Exhibit 8.1
List of Subsidiaries and Variable Interest Entities
| Name |
Jurisdiction of Incorporation |
Direct Parent Company of the Subsidiary and its | ||
| Subsidiaries: | ||||
| Beijing Decision Software Technology Co., Ltd. | PRC | Elite Concept Holdings Limited (Hong Kong) | ||
| Beijing Hewstone Technology Co., Ltd. | PRC | Elite Concept Holdings Limited (Hong Kong) | ||
| Beijing Pioneer Technology Co., Ltd. | PRC | Smart Shine International Limited (Hong Kong) | ||
| Beijing Smart Wood Software Technology Co., Ltd. | PRC | Smart Shine International Limited (Hong Kong) | ||
| Elite Concept Holdings Limited | Hong Kong | New Oriental Education & Technology Group Inc. (Cayman Islands) | ||
| Winner Park Limited | Hong Kong | New Oriental Education & Technology Group Inc. (Cayman Islands) | ||
| Smart Shine International Limited | Hong Kong | New Oriental Education & Technology Group Inc. (Cayman Islands) | ||
| East Buy Holding Limited | Cayman | New Oriental Education & Technology Group Inc. (Cayman Islands) | ||
| New Oriental Cultural Tourism Group Inc. | Cayman | New Oriental Education & Technology Group Inc. (Cayman Islands) | ||
| New Oriental Cultural Tourism Group Holding Limited | Hong Kong | New Oriental Cultural Tourism Group Inc. (Cayman Islands) | ||
| New Oriental Xuncheng Technology (HK) Limited | Hong Kong | East Buy Holding Limited (Cayman Islands) | ||
| Beijing Dexin Dongfang Network Technology Co., Ltd. | PRC | New Oriental Xuncheng Technology (HK) Limited (Hong Kong) | ||
| Variable Interest Entities: | ||||
| New Oriental Education & Technology Group Co., Ltd.* | PRC | |||
| Beijing New Oriental Xuncheng Network Technology Co., Ltd. | PRC | |||
| * | New Oriental Education & Technology Group Co., Ltd. had a number of subsidiaries and schools in the PRC as of May 31, 2025, including: |
| • | 71 schools, excluding certain schools that are separate legal entities but have been counted to our learning centers and certain schools that have been counted as the same school in the same city or region from the perspective of our internal management and our kindergartens; and |
| • | 161 wholly owned subsidiaries. |