CSRC Consultation on Administrative Measures for Registration of Securities Offerings

We refer to the China Securities Regulatory Commission's (CSRC) invitation to comment on the draft Decision on Amending the Administrative Measures for the Registration of Securities Offerings by Listed Companies and its related supporting rules (the Draft Rules) and welcome the opportunity to provide feedback. We commend CSRC's initiative to enhance the competitiveness, inclusiveness and adaptability of the capital market while reinforcing safeguards for minority shareholders.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with USD 2.11 trillion (CNY 14.76 trillion) at 31 December 2025 invested across 68 countries, of which approximately USD 53.94 billion (CNY 377.36 billion) was invested in the shares of 638 Chinese companies.

As an investor with around 70% of our holdings in listed equity, we depend on thriving public markets that foster long-term value creation. Refinancing rules directly shape how capital is raised, priced and diluted, and therefore how fairly minority shareholders are treated relative to controlling shareholders and other insiders. We welcome the Draft Rules' improvements to pricing fairness, voting safeguards and use-of-proceeds discipline, and suggest a few considerations below.

Please find our responses to selected articles in the annex, grounded in our Global Voting Guidelines. We shared some of these views during the CSRC consultation on the Regulations on the Supervision and Administration of Listed Companies.[1] We thank you for considering our perspective and remain available to discuss any of these views.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                     

Jeanne Stampe
Lead Policy Advisor

[1] NBIM (January 2026) Response to CSRC Consultation on the Regulations on the Supervision and Administration of Listed Companies