On November 14, the China Securities Regulatory Commission (CSRC) released its "Supplementary Material Requirements for Overseas Listing Filings (November 10–14, 2025)," requesting 10 companies to provide additional documentation. Among them, WYBOTICS Co., Ltd. was asked to clarify matters related to its corporate history and progress on state-owned shareholder identification procedures.
According to a September 28 disclosure on the Hong Kong Stock Exchange, Tianjin WYBOTICS Environmental Technology Co., Ltd. submitted a listing application for the main board, with CSC Financial International acting as the sole sponsor. The CSRC has requested WYBOTICS to address the following issues, with legal verification required:
1. **Corporate History**: - Explain the pricing rationale for the first share transfer in April 2025. - Clarify the commercial justification for zero-consideration share compensation in the June 2025 secondary share transfer, as well as pricing discrepancies. - Disclose tax payment status for the involved transfers. - Provide a legal compliance conclusion on all equity changes.
2. **Previous A-Share Listing Attempt**: - Detail the withdrawal of its earlier application to the Shenzhen main board and assess any material impact on the current listing.
3. **Business Operations**: - Explain activities under "new energy equipment sales" and "solar thermal power product sales" in subsidiaries.
4. **State-Owned Shareholder Identification**: - Report progress on compliance procedures.
5. **Fund Use & Overseas Operations**: - Detail approvals for production base-related fundraising. - Disclose overseas operations, subsidiary registrations, and whether fundraising involves foreign investment with proper approvals.
6. **Regulatory Compliance**: - Confirm if domestic subsidiaries meet overseas listing eligibility under Article 8 of relevant regulations.
7. **Employee Share Plan**: - Justify pricing fairness and rule out improper benefits.
8. **Foreign Investment Restrictions**: - Verify if operations fall under prohibited/restricted sectors in the 2024 Negative List.
9. **Share Encumbrances**: - Disclose pledged, frozen, or encumbered shares for "full circulation" participants.
**Company Overview**: WYBOTICS is a rapidly growing global leader in pool-cleaning robotics, specializing in R&D, design, manufacturing, and marketing. According to CIC data, it ranks among the world’s top three and China’s top one suppliers by 2024 shipment volume, pioneering cable-free models. Its portfolio includes 48 major product types as of September 2025, featuring AI-driven technologies like underwater acoustic positioning, 3D mapping, and autonomous navigation for efficient pool maintenance.