Hong Kong IPO disclosure precedents · 45 companies, 68 items
lease agreements not registered/filed; lessor lacks title or consent to sublet; leased property use not conforming to planned use; leasing allocated or collective land; relocation risk
Compliance matters are read from filings since 24 August 2026.
As of the Latest Practicable Date, registration procedures for nine leased properties had not been completed.
Risk Factors · p. 45
Our PRC legal advisor has confirmed that the lack of registration does not affect the validity or enforceability of these agreements, although fines ranging from RMB1,000 to RMB10,000 per unregistered lease may apply.
Risk Factors · p. 45
As of the Latest Practicable Date, we have not completed the lease registration procedures for nine leased properties in China.
During the Track Record Period and up to the Latest Practicable Date, we have not received any notices or administrative penalty decisions from the relevant authorities requiring us to complete lease registration filings for certain leased properties.
Business · p. 183
Our PRC Legal Advisor has advised that the absence of lease registration filings does not affect the validity of the lease agreements and will not have a material adverse impact on the overall business of the Company.
As of the Latest Practicable Date, the registration of 35 of our lease agreements in China with the relevant authorities had not been completed.
Risk Factors · p. 41
As of the Latest Practicable Date, we had not filed the lease agreements for 35 properties we leased in China with the local housing administration authorities as required under PRC laws and regulations.
Business · p. 175
As advised by our PRC Legal Advisor, the absence of registration will not affect the validity of the lease agreements.
In addition, the lessors of 13 of our leased properties in China have not provided ownership certificates or other similar proof of their right to lease the relevant properties to us or the consents to the leases required under applicable PRC laws and regulations.
Risk Factors · p. 41
As of the Latest Practicable Date, the lessors of 13 of the 45 properties we leased in China, with an aggregate GFA of approximately 1,944.9 sq.m., had not provided us with the title certificates or other evidence of title of the relevant properties.
Business · p. 176
The lessors of eight of the 13 properties have confirmed in writing that they will indemnify us for any loss we may suffer if we cannot use the leased properties due to any issue relating to the title or permitted use of the properties.
As of the Latest Practicable Date, two of our leased properties, with an aggregate GFA of approximately 286 sq.m. accounting for less than 1% of the total GFA of our properties in use and used for our staff accommodation, are situated on allocated land and the lease of such properties had not been approved by the competent authorities as required under applicable PRC laws and regulations.
Business · p. 175
As advised by our PRC Legal Advisor, if the competent authorities determine that the relevant leases are void, we would not be subject to any administrative penalties with respect to these properties, but our lease may be affected, and, as a result, we may be required to vacate the premises, in which case we would be entitled to request the return of prepaid rent.
As of the Latest Practicable Date, the lease agreements of six of our leased properties for business operations in China had not been registered with the relevant PRC government authorities.
Risk Factors · p. 56
As advised by our PRC Legal Adviser, the lack of registration does not affect the validity and enforceability of the lease agreements, and we may be subject to fines from RMB1,000 to RMB10,000 for each such lease agreement for failure to register and to rectify within the prescribed time period after receiving notices from the relevant PRC government authorities.
Business · p. 198
Two of these lease agreements are expected to complete the lease registrations by the end of 2026.
As of the Latest Practicable Date, the actual land use of one of our leased properties for business operations was office, which is inconsistent with its approved land use as specified in its land use right certificate of industrial land.
Business · p. 198
As advised by our PRC Legal Adviser, under relevant PRC laws and regulations, it is the lessor (not the tenants) may be ordered to make rectification within a prescribed time limit, and if there are illegal gains, a fine of one to three times the illegal gains capped at RMB30,000 may be imposed on the lessor.
Business · p. 199
In addition, as of the Latest Practicable Date, one of our leased properties currently used for office purposes is legally designated as industrial land in its land use right certificate.
As of the Latest Practicable Date, our four lease agreements for properties in China had not been registered and filed with the relevant PRC authorities as required under applicable PRC laws and regulations.
Business · p. 163
Accordingly, our PRC Legal Advisor is of the view that our failure to register and file the lease agreements for our leased properties will not have a material adverse impact on our production and operations.
Business · p. 164
As of the Latest Practicable Date, our four lease agreements had not been registered and filed with the relevant PRC authorities as required under applicable PRC laws and regulations.
As of the Latest Practicable Date, we had not completed the registration for three lease agreements relating to our leased properties in the PRC.
Business · p. 181
As advised by our PRC Legal Advisor, the lack of registration of the lease agreements does not affect the validity of such lease agreements, nor materially and adversely affect the operations of our Company and the Group.
As of the Latest Practicable Date, certain of our leased properties had title defects, including (i) one leased property with a gross floor area of 700 sq.m. located on collective construction land for which the requisite construction approval procedures had not been completed and no confirmation had been obtained from the competent land administrative authority in respect of the sublease of the collective construction land use right, and no real property ownership certificate had been obtained, (ii) one leased property with a gross floor area of 1,100 sq.m. for which the lessor had not obtained real property ownership certificates, and (iii) one leased property with a gross floor area of 142,225 sq.m. developed under a build-lease-repurchase arrangement for which real property ownership certificates remained pending.
As of the Latest Practicable Date three of our leased properties had title defects because the relevant lessor had not provided with us valid title certifications or relevant authorization documents evidencing the right to lease the property to us.
Business · p. 181
In addition, we were not provided with a valid title certificate in respect of three of our leased properties.
As of the Latest Practicable Date, certain of our leased properties had title defects, including (i) one leased property with a gross floor area of 700 sq.m. located on collective construction land for which the requisite construction approval procedures had not been completed and no confirmation had been obtained from the competent land administrative authority in respect of the sublease of the collective construction land use right, and no real property ownership certificate had been obtained, (ii) one leased property with a gross floor area of 1,100 sq.m. for which the lessor had not obtained real property ownership certificates, and (iii) one leased property with a gross floor area of 142,225 sq.m. developed under a build-lease-repurchase arrangement for which real property ownership certificates remained pending.
Business · p. 163
As of the Latest Practicable Date, certain of our leased properties in the PRC had title defects.
Among our leased properties, the actual usage of one leased property was inconsistent with the usage set out in its title certificate or relevant authorization document.
Business · p. 181
As advised by our PRC Legal Advisor, the inconsistent usage may affect our continued us of such premises.
Business · p. 181
Moreover, upon the completion of our new Wuxi facility, which is currently under construction, we expect this issue to be entirely resolved.
As of the Latest Practicable Date, for the 18 properties our Company and our major subsidiaries leased in China, we had not completed lease registration or lease registration modification for any of these properties.
Business · p. 160
As of the Latest Practicable Date, we had not completed the lease registration for certain properties leased by our Company and our major subsidiaries in China with the relevant land and real estate administration authorities.
In addition, as of the Latest Practicable Date, two of our lease agreements had not been registered with the relevant PRC authorities, primarily because certain landlords failed to complete the lease registration.
Business · p. 176
We estimate that the maximum penalty we may be subject to for these unregistered lease agreements will be approximately RMB20,000, which we believe is immaterial.
Business · p. 176
as of the Latest Practicable Date, two of our leases had not been registered and filed with the competent PRC government authorities as required by applicable PRC laws and regulations
As of the Latest Practicable Date, the actual use of two leased properties did not fit the prescribed scope of usage shown on the relevant ownership certificates.
Business · p. 176
administrative penalties may be imposed on the owners if the properties are leased for usage incompatible with the prescribed scope, and our usage of such leased properties with usage defects may be interrupted. However, as a tenant, we are not subject to any penalties in this regard.
Business · p. 176
two of our leased properties were subject to discrepancies between their actual use and the use descriptions reflected in the relevant property certificates.
As of the Latest Practicable Date, six of our leased properties in China had not completed such lease registration procedures with the relevant PRC government authorities.
Risk Factors · p. 56
As advised by our PRC Legal Advisor, failure to complete the registration and filing of lease agreements will not affect the validity of such leases or impede our use of the relevant properties but could result in the imposition of fines up to RMB10,000 for each leased property that is unregistered if we fail to rectify the non-compliance within the time frame prescribed by the relevant authorities.
Business · p. 195
We have not made provisions for potential penalties, given that the risk of significant administrative penalties is considered low and we are actively rectifying such non-registration.
In 2024, our Company entered into a lease agreement with Shaoguan Resources for properties with an aggregate land area of approximately 3,653,806.13 sq.m., for a term from 1 January 2024 to 31 December 2026, at a monthly rent of RMB2.49 million.
Business · p. 145
As at the Latest Practicable Date, Shaoguan Resources had not obtained the approval of the competent authorities for the leasing of the allocated land.
Business · p. 145
Guangdong Rising Holdings, as the holding company of Shaoguan Resources, submitted an application to the Guangdong Provincial Department of Natural Resources on 26 August 2026 for approval of the overall land disposition plan, including conversion by way of capital contribution and authorized operation.
As of the Latest Practicable Date, we had not completed lease registration for the properties we leased in China, with a GFA of approximately 24,847 sq.m., which were mainly used as our offices, R&D centers and production base.
Business · p. 190
As of the Latest Practicable Date, our lease agreements had not been registered, primarily because certain lessors had not completed the registration formalities.