IPO News | Smart Exchange plans to list Hong Kong stocks, China Securities Regulatory Commission requests additional explanation on the latest developments in pending lawsuits

The Zhitong Finance App learned that on January 5, the China Securities Regulatory Commission issued the “Supplementary Material Requirements for Overseas Issuance and Listing (December 29, 2025 to January 4, 2026)”. The International Department of the Securities Regulatory Commission issued supplementary material requirements for 13 companies. In the announcement, the Securities Regulatory Commission requested Smart Exchange to provide additional explanations on the details of the pending lawsuits, the latest developments, and the three previous counseling sessions. According to the Hong Kong Stock Exchange's disclosure on October 31, 2025, Smart Intercom Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, with CITIC Securities and CCB International as co-sponsors.

The China Securities Regulatory Commission requested Smart Communications to further explain the following matters, and ask lawyers to check and issue clear legal opinions:

1. Please provide additional explanations: (1) Request the company to issue a special explanation, detailing the specific situation of the AI model in its business, application scenarios, specific functions, etc.; (2) Request the company to issue a special explanation detailing the specific business model of the embedded advertising business carried out by the company, the scale and share of revenue and customer conditions during the reporting period; (3) The business and business scope of the company and its subsidiaries include advertising design, agency; advertising production; advertising production; advertising; design, production, agency and publication of various domestic advertisements; engaging in advertising business; market research; multi-mode enhanced applications of satellite navigation Service system integration; satellite remote sensing application system integration; comprehensive satellite technology application system integration; medical research and experimental development; real estate development; value-added telecommunication services; Internet data services; artificial intelligence public data platforms; data processing and storage support services; big data services; data processing services; satellite remote sensing data processing; data processing, etc., please specify whether they have actually carried out related business and specific operating conditions, and whether the necessary qualifications have been obtained; (4) Please follow the “Guidelines for the Application of Regulatory Rules - Overseas Distribution and Listing Category No. 2” for the company's subsidiaries, Check whether the branch's business and scope of operations involve restricting or prohibiting foreign investment, and ask a lawyer to issue a clear conclusion.

2. Please provide additional information on whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or otherwise flawed.

3. Please provide additional information on the company's three previous counseling and filing procedures, whether it plans to continue promoting the A-share listing and specific arrangements, and whether there are any circumstances that have had a significant impact on this issuance and listing.

4. Please provide additional information on the company's previous capital increases and share transfer prices, the basis for pricing and the reasons for price differences, whether there are any abnormalities in consideration, and issue a concluding opinion on whether the establishment of the company and the successive equity changes are legal and compliant.

5. Please provide additional information on the progress of tax settlement procedures and commercial cancellation procedures for the company's subsidiaries Chongqing Aitong Technology Co., Ltd., Chechao (Shanghai) Intelligent Technology Co., Ltd., and Shijiazhuang Branch of Smart Intercom Technology Co., Ltd.

6. The company is requested to further explain the details and latest developments of the pending lawsuits, whether the relevant circumstances may have a significant adverse impact on the company's future operations, whether they may constitute a material obstacle to this issuance, and whether the relevant pending lawsuits have been fully disclosed.

7. The shareholding plan for the company's employees includes a small number of outsiders. In accordance with the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2” equity structure and control structure verification requirements, additional explanation of the shareholding price, price fairness, and funding source of the relevant personnel, if the share price is the same or similar to that of the employee, it should indicate whether there is a transfer of benefits and issue a clear concluding opinion.

According to the prospectus, Smart Communications is a leading provider of artificial intelligence technology and product space intelligence solutions in China. It has unique technical capabilities in developing high-precision artificial intelligence solutions by combining advanced products and services, with a special focus on the field of urban traffic management.

According to Frost & Sullivan, in terms of 2024 revenue, the company ranked fourth among all spatial intelligence solution providers in the smart transportation industry in China, accounting for 6.6% of the market share. According to the same source, in terms of revenue in 2024, the company ranked first among all spatial intelligent roadside solution providers in the smart transportation industry in China, with a 19.3% market share. The global market for high-precision AI solutions grew from RMB 47.7 billion in 2019 to RMB 225 billion in 2024. The compound annual growth rate from 2019 to 2024 was 36.1%, and is expected to reach RMB 1,433 billion in 2029, with a compound annual growth rate of 42.2% from 2025 to 2029.