Written by: Liang Yu
Editor: Zhao Yidan
In February 2026, Chinese regulators clearly outlined the future path for Real-World Assets ( RWAs ) and Virtual Assets: comprehensive and strict regulation domestically, while encouraging compliant operations overseas. This clear signal of "openness" and "prohibition" has pointed the way for the entire industry.
On February 6, the China Securities Regulatory Commission (CSRC) issued the "Regulatory Guidelines on the Issuance of Asset-Backed Securities Tokens Overseas by Domestic Assets," establishing for the first time a clear filing framework for the issuance of RWA by domestic assets overseas. The following day, eight departments, including the People's Bank of China, jointly issued a document strictly prohibiting the issuance of any unapproved offshore RMB stablecoins. This series of measures established the core principle that "physical assets can be legally transferred overseas, but the bottom line of monetary sovereignty cannot be touched."
Once domestic assets receive the necessary approvals for compliant overseas listing, where will they go? Currently, among institutions overseas that provide a full-chain service encompassing compliant listing, custody, and trading, the Hong Kong-licensed Virtual Asset Trading Platform (VATP) stands out as a key option with distinct advantages. While licensed platforms in Singapore and other locations also offer similar services, Hong Kong's unique advantages in terms of traded asset classes (tokenized securities) and policy alignment make it irreplaceable. Unlike traditional Type 1 licenses that only allow distribution, VATP serves as a crucial hub connecting compliant assets with global investors. Even more transformative is the upcoming approval for margin trading by Hong Kong VATP. This means RWA will be fully integrated into the efficient trading logic of traditional finance, with its capital leverage efficiency far exceeding that of DeFi models that require full upfront funding.
China's new regulations are working in tandem with Hong Kong's unique market advantages. The mainland has established secure "factory standards," while Hong Kong, with its globally unique institutional advantages, is poised to upgrade into an "international trading market" that combines depth and efficiency. A new chapter in RWA development, driven by policy and focused on Hong Kong, has begun.
I. The Formal Establishment of the RWA Regulatory Framework in China
After months of market speculation and window guidance, the issuance of RWAs by Chinese domestic assets overseas has finally gained a clear legal status. On February 6, 2026, the China Securities Regulatory Commission (CSRC) issued Announcement No. 1 of 2026, marking the formal establishment of the regulatory framework in this area.
This document, titled "Regulatory Guidelines on the Issuance of Asset-Backed Securities Tokens Overseas by Domestic Assets," is the first official definition of RWA (Responsible Asset-Backed Securities). According to the guidelines , such activities refer to "activities that issue tokenized equity certificates overseas using cryptographic technology and distributed ledger or similar technologies, with cash flow generated from domestic assets or related asset rights as repayment support."
The core principle of the regulatory authorities is "same business, same risk, same rules." This means that tokenized securities are not exempt from regulation due to their technological nature, but are instead managed within the existing securities regulatory system.
In terms of the division of responsibilities, the China Securities Regulatory Commission (CSRC) is responsible for regulating equity-based and asset-backed securities-based RWAs, while the National Development and Reform Commission (NDRC) is responsible for regulating foreign debt-based RWAs. As with traditional overseas financing, the repatriation of funds raised overseas is regulated by the State Administration of Foreign Exchange (SAFE) in accordance with the law. This arrangement clearly defines the boundaries of responsibility for each department and provides market participants with a clear compliance path.
II. The Unique Positioning and Functional Evolution of VATP in Hong Kong
With mainland policies clearly defining the basic path of "domestic assets, overseas issuance," Hong Kong's role as a "super connector" becomes crucial. Hong Kong-licensed virtual asset trading platforms are the core hubs for realizing this role.
VATP in Hong Kong has long transcended the role of a mere trading venue. It is currently the only overseas platform capable of simultaneously completing compliant listing, custody, and trading in a "one-stop" manner. In contrast, traditional Type 1 license (securities trading) institutions have limited functions in this area, only able to engage in distribution activities.
Recently, the Hong Kong Securities and Futures Commission (SFC) has been actively considering allowing licensed VATPs to provide secondary trading services for tokenized securities to retail clients. Previously, retail investors could only subscribe to and redeem tokenized products in the primary market, and the lack of liquidity severely constrained market depth. Opening up the secondary market would allow tokenized securities to be freely traded like traditional securities, greatly improving capital efficiency and market attractiveness.
Crucially, Hong Kong has established the clearest and most direct regulatory framework globally for tokenized securities trading on virtual asset trading platforms. Through a dedicated licensing regime, the Hong Kong Securities and Futures Commission (SFC) explicitly allows licensed VATPs to provide such services to retail investors. This, compared to Singapore's approach of covering the market through existing securities licenses and the EU's ongoing implementation of new regulations, gives Hong Kong a unique institutional advantage and first-mover advantage in building a "hybrid asset" trading market. Investors are anticipating seamless trading from Bitcoin to tokenized government bonds within a single account.
III. Complementarity and Synergy: How to Form a Strategic Closed Loop Between the Policies of the Two Regions
If we shift our focus beyond individual documents and examine the recent series of regulatory actions taken by mainland China and Hong Kong, a highly strategic and coordinated picture is emerging. The introduction of the mainland's regulatory framework has addressed the questions of "where do assets come from" and "how to compliantly exit the country."
The filing system established by the guidelines paves a clear compliance track for high-quality domestic assets (such as infrastructure revenue rights, accounts receivable, and lease receivables) to be converted into tradable digital securities overseas through technological means. Meanwhile, the evolution of the Hong Kong market has solved the problems of "where to trade after going overseas" and "how to achieve efficient circulation."
The secondary market liquidity provided by Hong Kong's VATP, the upcoming margin trading mechanism, and the open environment for global investors offer these RWA products going global a mature market for value discovery and efficient circulation. The policies of the two regions, one preceding and one following, together form a complete business loop from the asset side to the trading side.
This synergy not only serves market efficiency but also supports higher-level financial strategies. Against the backdrop of RMB internationalization and financial opening, allowing domestic assets to access global capital markets in a controllable and transparent manner through the RWA (Regional Asset Access Agreement) is a proactive attempt to explore new channels for cross-border financing. Hong Kong, with its common law system, free flow of capital, and international market environment, has become the ideal "testing ground" and "firewall" for the implementation of this strategy.
IV. Market Impact: How will the new regulations change the rules of the game for participants?
The new regulatory landscape defines new action quadrants for different types of market participants. For domestic asset holders (such as corporations and financial institutions), the clear filing process represents an opportunity. They can leverage assets that were previously difficult to activate or had high cross-border financing costs to seek better financing conditions and a broader investor base overseas through RWA structures.
For international capital and professional investors, the RWA market, backed by compliant Chinese underlying assets and traded on a compliant Hong Kong platform, offers a highly attractive alternative investment option. Unlike highly volatile cryptocurrencies, it represents a robust asset backed by real cash flow and enjoys the legal and regulatory protection of Hong Kong.
For fintech companies and service providers, opportunities exist at both ends. In mainland China, the opportunity lies in providing asset providers with regulatory-compliant RWA structure design, technical support, and registration guidance services. In Hong Kong and overseas, the opportunity lies in providing trading platforms, custodians, market makers , and others with technical solutions to enhance the liquidity, security, and user experience of RWA products.
However, challenges and opportunities coexist. Compliance costs are the primary hurdle, and cross-border registration involves multiple departments and complex processes. Technological risks cannot be ignored either; the security, interoperability, and reliability of smart contracts in blockchain systems are the cornerstones of the business. Furthermore, market education remains a significant task, requiring a clear explanation of the structure, risks, and value of RWA products in China to global investors.
V. Clarify the red line: Why is it strictly forbidden to issue stablecoins pegged to the RMB?
Almost simultaneously with the RWA's "Guidelines," an even stricter document was released. The People's Bank of China, together with eight other departments including the National Development and Reform Commission and the China Securities Regulatory Commission, issued the "Notice on Further Preventing and Handling Risks Related to Virtual Currencies."
This notice, which has been dubbed the "strictest ever" in the industry, reiterates that virtual currency-related businesses are illegal financial activities and draws an inviolable red line for monetary sovereignty.
The notice clearly states that "without the consent of relevant departments in accordance with laws and regulations, no entity or individual, whether domestic or foreign, may issue stablecoins pegged to the RMB overseas."
The logic behind this regulation is that stablecoins pegged to fiat currencies effectively perform some of the functions of fiat currencies in circulation, which is a matter of monetary sovereignty and financial stability. This move aims to cut off the issuance channels of "shadow currencies" that could potentially impact the status of the RMB at the source, and prevent them from becoming vehicles for illegal cross-border capital flows.
It is worth noting that the "Notice" also clarified its stance on RWA tokenization activities, distinguishing them from pure cryptocurrency speculation. While the regulations stipulate that conducting related activities and providing intermediary services within the territory constitutes illegal financial activity, it also includes an exception clause for "related business activities conducted with the consent of the competent business authority in accordance with laws and regulations and relying on specific financial infrastructure."
This reflects a differentiated regulatory approach of "blocking illegal activities and allowing compliance," which preserves space for the standardized development of RWA within a strict framework.
VI. Looking to the Future: Three Major Trends in RWA Development
With the implementation of the regulatory framework, the development path of China's related RWA market is becoming increasingly clear. Firstly, asset types will evolve from simple to complex. Initially, asset-backed securities with stable cash flow and clear structures (such as accounts receivable and finance lease receivables) and money market funds will become the mainstream.
As the market matures and regulatory experience accumulates, more complex asset types, such as commercial real estate, infrastructure revenue rights, and even intellectual property, may be gradually included.
Secondly, Hong Kong's trading ecosystem will become increasingly rich and professional. In addition to spot trading, complex financial functions such as margin trading, lending, and derivatives may revolve around RWA products, enhancing the capital efficiency and financial depth of the entire ecosystem. A range of traditional financial market intermediary services, including professional market makers, rating agencies, and auditing firms, will also be introduced, making the market more robust.
Finally, regulatory technology and compliance technology will experience explosive growth. The continuous oversight of on-chain RWA assets, ensuring fund flows comply with registered purposes, and preventing money laundering risks will generate significant demand for RegTech and SupTech. Technology companies capable of providing transparent and automated regulatory solutions will gain a competitive advantage in the next round of financial infrastructure upgrades.
The global RWA (Real-Time WA) wave is unstoppable. According to industry data platforms, by the end of 2025, the total value of global RWA issuances had exceeded US$18 billion, representing an eightfold year-on-year increase. Mainland China and Hong Kong are actively integrating into this transformation through a dual-driven approach of "regulatory framework" and "market practice."
In the future, when investors can easily buy and sell tokenized securities with the underlying asset of a highway revenue right in China on a compliant trading platform in Hong Kong, they may truly understand how these two seemingly independent announcements in February 2026 quietly reshaped the global asset flow map.
Some of the information comes from the following sources:
• Breaking News! Hong Kong Securities and Futures Commission Considers Allowing Retail Investors to Trade Tokenized Securities: Is RWA's "Hong Kong Moment" Coming?
• Eight departments, including the People's Bank of China, have issued a directive prohibiting the issuance of RMB-pegged stablecoins overseas without the consent of relevant authorities.
Caixin: China Announces Regulatory Framework for Allowing Domestic Assets to Issue RWAs Overseas.
