On September 4, China's securities regulator issued supplementary document requests as part of the overseas listing filing process, covering companies that submitted applications between August 31 and September 4.
The CSRC's international department raised specific queries for Nanjing Leading Technology, focusing on the pricing details and valuation basis of its historical capital increases and share transfers, including whether any share subscription prices were abnormal. According to the Hong Kong Stock Exchange disclosure on April 22, Nanjing Leading Technology has filed its listing application for the main board, with CICC and CITIC CLSA serving as joint sponsors.
The regulator is asking Nanjing Leading to clarify several points, with legal opinions required from its counsel. First, the company must explain the pricing and valuation basis for each past capital increase and equity transfer, addressing any anomalies in subscription prices, potential benefit transfers, whether capital contributions were actually paid in, or whether there were failures to fulfill or instances of capital withdrawal, as well as any defects in contribution methods. Additionally, it must confirm whether shareholding arrangements in its historical development involved nominee holdings, provide the rationale for determining that it has no actual controller, and issue a conclusive opinion on the legality of its establishment and historical equity changes, along with verification of its legal status and continuing validity.
Second, the company needs to detail the pricing basis for new shareholder stakes added within the 12 months prior to submitting the filing, explain any differences compared with capital increase pricing during the same period and their reasonableness, and disclose the income tax payments made by transferors in those transactions, while providing a clear conclusion on whether any benefit transfers occurred.
Third, clarification is required on the subscription price and fairness of its employee stock ownership plan, the situation regarding incentive shares held by employees after leaving the company, compliance with relevant agreements, any existing or potential disputes, and whether there are reserved or unallocated shares within the employee shareholding platform.
Fourth, the company must address how ride-hailing operating entities handle situations where vehicles or drivers lack the required certificates, such as the "Ride-Hailing Transport Certificate" or "Ride-Hailing Driver Certificate", and the impact on business operations along with any potential obstacles to the listing. It also needs to verify whether its small and micro passenger car leasing businesses have completed required filings under relevant laws, the operational impact of any incomplete filings, and whether these pose obstacles to the offering. Furthermore, it must clarify whether its business scope and actual operations involve areas restricted or prohibited for foreign investment, how foreign shareholding ratios are calculated after the issue and full circulation, and whether it continues to meet foreign investment access requirements.
Finally, the regulator requests confirmation that shares held by shareholders participating in the proposed "full circulation" arrangement are not subject to pledges, freezes, or other rights defects.
According to the prospectus, T3 Travel connects passengers, drivers, and vehicles through its T3 platform, delivering a range of intelligent mobility services. The company operates a technology-driven platform that integrates AI into mobility to enhance demand forecasting, vehicle dispatch, and resource allocation, a model it describes as "AI + mobility". This approach aims to improve smart scheduling, safety assurance, and service levels for drivers and passengers.
Citing CIC data, T3 Travel developed China's first hybrid dispatch platform capable of coordinating both human-driven vehicles and robotaxis simultaneously, positioning it to leverage advantages during the transition toward autonomous driving. As of December 31, 2025, T3 Travel operated in 194 cities across China, serving over 234.5 million registered users. In 2025, the company facilitated 797.2 million orders, with total transaction value reaching RMB 18.9 billion. Ranked by 2025 order volume, T3 Travel is China's third-largest smart mobility platform, and according to CIC, it is the fastest large-scale smart mobility platform to achieve profitability. The business counts leading technology investors among its backers, including FAW, Dongfeng Motor Group, Changan Automobile, Tencent, and Alibaba.