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ARTICLE · 01 OCTOBER 2025

Filing-based System For Overseas Listings (III) – Direct Listings

Han Kun Law Offices
Han Kun Law Offices
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Han Kun Law Offices

Han Kun Law Offices

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The direct overseas offering and listing by domestic entities refers to the overseas offering and listing by joint-stock companies registered and incorporated domestically in China (the "Direct Overseas Listings"), which is currently one of the main ways for domestic entities to be listed overseas.

ChinaCorporate/Commercial Law

The direct overseas offering and listing by domestic entities refers to the overseas offering and listing by joint-stock companies registered and incorporated domestically in China (the "Direct Overseas Listings"), which is currently one of the main ways for domestic entities to be listed overseas. Prior to the implementation of the New Filing Rules, the Direct Overseas Listings are subject to the examination and approval by both the CSRC and the overseas securities regulatory authorities. However, under the New Filing Rules, the CSRC changes its administration from approval-based administration to filing-based administration, strengthening its supervision during and after overseas listing, and significantly modifying the original examination and approval mechanism for Direct Overseas Listings. In addition, the New Filing Rules also specify and make breakthroughs with respect to issues highly concerned by the market in the original examination and approval system,

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