspects such as substantive compliance of the enterprise’s business scope, tax compliance of cross-border reorganization, penetrating disclosure of shareholder structures such as family trusts, and clear disclosure of business models and data security, among others. When submitting supplementary documents, enterprises should return to the commercial essence and provide clear and comprehensive explanations, avoiding regulatory misunderstandings caused by stacking up technical terminology.

“A+H” listing trend continues

In terms of listing destinations, domestic enterprises’ destinations for going overseas are highly concentrated; the Hong Kong market remains the first choice, and industry concentration is high, mainly driven by technology innovation enterprises. The applicant companies are mainly concentrated in technology innovation areas such as healthcare and information technology. At the same time, companies in fields such as biotech, semiconductors, and internet services are also relatively active. Some companies also choose the Nasdaq Stock Market, mostly small and medium-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 listed in Hong Kong. Only this year, 15 A-share companies have listed in Hong Kong. In 2024 and 2025, the number of A-share companies that landed in Hong Kong was 3 and 19, respectively.

With the rise of the “first A, then H” model, leading industry players with market values of tens of billions of Hong Kong dollars have taken the lead, introducing international long-term funds, and becoming benchmark projects in Hong Kong equities. Meanwhile, more A-share companies with smaller market caps are also planning to list in Hong Kong. In this regard, Wang Yajun,主管王亚军 of Goldstone Asia (excluding Japan) in charge of stock capital market, said that before small and medium-cap companies decide to list in Hong Kong, they need to be clear about the core purpose of listing. If the goal is to obtain continuous financing capacity, and if the liquidity of H-shares is insufficient and the market capitalization is small, the scale of subsequent refinancing for such companies will also be limited.