IPO News | SUNMI Technology plans to list Hong Kong stocks, China Securities Regulatory Commission requests additional explanation of early A-share declarations and withdrawals

The Zhitong Finance App learned that on September 5, the China Securities Regulatory Commission announced the “Requirements for Supplementary Materials for Overseas Issuance and Listing (August 29, 2025 to September 4, 2025)”, and the International Department of the Securities Regulatory Commission issued supplementary material requirements for 12 companies. Among them, Sunmi Technology was requested to provide additional explanations on matters such as the early A-share declarations and withdrawals. According to reports, on June 25, 2025, Shangmi Technology submitted a listing application to the Hong Kong Stock Exchange, with Deutsche Bank, CITIC Securities, and Agricultural Bank International as co-sponsors.

The Securities Regulatory Commission requested additional explanations from Shangmi Technology on the following matters, and requested lawyers to check and issue clear legal opinions:

1. The scope of business of the Company and its subsidiaries involves Class II value-added telecommunications services and holds value-added telecom business licenses. Please explain in detail the reasons why business operations do not involve areas where foreign investment is prohibited or restricted in accordance with the relevant policies and the business scope of the company and its subsidiaries, and issue a clear conclusion on whether it complies with the “Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)” before and after this issuance and listing.

2. Request the company (1) to explain the specific functions and application scenarios of the company's main products and services based on the top five customers and their business types in each year during the reporting period; (2) to provide additional information on the development and operation of websites, apps, applets and other products, the scale of collected and stored user information, data collection and usage, and whether it involves providing personal user information to third parties, personal information protection and data security arrangements or measures before and after listing; (3) explain whether it actually carries out advertising design, agency, advertising production, advertisement publishing and other related businesses and obtained the necessary qualifications and business Whether management complies with the requirements of regulations such as the “Notice on Further Remediation of Internet Advertisements”; (4) Further explain the specific implementation of supervisory procedures such as overseas investment and foreign exchange registration involving overseas subsidiaries, and issue concluding opinions on compliance.

3. Request the company to further explain (1) whether special voting shares or similar arrangements have been retained after the current issuance and the relevant basis for determination; (2) the price and pricing basis for previous capital increases and share transfers, whether actual investment has been paid, whether there has been an equity escrow in historical history, whether the establishment and successive equity changes are legal and compliant; (3) Shareholder Han Tao Consulting's failure to report on the basis of law whether the concentration of operators is an obstacle to the current issuance and listing.

4. The company is requested to further explain the early A-share declarations and withdrawals, whether it plans to continue the A-share listing and specific arrangements, and whether there are any circumstances that have had a significant impact on this issuance and listing.

5. Please provide additional information on whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.

According to the prospectus, Shangmi Technology is the world's leading provider of commercial Internet of Things (BioT) solutions. The company's solutions integrate intelligent hardware, software and data insights to enable many offline business scenarios to achieve digital transformation and improve the efficiency of core business operations processes (such as payment, membership management, order fulfillment, inventory control and employee management).

According to Insight Consulting, in terms of revenue in 2024, the company is currently the world's largest Android BioT solution provider, with a market share of more than 10%. The company has deployed solutions in more than 200 countries and regions, and has the most extensive business network around the world. The number of monthly active smart devices increased from about 3.2 million as of December 31, 2022 to about 4.9 million as of December 31, 2024.