On September 18, the China Securities Regulatory Commission (CSRC) released its supplementary filing requirements for overseas listing filings covering the period from September 14 to September 18, 2026. The regulator's International Department issued additional documentation requests to six companies, including a directive for Guan'an Information to elaborate on matters such as the pricing and valuation rationale for its historical capital increases and equity transfers, as well as any instances of shareholding arrangements in its corporate history.
According to the Hong Kong Stock Exchange disclosure dated May 20, Guan'an Information, officially known as Shanghai Guan'an Information Technology Co., Ltd., has submitted its listing application to the main board of the Hong Kong Stock Exchange, with ICBC International and China International Capital Corporation (Hong Kong) serving as joint sponsors.
The CSRC has requested Guan'an Information to provide supplementary explanations on the following matters, with legal counsel required to conduct verification and issue clear legal opinions. First, the company must explain the pricing and basis for determining share prices in all past capital increases and equity transfers, including whether any subscription prices were abnormal, whether there was any transfer of benefits, whether capital contributions were fully paid, and whether there were any failures to fulfill capital contribution obligations, capital withdrawals, or defects in the method of capital contribution. Additionally, the company must disclose whether any shareholding arrangements existed throughout its history and provide conclusive opinions on the legality and compliance of its establishment and all historical equity changes, as well as its qualifications and ongoing effective existence.
Second, Guan'an Information is required to disclose the pricing basis for shares acquired by new shareholders within the 12 months preceding the submission of its overseas listing filing, the reasons for and reasonableness of any differences compared to contemporaneous capital increase pricing, the income tax payment status of the transferring parties in these equity transfer transactions, and to provide a definitive conclusion on whether any benefit transfers occurred.
Third, the company must update the CSRC on the progress of its state-owned shareholders in completing state-owned share labeling procedures and other state-owned asset management processes, as well as the approvals or internal decision-making procedures undertaken for the "full circulation" of shares.
Fourth, Guan'an Information must explain the reasons behind the shareholding of close relatives of its management team members in the employee shareholding platform, whether any other external individuals are involved, the legality and compliance of these shareholdings, and the potential for benefit transfers. The company must also clarify whether the employee shareholding platform holds any reserved or unallocated shares.
Fifth, the company and its subsidiaries must clarify whether their business scope and actual operations involve areas subject to restrictions or prohibitions on foreign investment. They must also provide details on the foreign ownership percentage and the specific calculation method following the proposed listing and "full circulation," ensuring sustained compliance with foreign investment access requirements.
Sixth, Guan'an Information is asked to disclose whether any shares held by shareholders participating in the proposed "full circulation" are subject to pledges, freezes, or other defects affecting ownership rights.
Based on the prospectus, Guan'an Information is a leading provider of professional intelligent information security solutions in China. According to a Frost & Sullivan report, based on 2025 revenue, the company ranks first among professional security providers offering data security platforms in China, holding a 9.7% market share. It also ranks seventh among professional security providers offering data security services, with a 3.8% market share, and thirteenth among professional security providers offering information security services, with a 1.8% market share.
Guan'an Information is also an early adopter of big data analytics and artificial intelligence technologies in China's information security sector, focusing on data security, network security, and emerging security domains. The company's security solutions are tailored to meet the needs of clients in sectors such as telecommunications, energy and power, and government and public entities.