YMTC IPO Tutoring Phase One Report Filed; CITIC-CLSA 31-Member Team Unveiled

Chinese memory chip giant Yangtze Memory Technologies Co., Ltd. (YMTC) has taken another step forward in its listing journey. The China Securities Regulatory Commission (CSRC) disclosed the first-phase progress report on the IPO tutoring for YMTC on July 10. The formal unveiling of a 31-member tutoring team from CITIC Securities and China Securities Co., Ltd. signals that China’s only integrated device manufacturer (IDM) with independent 3D NAND flash R&D and production capabilities is accelerating its sprint toward the STAR Market.

The tutoring report shows that YMTC completed its IPO tutoring filing on May 19 of this year, officially initiating the listing tutoring process. The first phase of tutoring covered the period from May 19 to June 30, with CITIC Securities and China Securities Co., Ltd., two leading Chinese securities firms, jointly serving as tutoring institutions. The two firms dispatched a combined total of 31 professionals to form the tutoring working group, conducting comprehensive tutoring through on-site due diligence, organized intensive training sessions, and specialized issue discussions.

Initial Tutoring Phase Focuses on Corporate Governance and Shareholder Penetration Verification

According to the report, the core work of the first tutoring phase centered on two main areas. First, the team continued to advance due diligence, systematically reviewing the company’s corporate governance and standardized operations. The tutoring working group conducted a comprehensive review and verification of YMTC’s corporate governance structure and standardized operations, promptly offering improvement suggestions for identified deficiencies, and urging the company to implement corrective measures and standardization plans to ensure a sound governance structure and effective internal controls.

Second, the team strengthened regulatory study and compliance awareness. The tutoring group arranged and supervised the company’s focused study of laws and regulations, including the Company Law of the People’s Republic of China and the Securities Law of the People’s Republic of China, continuously conveying the latest securities market regulatory requirements and review dynamics. Through intensive training and individual consultations, the team helped the company and its personnel grasp the statutory conditions, review concepts, processes, and related regulatory knowledge for listing.

The report also candidly acknowledged two major challenges in the current tutoring work. On one hand, the tutoring working group needs to further urge YMTC to improve its corporate governance and internal control systems according to listed company standards, collaborating with securities service institutions to continuously identify problems based on comprehensive due diligence results and provide solutions. On the other hand, in accordance with CSRC and exchange regulatory requirements on shareholder information disclosure for initial public offering companies, the workload for verifying shareholder eligibility through penetration is substantial. The tutoring working group will cooperate closely with securities service institutions and communicate fully with company shareholders to continuously advance shareholder penetration verification and implement relevant regulatory requirements.

Next Phase: Rectification and Regulatory Training in Parallel

For the next phase of tutoring work, the report outlined two key priorities. The tutoring working group will continue conducting due diligence and standardized tutoring for YMTC, promptly coordinating discussions between intermediaries and the company on identified issues, researching and determining standardization plans, and urging the company to earnestly implement rectification requirements, continuously improve corporate governance and internal control systems, and enhance standardized operational levels.

Simultaneously, the tutoring group will promptly and continuously convey the latest regulatory normative documents for listed companies to the personnel receiving tutoring, urging them to conduct comprehensive regulatory knowledge study and training, deeply understand laws, regulations, and rules regarding issuance, listing, and standardized operations, become aware of responsibilities and obligations in information disclosure and commitment fulfillment, and establish a sense of integrity, self-discipline, and rule of law for entering the securities market.

IPO Tutoring Timeline Benchmarked Against CXMT

How long will YMTC’s IPO tutoring take? The market naturally benchmarks it against ChangXin Memory Technologies (CXMT), the other half of China’s “Two Changs” in domestic memory.

Public information shows that CXMT’s IPO tutoring took approximately three months. The company signed an agreement with its tutoring institution on July 4, 2025, officially launched tutoring on July 7, and passed the listing tutoring acceptance review in October 2025. According to relevant regulations, the tutoring period should in principle be no less than three months, and CXMT’s tutoring period ended right at this threshold.

CXMT is about to conduct its subscription on July 16, with its STAR Market listing imminent. Based on this timeline, YMTC could complete its tutoring acceptance review by mid-to-late August at the earliest. However, considering the substantial workload of YMTC’s shareholder penetration verification, the actual tutoring cycle still faces some uncertainty.

Equity Structure and Industry Chain Layout

YMTC was established in December 2016, headquartered in Wuhan, Hubei province. It is a memory IDM enterprise integrating chip design, manufacturing, packaging and testing, and system solution products. The company has a registered capital of 17.82 billion yuan (approximately $2.6 billion), with no controlling shareholder. Its largest shareholder, Hubei Changsheng Development Co., Ltd., directly holds a 26.5442% stake.

YMTC’s wholly-owned subsidiary provides global partners with 3D NAND flash wafers and particles, embedded memory chips, and consumer and enterprise-grade solid-state drives, widely used in mobile communications, consumer digital products, computers, servers, and data centers.

In September 2025, YMTC and Hubei Changsheng Phase III jointly invested 20.72 billion yuan (approximately $3.1 billion) to establish Changcun Phase III (Wuhan) Integrated Circuit Co., Ltd. Construction of this project is currently accelerating and is expected to significantly boost the company’s 3D NAND flash chip production capacity, further solidifying YMTC’s manufacturing advantages.

Notably, since June of this year, significant equity changes have occurred in several subsidiaries under YMTC. On June 17, the Chongqing Municipal Market Supervision Administration publicized a concentration of undertakings filing regarding Wuhan Optics Valley Semiconductor Industry Investment Co., Ltd.’s acquisition of equity in Wuhan Xinxin Semiconductor Manufacturing Co., Ltd. The transaction overview shows that Wuhan Optics Valley Semiconductor Industry Investment, Guangxin Qihang, YMTC, and Wuhan Xinxin signed an agreement, under which Optics Valley Semiconductor Industry Investment and Guangxin Qihang, which it controls, intend to acquire 39% equity in Wuhan Xinxin held by YMTC. Before the transaction, YMTC held 68.19% equity in Wuhan Xinxin, exercising sole control; after the transaction, Optics Valley Semiconductor Industry Investment and its concert parties will directly or indirectly control 47.8846% equity in Wuhan Xinxin, exercising sole control.

Additionally, Yangtze Advanced Memory Industry Innovation Center Co., Ltd. recently underwent business registration changes, with shareholders including Jingce Electronic and PNC Process Systems exiting, raising YMTC’s stake from 39.47% to 100%. The company was established in 2018 with a registered capital of 315 million yuan (approximately $46.6 million), and its business scope covers research, development, design, inspection, testing, manufacturing, and sales of advanced memory technologies and related products.

China’s “Two Changs” Race in the Capital Market

With CXMT about to complete its subscription and YMTC’s tutoring work steadily advancing, the competitive landscape for China’s “Two Changs” in the capital market is becoming increasingly clear.

CXMT focuses on the DRAM field, while YMTC specializes in 3D NAND flash. Together, they form the core force for China to achieve self-reliance and control in the memory chip sector. Against the backdrop of a global memory chip market dominated by overseas giants such as Samsung, SK Hynix, and Micron, the successive listings of the “Two Changs” will not only provide more ample financial support for their respective technology R&D and capacity expansion but also further enhance the international competitiveness of China’s memory chip industry.

From a timeline perspective, CXMT currently leads in the IPO process, but YMTC’s pace of catching up has noticeably accelerated. With the formal disclosure of the first-phase tutoring report, YMTC’s listing path is gradually becoming clearer. The market will continue to monitor its subsequent tutoring progress, as well as the final choice of listing venue and fundraising scale.