The Zhitong Finance App learned that recently, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (December 29, 2025 to January 4, 2026)”. The International Department of the China Securities Regulatory Commission issued supplementary material requests for 13 companies. Among them, Hixue.com was requested to provide additional explanations on matters such as equity changes and shareholder conditions. According to the Hong Kong Stock Exchange's disclosure on October 28, Beijing Hixue.com Education Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, with CMB International as the sole sponsor.
The Securities Regulatory Commission requested Hixue.com to provide additional explanations on the following matters, and ask lawyers to check and issue clear legal opinions:
1. Regarding changes in equity and shareholder conditions: (1) Please explain the basis for the pricing of your company's previous capital increases and equity transfers, whether the capital was actually paid, whether there were any cases of failure to fulfill investment obligations, evasion of contributions, or flaws in the funding method; (2) Please explain whether there are any share intermediaries in your company's historical history; (3) Please explain whether there are domestic entities prohibited from holding shares by laws and regulations after the upward penetration of your company's shareholder Tan Ying Investment.
2. Please explain the business scope of your company and its subsidiaries, including the specific circumstances of “value-added telecommunications services; data processing services; data processing and storage support services; advertising design, agency, publishing, production; market research”, whether they have actually carried out related business and specific operating conditions, whether they have obtained the necessary qualifications, whether the scope of business and actual business development involve restricted or prohibited areas of foreign investment, foreign shareholding ratio requirements, and whether they continue to meet the requirements of foreign investment entry policies before and after this listing and “full circulation”.
3. Regarding the standardized operation situation: (1) Please explain the labor, social insurance and housing provident fund compliance of your company and its subsidiaries; (2) Please explain the details and latest developments in pending lawsuits between your company and its subsidiaries, the rectification situation after being administratively punished due to false publicity, and the reasons for not completing housing rental registration and filing procedures; whether the above situation has had a significant adverse impact on daily operations and whether it poses a substantial obstacle to this issuance and listing.
4. Please explain whether your company and its subsidiaries are involved in developing and operating products such as websites, applets, apps, public accounts, etc., and whether they are involved in providing information content to third parties, the types of information content, and information content security protection measures; also explain the scale of collected and stored user information, data collection and use, and personal information protection and data security arrangements or measures before and after listing.
5. 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.
6. Please explain the details of your company's A-share listing guidance filing and filing in the early stages, whether it plans to continue to advance the A-share listing and specific arrangements, and whether there are any circumstances that have had a significant impact on this listing.
According to the prospectus, according to the Frost & Sullivan report, in terms of revenue in 2024, Hixue.com is the fourth largest online vocational competency training service provider in China. According to the same report, in 2024, the company was also the largest online construction vocational competency training service provider and the second largest online emergency safety vocational competency training service provider in China by revenue. The company's products cover the fields of building construction, emergency safety, accounting and economics, law and health care, and tailor training services and solutions for specific requirements in related fields.
At the same time, the company believes that technology is a powerful driving force for the company's business development and deeply empowering users. Specifically, by focusing on the in-depth application of AI technology, the company is committed to turning the platform into a one-stop service platform for career development for workers and a lifelong learning platform covering the learning needs of adults.