Cybersecurity review and new ideas for listing in Hong Kong

On the evening of 30 June 2021(Beijing time), Didi was officially listed on the New York Stock Exchange. Two days after Didi’s listing, the PRC Cybersecurity Review Office published an announcement regarding the launch of cybersecurity review against Didi (the “Review Announcement”), announcing that the review would be conducted according to the National Security Law of the People’s Republic of China (the “National Security Law”), the Cybersecurity Law of the PRC and the Cybersecurity Review Measures which came into effect on 1 June 2020 (“Cybersecurity Review Measures”). The PRC Cybersecurity Review Office also announced that during the cybersecurity review, no new user was allowed to register with the Didi application. On 4 July 2021 and 9 July 2021, Cybersecurity Administration of China (“CAC”) issued two consecutive circulars, announcing that since Didi Chuxing, Didi Enterprise, and 25 other applications (collectively referred to as “Didi Apps”) had severe violations of rules against personal data collection, those Didi Apps were required to be removed from app stores. Subsequently, CAC issued the Cybersecurity Review Measures (Revised Draft for Comment) (the “Revised Draft”) to further clarify the direction for future cybersecurity review. The Revised Draft directly links cybersecurity review with listing in the United States (the “U.S.”) or other jurisdictions. Read more…