Optimizing the cybersecurity review system for Chinese enterprises’ overseas listings

The cybersecurity review regime for overseas listing is a piece of emergency legislation promoted by the DIDI Incident against the background of increasing tension of international securities regulation and increasingly frequent data transborder flow activities. With the constant change of the institutional environment and legislative background, the defects it exposed are increasingly obvious. Vague concept interpretations, loopholes in risk regulations, superfluous system designs and other problems not only give rise to a heavy burden of market compliance, but also cause a high consumption of regulatory resources. The cybersecurity review regime for overseas listings requires systematic restructuring and innovation. It is necessary to take into account relevant extraterritorial institutional experiences, clarify the core positioning of the system, coordinate the relationship between the system and other national security review systems such as data security review, strengthen the connection between the system and the securities regulation system in overseas listing, reduce regulatory overlaps, improve regulatory efficiency, reduce compliance costs, and finally foster the coordinated integration of national security and market efficiency.