In addition to drawing on past experiences, this reform highlights three key areas worth noting: facilitating direct financing for businesses, establishing a regulatory approach centered on information disclosure, and strengthening risk management.

• Convenient Direct Financing: Streamline and optimize the current requirements for issuing mainboard listings, establishing broadly uniform issuance criteria applicable across the entire market. Gradually shift from investor-driven assessments in existing guidelines to more rigorous, comprehensive, and precisely tailored information-disclosure requirements, thereby broadening the reach of capital markets. Additionally, refine the issuance and listing review & registration process by implementing an open, transparent, efficient, and user-friendly stock issuance and registration system—ultimately enhancing the efficiency of direct financing.
• Information disclosure as the core: Establish and improve a stock issuance and listing system centered on information disclosure, clearly defining disclosure requirements that are investor-driven, and meticulously implementing the statutory information disclosure obligations of issuers, intermediaries, and other market participants. Strengthen oversight of information disclosure, ramp up penalties for violations, increase the costs of non-compliance, and ensure that issuers take full responsibility while reinforcing the "gatekeeper" role of intermediaries.

• Strengthening risk prevention and control: The registration-based system requires companies to meet the most fundamental criteria for stock issuance and listing, as well as stringent information disclosure requirements. The exchange assumes full responsibility for reviewing both the issuance/listing process and the compliance with information disclosure standards. Meanwhile, the China Securities Regulatory Commission (CSRC) is accelerating its functional transformation by strengthening overall coordination, supervision, and management of the registration review process. This includes aligning review principles and standards across the board, reinforcing oversight of the exchanges, and enhancing comprehensive pre-, during-, and post-event monitoring. Such measures aim to effectively mitigate various risks and ensure that listed companies maintain high-quality standards from the very beginning.

"The Impact of the Comprehensive Registration System on Both Domestic and Overseas Markets"

Song Xiaoming, Partner at Zhonglun Law Firm, Member of Zhonglun Securities Core Committee, and Member of the Executive Committee at the Beijing Head Office

The changes brought about by the comprehensive registration system to the domestic market can be summarized by three key words: "solidification," "simplification," and "strengthening." First, this reform builds upon the adjustments made to the rules three years ago, solidifying them into a more comprehensive regulatory framework and extending the full registration system to the main board. Second, under the comprehensive registration model, the market segments no longer differ significantly in their review criteria—instead, distinctions are now primarily based on factors such as financial metrics and the companies' innovative, science-and-technology-focused attributes. Finally, from an oversight perspective, the process still involves dual reviews conducted by both the China Securities Regulatory Commission (CSRC) and the stock exchanges, with the CSRC entering the review phase at an earlier stage.

The impact of the comprehensive registration system on various types of overseas listing models is primarily evident in: direct overseas listings (such as H-shares), Regulation will be uniformly applied to both direct and indirect listings, with the review criteria remaining essentially unchanged from the original H-share review guidelines. Additionally, the previous pre-approval management system will be replaced by a post- and in-process filing process, streamlining the review procedures even further. Red-chip listing, Previously, the advantage of not requiring domestic approval no longer exists; however, it still offers significant flexibility in areas such as shareholder fund repatriation, holding shares through offshore family trusts, and post-listing lock-up periods. VIE Structure, VIE-structured companies that meet compliance requirements will be subject to filing for overseas listings, enabling them to leverage both global markets and diverse resources to drive growth and expansion. Meanwhile, the actual regulatory stance toward companies operating in sectors restricted or prohibited for foreign investment—and how industry regulators choose to intervene—remains to be seen.

In summary, regarding domestic listings, it is clear that the capital market should serve national strategies by fostering a healthy cycle among "technology, industry, and finance." By supporting national innovation and building modern industrial systems, the capital market aligns with key areas prioritized under national strategies—leveraging market-driven capital to achieve these strategic objectives. As for overseas listings, while growth remains essential, ensuring security is equally critical. From a security perspective, industry policies must be carefully aligned, and we must effectively harness both global markets and diverse resources. Under the principles of deregulation, regulation, and service, the focus should remain firmly on compliance and related issues.

"Policy Research Guides Value Investing: Long-Termism Drives Value Creation"

Liao Xiaolong, Executive General Manager of the TMT Industry Group at CITIC Securities Investment Banking Committee, and Sponsor Representative

From a stage perspective, The regulatory hallmark of the comprehensive registration system is a combination of deregulation and oversight—specifically, rigorous quality control at the front end, strengthened information disclosure in the middle stage, and strict punishment of fraudulent activities at the back end. These are also the three red lines for companies going public: first, striving for high quality during the IPO application process to align with the nation’s goals and vision for high-quality development; second, emphasizing the timeliness and accuracy of information disclosure after listing; and third, ensuring that no illegal or non-compliant activities—no matter how minor—are ever crossed.

Driving value creation requires us to focus on every stage of an IPO-bound project’s full lifecycle—starting from the early-stage development, through growth, filing, and finally the issuance phase. Key areas of emphasis include structuring the equity framework, managing financing considerations, designing effective equity incentives, strengthening internal control systems, refining business models, carefully timing the IPO process, and crafting a compelling investment narrative.

During the early stages of a company's startup phase, investment firms should focus on whether the equity structure is stable and whether the company has the ongoing ability to "replenish" or "inject" capital. As the company enters its growth phase, it’s crucial to carefully design employee incentive programs—especially for companies listed on the STAR Market or the ChiNext Board, where the number or proportion of employees receiving incentives can influence regulators' assessment of the company’s value. Additionally, businesses should closely monitor their growth trajectory and internal control issues, proactively standardizing financial practices and refining their business models. Once the company moves into the filing stage, it must clearly articulate its unique industry positioning, business model, and operational details while maintaining a well-managed timeline for the IPO process. At the same time, during the pricing phase, companies should effectively communicate their compelling investment story. Only then can they empower the business, driving further value creation and enhancement.

"Opportunities and Challenges in Equity Investment Under the Comprehensive Registration System"

Wang Wei, Partner at Yuanma Capital

Under the comprehensive registration system, both companies and investors have moved beyond the days when they could expect substantial gains or easy access to capital simply by going public—as was possible in the past. From the perspective of investment firms, Investment management and IPO management for portfolio companies can be planned from two perspectives: managerial and proactive.

Management is evident in comprehensive planning that spans from the early stages of investing in a company all the way to supporting its future IPO, helping businesses transition smoothly from the primary to the secondary market. Due to the more refined positioning of each sector under the comprehensive registration system and the increasingly stringent profitability requirements from both domestic and international markets, investment institutions need to adopt a more proactive and strategic approach to management from an exit perspective—such as clearly defining the optimal path for portfolio companies to go public in the future, while carefully managing corporate growth and valuation to ensure that post-listing performance aligns seamlessly with the company’s long-term strategic goals.

Proactiveness is evident in areas such as architecture setup and management team training: If you establish a red-chip offshore structure in advance, consider engaging intermediary institutions early on to provide compliance training for the company's management team.

For investment institutions themselves, the key is still to adapt to the market and embrace change.

"Opportunities and Challenges in Equity Investment Under the Comprehensive Registration System"

Chen Wei, Partner at Xingfu Capital

The introduction of the comprehensive registration system has not only optimized the corporate listing approval process, reduced financing costs for businesses, and boosted the efficiency of high-quality companies going public—but it has also placed higher demands and greater challenges on both enterprises and investment institutions.

One of the core aspects of the comprehensive registration system is thorough information disclosure. With the seamless integration of systems between securities firms and the China Securities Regulatory Commission, companies are now required to complete compliant and exhaustive review documents right from the project initiation stage—placing greater accountability on both enterprises and intermediary institutions. On the other hand, these enhanced information disclosure requirements also underscore the capital market's growing commitment to openness, fairness, and transparency.

For investment institutions, When investing in a company, it’s essential to incorporate a compliance perspective. Engage professional accounting firms and brokerage institutions to conduct early-stage diagnostics, helping you clearly identify the gaps on your path to an IPO as soon as possible. Therefore, To better support companies in their growth, development, and eventual public listing, investment firms need to establish a diversified, comprehensive collaboration ecosystem and actively mobilize resources. This includes forging all-around partnerships with accounting firms, law firms, and securities institutions, empowering businesses at every stage of their journey.