Filing-based System For Overseas Listing (II) – Indirect Listing

On February 17, 2023, the New Filing Rules was released by the China Securities Regulatory Commission ("CSRC"), which will come into force on March 31, 2023. In the meantime, the Notice of the State Council on Further Strengthening the Administration of Overseas Stock Issuance and Listing (State Council Announcement [1997] No. 21) (the "97 Red Chip Guidelines") will be repealed on the effective date of the New Filing Rules. The New Filing Rules remove the distinction between overseas listings with a large red-chip structure and overseas listings with a small red-chip structure, as well as the distinction between Chinese authorities' regulatory administration over overseas listings with a red-chip structure and over direct overseas listings of Domestic Enterprises (such as H shares). This will unfold a new era of unified filing-based regulatory system for the overseas offerings and listings by Domestic Enterprises (as defined below).