Xaircraft Technology has received feedback from the China Securities Regulatory Commission (CSRC) regarding its overseas listing application. Key points raised in the feedback include:

1. **Legality of Equity Changes**: The company must provide a conclusive opinion on whether its establishment and historical equity changes comply with regulations.

2. **Withdrawal of STAR Market Application**: Xaircraft must clarify the details and reasons for withdrawing its previous application for a STAR Market listing, as well as whether it plans to reapply for an A-share listing and any potential impact on its current Hong Kong IPO.

3. **Data Privacy Compliance**: The company needs to disclose its development and operation of apps, mini-programs, and public accounts, including whether it collects and uses personal data, the scale of user information stored, and data usage practices.

4. **AI Model Compliance**: Xaircraft must confirm whether its AI-related technologies or services have completed necessary regulatory filings.

5. **Regulatory Penalties**: The company must explain the specifics of an administrative penalty imposed in August 2023, its rectification measures, and whether this constitutes a material violation affecting the IPO.

6. **Advertising Business**: Xaircraft must detail its advertising-related operations and verify whether it holds required licenses.

7. **Employee Incentive Plans**: The company must disclose its employee stock ownership and equity incentive plans, including compliance checks on external advisors and potential conflicts of interest.

8. **Foreign Investment Restrictions**: Xaircraft must confirm whether its agricultural research and seed businesses involve sectors restricted or prohibited for foreign investment under China’s 2024 Negative List.

9. **Shareholder Lock-ups**: The company must verify whether shares held by "full circulation" participants are pledged, frozen, or encumbered.

Legal opinions on these matters must be provided by counsel.

**IPO Background** On September 25, Guangzhou Xaircraft Technology filed for a Hong Kong IPO, with Huatai International as the sole sponsor. This marks its second IPO attempt after withdrawing a STAR Market application in 2021.

Proceeds will fund agricultural robotics R&D, global sales expansion, a new headquarters, and working capital.

**Financial Concerns** In H1 2025, Xaircraft’s revenue growth slowed sharply to 2.08% YoY, while contract liabilities—a key performance indicator—plummeted 77.64% to RMB 78.985 million. Accounts receivable surged 1,345.55%, and inventory, though down 20.71%, still accounted for 21.33% of current assets.

**Quality and Compliance Issues** The company has faced repeated criticism over product quality and after-sales service, including a 2021 exposé by CCTV. It was fined RMB 54.456 million in 2022 and RMB 10.063 million in 2023. Over the past year, 60 consumer complaints were filed on the 12315 platform.