Decoding the Q1 IPO "pause wave": Over 20 companies, including Changxin Technology, temporarily "pause" due to financial report updates

Every year at the end of March and the end of September, within the IPO review queues of the SSE and the SZSE, a cluster of situations often emerges in which the review status of proposed listed companies turns to “suspended.” Taking ChangXin Memory Technologies’ (CXMT) IPO review status update on the STAR Market as an example, these adjustments do not mean that a company’s path to listing is being obstructed. Fundamentally, under the registration-based system, they are routine update actions carried out because the financial filing materials have an expiry window. They are also a typical manifestation of the capital market’s continued move toward standardized operations. From multiple angles—including the logic of regulatory rules, the operating characteristics of the industry, and representative company cases—this article will comprehensively analyze the underlying causes of this concentrated phenomenon and its impact on the market.

3, “suspension tide” in September? Rooted in the 6-month validity rule for financial data

At the end of each March and at the end of each September, the A-share IPO market is prone to seeing a concentration of companies with review statuses that become “suspended.” The core trigger for this phenomenon is the hard requirement regarding the validity period of financial data in A-share IPO reviews. Under regulatory rules, the financial statements cited in the prospectus are valid for 6 months. In special circumstances, an extension of up to 3 months can be applied for—an industry-known “6+3” rule.

If a proposed listed company submits for listing using financial data for the full previous year (as of December 31), the validity period of its financial statements ends on June 30 of the following year, and can be extended to September 30 of the following year upon application; if it submits using data for the first half of the current year (as of June 30), the validity period ends on December 31 of the current year, and can be extended to March 31 of the following year upon application.

When a company’s financial data is approaching the end of its validity period, but the listing review process has not yet been completed, it must hit the “pause” button and supplement disclosures with the latest audited financial statements. Under this regulatory requirement, compliant operations of this kind make the end of March and the end of September high-frequency periods for the “suspension tide” in IPOs. In essence, under the registration-based system, this is a procedural “technical pause” driven by the timeliness of information disclosure, with no direct linkage to the company’s operating situation or shifts in review policies.

IPO “suspension” versus “termination”: the difference is one word—but the outcome is worlds apart

Within the A-share IPO review framework, although “suspended” and “terminated” differ by only one character, they have a fundamental distinction and represent different directions in a company’s path toward listing.

“Termination” means the complete end of a company’s listing application. Either the company withdraws its listing application on its own, or the regulator rejects the application according to law. The listing process is declared terminated. If the company later wants to file again for listing, it must go through the full review process anew.

By contrast, “suspension” is the “pause button” during the IPO review process, not the end of the listing process. The most common triggering reason is that the financial materials cited in the prospectus fall outside the statutory validity period. This type of review suspension caused by expired financial materials is defined by the investment banking community as “technical suspension.” When a company enters a new fiscal year, the old financial data can no longer fully and accurately reflect its latest operating status. Regulators require the company to supplement disclosures with an updated audited report, and this process naturally leads to a temporary halt in the review.

After the company completes supplementation and updating of the latest financial materials and resubmits them, the exchange will promptly resume the review process. Therefore, these changes in review status are part of normal, routine compliance operations in the capital market, laying a foundation for the company to continue advancing toward listing. Looking at past cases, “suspension” is not a negative signal—in fact, it confirms that the company has entered a substantive review stage closely aligned with regulatory requirements. Completing the financial statement update through “technical suspension” is a necessary step for a company to demonstrate its true operating profile to the market.

Industry norm: the usual “data update pause” for listing by major players

Looking back at the listing journey of A-share hard-tech giants, review suspensions triggered by updating financial reports have long been the norm in the industry. Taking Semiconductor Manufacturing International Corporation (SMIC) as an example, during its return-to-A process, it faced concentrated needs for audit updates. For large enterprises with global operations and complex equity structures, financial information disclosure must take into account different accounting standards and regulatory requirements, and the workload for auditing and verification grows at a geometric rate. Rolling updates of financial materials are not only a regulatory requirement, but also a manifestation of the company’s rigorous compliance capabilities.

Similar cases are not uncommon in IPO projects worth hundreds of billions or even a thousand billions. For example, agricultural technology giant Syngenta Group (ChemChina / Syngenta) and leading auto chip company BYD Semiconductor have also seen review suspensions triggered by expired financial materials. These companies’ suspended status is not a sign that the review is being blocked; it is the result of the natural intersection between regulatory process timelines and a company’s development timeline—a routine part of a company’s process of advancing toward listing.

From historical data, once companies complete supplementation and updates of their latest audited reports, the review process often resumes relatively quickly. The vast majority of companies can complete material updates and resume review within 1–2 months. Some companies can even finish the review process within five business days after receiving the updated materials, and the listing process is not affected as a result.

The special nature of the hard-tech track: why does semiconductor project review workload become so large?

For companies with high technical barriers and large business scale, the complexity of annual audits far exceeds that of ordinary industries. The semiconductor industry is a typical example. Taking ChangXin Memory Technologies as an example, it adopts the IDM (integrated design and manufacturing) model, with business coverage across all phases of semiconductor design and manufacturing. Its business complexity is significantly higher than that of Fabless companies that only engage in chip design.

As one of the largest and most technologically advanced DRAM research, design, and manufacturing integrated enterprises in China, ChangXin Memory Technologies has three 12-inch wafer fabs in Hefei and Beijing, with annual output value exceeding 73.64B RMB. Its customers include industry leaders such as Alibaba Cloud, Tencent, Xiaomi, and OPPO. The challenges in its audit work lie not only in the verification of conventional financial data, but more so in its unique business model and extensive industrial ecosystem. It needs to complete massive fixed-asset inventory, precisely allocate complex R&D expenses, handle global patent license accounting, and conduct multi-dimensional reconciliation of customer transactions. These high-difficulty matters substantially increase the intensity and duration of the audit work.

In addition, ChangXin Memory Technologies is also the first company to implement a pilot of the SSE’s “preliminary inquiry system,” and it has completed two rounds of preliminary inquiries. For such industry leaders with prominent standing and large financial scale, using sufficient time to complete high-quality annual report audits is a necessary compliance action to ensure disclosure quality and to be accountable to investors, and it also reflects the regulator’s rigor and professionalism in reviewing hard-tech enterprises.

Regular updates of financial data: a hard disclosure requirement under the registration-based system

As the registration-based system is implemented more deeply in China’s A-share market, market understanding of the “suspended” IPO status is gradually becoming more rational. These rule constraints based on the validity period of financial information are not only a reflection of the rigidity of the regulatory system, but also a sign that capital markets are improving their compliance level and that the information disclosure framework is becoming increasingly mature.

Stage-by-stage changes in IPO review status are, in essence, the regulator’s core measure to ensure that the operating data of listing companies are authentic, timely, and transparent. Each time financial materials are updated and each time the review process is temporarily suspended, it represents the regulator scrutinizing compliance at multiple layers for proposed listed companies. This drives the capital market to develop in a more standardized and mature direction.

With the rolling update of annual report materials, the operating resilience and growth potential of high-quality companies will be truly demonstrated across a more complete financial period. This process helps investors evaluate company value more comprehensively and also builds the information disclosure foundation for high-quality development in the capital market.

A storage super cycle is on the way: industry opportunities for ChangXin Memory Technologies’ listing

From an industry perspective, the progress of ChangXin Memory Technologies in pushing forward its STAR Market listing is not only a critical step for the company itself toward the capital market. It is also an important showcase of China’s semiconductor industry—especially DRAM storage chips—achieving self-reliance and controllability, as well as a market value reappraisal of domestically developed core storage technologies.

According to Omdia statistics, measured by production capacity scale and shipment volume, ChangXin Memory Technologies currently ranks first in China’s DRAM sector and is also the world’s fourth-largest DRAM supplier. From the prospectus materials already disclosed, it is not hard to see that the company’s characteristics of high R&D intensity and high growth are very prominent, closely matching the STAR Market’s positioning focused on hard-core technology. From 2022 to the first half of 2025, the company’s cumulative R&D spending exceeded 18.8 billion RMB, with its R&D spending ratio significantly above the industry average. Its patent portfolio layout is also in the top tier of the industry. Supported by sustained high-intensity R&D, the company has completed its layout of the full range of mainstream memory products, from DDR4 to DDR5 and LPDDR5/5X, among others. From 2022 to September 2025, the company’s total operating revenue was 73.636 billion RMB. From 2022 to 2024, the CAGR of revenue from its main business reached 72.04%.

At present, AI computing demand is driving the global storage industry into a new round of super cycle, bringing an important development window for the industry. Omdia forecasts that the global DRAM market size will grow from US$97.6 billion in 2024 to US$204.5 billion in 2029, with a CAGR of 15.93%. As a domestic DRAM leader and a core enterprise in the industrial chain, ChangXin Memory Technologies’ successful listing is expected to form a significant benchmark effect and a driving role. It can not only effectively boost confidence across the entire industrial chain and promote coordinated development across upstream and downstream segments such as chip design, semiconductor equipment, and key materials, but it will also inject key momentum into China’s integrated circuit industry to achieve high-quality development.