IPO News | Nanjing leads proposed Hong Kong stock IPO, China Securities Regulatory Commission requests additional explanation on matters such as previous capital increases and share transfer prices and pricing basis

Zhitong Finance App learned that on September 4, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (August 31, 2026 to September 4, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 5 companies. Among them, the Nanjing leader was requested to provide additional explanations on matters such as the price and pricing basis of previous capital increases, equity or share transfers, and whether there are any abnormalities in the share price. According to the Hong Kong Stock Exchange's disclosure on April 22, Nanjing Lingxing Technology Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, with CICC and CITIC Construction Investment International as co-sponsors.

The China Securities Regulatory Commission requested the Nanjing leader to provide additional explanations on the following matters, and ask lawyers to check and issue clear legal opinions:

1. Please provide additional explanation: (1) The price and pricing basis for your company's successive capital increases and equity transfers; whether there is an abnormal share price; whether there is a transfer of benefits; whether there is actual payment of capital; whether there is a situation of failure to fulfill investment obligations, evasion of funding, or flaws in the funding method; (2) whether there is stock escrow in the historical history of your company; (3) Please confirm whether your company's establishment and successive shareholding changes are legal and compliant, and whether your company's principal qualifications and continuation are valid Concluding remarks.

2. Please further explain the pricing basis for the share price of new shareholders within 12 months before submitting the overseas issuance and listing filing application, the reasons and rationality of the difference in capital increase pricing with the same period, and the transferor's income tax payment status in connection with the above equity transfer process, and issue a clear conclusion on whether there is a transfer of benefits.

3. Please further explain the share price and fairness of your company's employee shareholding plan, whether the employee holds the relevant incentive share after leaving the job, whether it complies with the relevant agreements, whether there are disputes or potential disputes, and whether there is a transfer of benefits; and whether the employee shareholding platform has reserved shares or ungranted shares.

4. Please provide additional information on (1) the situation where each online car-hailing operator of your company does not obtain an “online car-hailing transport license” and “online car-hailing driver's license” on the online car-hailing business operation platform, the impact on the business operations of your company and its subsidiaries, and whether it is an obstacle to the current issuance and listing; (2) whether your company and its subsidiaries have completed the filing in accordance with relevant laws and regulations; the impact of uncompleted filing on the business operation of your company and its subsidiaries is a hindrance to this listing; (3) your company and its subsidiaries The scope of business of the company and Whether the actual business involves areas where foreign investment is restricted or prohibited, and whether the foreign shareholding ratio and specific calculation method after the current issuance and “full circulation” will continue to meet the foreign investment entry requirements.

5. Please provide additional information on whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.

According to the prospectus, through the T3 platform, T3 Travel mainly connects passengers, drivers and vehicles to provide a series of intelligent travel services. The company operates a technology-driven platform that integrates AI into travel services to optimize demand forecasting, vehicle scheduling, and resource allocation, or what the company calls the “AI+ mobility” model. This model can improve the level of intelligent scheduling, safety and passenger service. According to Insight Consulting, since T3 Mobility has developed the first hybrid dispatch platform in China that can simultaneously coordinate manned vehicles and Robotaxis, it can also have a first-mover advantage in the trend of shifting to autonomous driving.

As of December 31, 2025, T3 Travel is operating in 194 cities in China, serving more than 234.5 million registered users. In 2025, the department facilitated 797.2 million orders with a total transaction value of RMB 18.9 billion. According to Insight Consulting's data, based on the 2025 order volume, T3 Travel is the third largest smart travel platform in China. According to Insight Consulting, T3 Travel is the fastest profitable large-scale smart travel platform in China. T3 Travel's business is supported by China FAW, Dongfeng Motor Group, Changan Automobile, and leading technology companies such as Tencent and Alibaba.