China's securities regulator has raised questions about Lingka Tech's advertising-related business scope and historical shareholding arrangements as the company pursues a Hong Kong initial public offering.

On September 11, the China Securities Regulatory Commission (CSRC) released its supplementary document requirements for overseas listing filings covering September 7-11, 2026. The regulator's International Department issued additional information requests to nine companies, including Lingka Tech, which was asked to clarify whether its advertising design, agency, production, and distribution operations involve embedded advertising or promotional activities.

The company submitted its Hong Kong Stock Exchange main board listing application on June 25, with China International Capital Corporation and SPDB International serving as joint sponsors. The CSRC has requested Lingka Tech to provide detailed explanations on several matters, with legal opinions required from its counsel.

Regarding shareholding changes, the regulator asked the company to explain the reasonableness of pricing for new shareholders who invested within 12 months before the filing, the reasons for price differences among such investments, and whether any abnormal consideration exists. Additionally, the company must disclose whether any shareholding arrangements in its historical development involved nominee holdings, and if so, comply with the verification requirements outlined in Regulatory Guidelines for Overseas Listings Type 2.

On business operations, the CSRC requested clarification on the specific operations of its advertising-related business scope and whether it involves embedded advertising. If applicable, the company must detail revenue scale, proportion, and client information during the reporting period. The regulator also asked about the necessity of including market research, e-commerce, socioeconomic consulting services, and cultural and artistic exchange activities within its business scope.

The company must also supplement its filing report with details on the number of shares to be issued in this offering, the proportion relative to post-offering total share capital, and the specific use of proceeds including domestic and overseas allocation. The regulator asked whether funds would be invested in overseas projects and whether necessary approvals or filings with competent authorities have been completed.

Additional requirements include disclosing whether shares held by shareholders participating in the proposed "full circulation" mechanism are subject to pledges, freezes, or other rights restrictions. The company must also provide comprehensive details on its option incentive plan, including basic terms, incentive recipient profiles, grant and exercise price determination principles, whether reserved interests are established, and whether any benefit transfers exist, along with a compliance opinion.

According to the prospectus, Lingka Tech operates as a leading flexible employment platform in China, providing solutions to enterprises across restaurants, retail, tea and coffee shops, and hotels. Based on CIC Consulting data, the company ranked as China's largest flexible employment platform by 2025 revenue, holding a 17.2% market share.

The company operates the "Linggong Daka" one-stop flexible employment solution and the "Qingtuan She" recruitment platform. As of December 31, 2025, Qingtuan She had nearly 2 million registered corporate clients and approximately 57 million registered users, with the company serving around 440,000 flexible workers.

Financially, the company reported revenues of approximately 463 million yuan, 1.201 billion yuan, and 2.435 billion yuan for 2023, 2024, and 2025 respectively. Net losses during the same periods stood at approximately 110 million yuan, 20.876 million yuan, and 269 million yuan.