On December 24, 2021, the China Securities Regulatory Commission ("CSRC") released the Administrative Provisions of the State Council Regarding the Overseas Issuance and Listing of Securities by Domestic Enterprises (the "Administrative Provisions") and the Measures for the Overseas Issuance of Securities and Listing Record-Filings by Domestic Enterprises (Draft for Comments) (the "Filing Measures"), both of which have a comment period that expires on January 23, 2022. The Administrative Provisions and Filing Measures regulate the system, filing management, and other related rules in respect of the direct or indirect overseas issuance of listed and traded securities by "domestic enterprises". As analyzed below, the Administrative Provisions and Filing Measures apply to PRC enterprises with Cayman parent entities and /or variable interest entity structures.