SRSEC Reporting Desk

Phaos Technology (Cayman) Holdings Ltd (POAS) – SEC staff letter

2026-02-19 · Re: (Cayman) Holdings Ltd Form 20-F filed September 18, 2025 · Accession 0000000000-26-001711 · 1 staff comment(s) issued

Company response(s): 2026-03-05

MD&A: Results & Known TrendsIFRS & Foreign Private Issuers

2026-02-19 · (Cayman) Holdings Ltd Form 20-F filed September 18, 2025 · Comment 1 · Statements of Operations, page F-3 Agreed to revise
Staff comment: Please identify for us the business, competitive and economic factors that caused your sales to decline by 91%. Explain the underlying reasons for the reduction in sales orders from your largest customers. This information should also be included under Item 5 of your next Form 20-F. letter →
Company response: We respectfully advise the staff as follows: The Company’s revenue for the years ended April 30, 2025 and 2024 were S$167,707 (approximately US$128,464) and S$1,882,803 (approximately US$1,380,848), respectively, representing a decrease of 91.1%. This reduction in revenue was primarily attributed to a reduction in sales orders from our largest customers due to a change in our business strategy in which we directly interact with our customers. As a result, the Company has expanded its sales channel from selling to our distributors to selling directly to customers, with the price of the products remaining largely unchanged, leading to a decline in revenue where sales to distributors have… response letter →
MD&A: Results & Known TrendsIFRS & Foreign Private Issuers

Full letter on EDGAR → · Filing index · All Phaos Technology (Cayman) Holdings Ltd (POAS) correspondence

MD&A: Results & Known Trends – what to check: Quantify drivers of changes (price vs. volume), discuss known trends and uncertainties, and avoid repeating the financial statements.

IFRS & Foreign Private Issuers – what to check:

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