Author: Lawyer Liu Honglin

Not only partners in the cryptocurrency circle, but financial institutions in mainland China have also started to replay the previous craze for stablecoins, frequently paying attention to and interpreting the notification issued jointly by the People's Bank of China and eight departments on February 6 regarding the prevention and disposal of risks associated with virtual currencies, as well as the regulatory guidelines released by the Securities Regulatory Commission regarding the offshore issuance of asset-backed tokens.

In recent days, whether at offline events in Hong Kong or internal policy interpretation meetings organized by several financial institutions with Lawyer Honglin invited to participate, it was found that many focal points of interest were consistent. Thus, we decided to write an article to compile framework perspectives on Document No. 42 and Document No. 1 from the Securities Regulatory Commission, as well as currently observed business details in legal practice and industry operations, for your reference.

From an overall qualitative perspective, my personal opinion as Lawyer Honglin is: the latest regulatory policy is "beneficial, but the benefits are limited."

To understand this judgment, one must first clarify the relationship between Document No. 42 and Document No. 1 from the Securities Regulatory Commission: this is a logic of "principle" plus "exception." The content of Document No. 42 concerning the prevention and disposal of risks related to virtual currencies is the principle and the background; meanwhile, the guidelines from the Securities Regulatory Commission regarding the issuance of asset-backed tokens are a pilot "exception" within this tightly regulated framework.

Looking back at a series of regulatory documents released in China from 2013, 2021 to November 2025, one will find that Document No. 42 does not impose many additional restrictive categories regarding the "breadth" of regulation. However, from our insider perspective, the "depth" of regulation has significantly strengthened compared to before. The document precisely addresses details such as verifying business registration information, specifics about the sale of cryptocurrency mining operations within the country, and the norms for issuing stablecoins pegged to the renminbi. Previously, some areas may have seemed somewhat ambiguous, but now regulatory authorities have a thorough grasp of the operational details of the crypto world in Chinese-speaking regions, including specific business linkages. On this basis, it has not made the environment worse; instead, it has opened a door via the Securities Regulatory Commission’s documents, allowing domestic assets to be issued as asset-backed tokens abroad with the approval of domestic regulatory departments.

Regarding the two terms "real-world asset tokenization (RWA)" and "securities tokenization," many in the industry found this somewhat strange. Document No. 42 discusses RWA, while in the framework of the Securities Regulatory Commission, it has become securities tokenization. In fact, RWA is a higher-level concept. As of today in 2026, the global practice of RWA has mainly evolved into three paths:

The first path leans towards tokenization that resembles securities or financial products, which is the primary area of regulatory oversight by the Securities Regulatory Commission, including attempts to solve secondary market liquidity for assets like US stocks and funds on the blockchain;

The second path is more focused on the sale of goods, membership rights, or user points to promote activity, following an e-commerce logic; if this part does not involve financial fundraising, regulation currently has not provided a clear evaluation.

The third path, uniquely tailored to China, involves companies like Ant Group, Langxin, and Xiexin attempting to package the income rights of domestic new energy assets into fixed-income or investment return distribution products for sale in Hong Kong starting in 2024.

Document No. 1 from the Securities Regulatory Commission officially incorporates products involving "securities" and "credit" attributes into the regulatory framework of mainland government departments. My understanding is that the Securities Regulatory Commission only focuses on the lower-level scenario of securities tokenization within RWA, while other forms of commodity tokenization do not fall within its jurisdiction.

In Document No. 42, there is a detail that many payment companies and financial institutions are particularly concerned about: stablecoins. A document from November 2025 once categorized stablecoins as a form of virtual currency, leading many institutions at the time to believe that the path for domestic enterprises to issue offshore renminbi stablecoins had been blocked. However, the first article and the first paragraph of Document No. 42 clearly state that issuing renminbi-pegged stablecoins without consent is prohibited, which, conversely, means that it is actually permissible with the lawful approval of relevant departments. This essentially represents a benefit for giants like Ant Group and JD.com, who have already laid out their stablecoin markets in Hong Kong.

Currently, there are 36 institutions applying for stablecoin licenses in Hong Kong, and reports suggest that the first batch of licenses may be issued to Standard Chartered or HSBC by the end of March 2026. Why are stablecoins significant? Because true RWA in the future must come with stablecoins, as the core advantage of blockchain lies in its programmability. The ideal scenario is: business data is brought on-chain through IoT chips, making it truly immutable; investor returns are automatically allocated to accounts based on this data via smart contracts. This kind of closed loop of "information flow" and "capital flow" can enable periodic interest distribution akin to BlackRock’s U.S. Treasury product. Without compliant stablecoins participating in value settlement, the financial innovation significance of RWA is halved.

Although policies have released signals, we must be soberly aware of the current practical gaps. The RWA projects emerging from Hong Kong, besides those targeting new energy assets, are often leaning towards agricultural products, non-performing assets, or real estate, where the rights to these underlying assets are often poorly handled during the due diligence stage, which could even be described as "grassroots operations."

In many of the RWA projects linked between Hong Kong and mainland China, most still follow a traditional fund product sales logic combined with blockchain recording functions, where fundraising still proceeds through conventional contract signing and channels for offshore qualified investors, ultimately providing funds to domestic project companies via loans. This approach differs significantly from the ideal RWA envisioned in the Web3 world, where assets can flow freely on the blockchain, and is more about utilizing the concept of blockchain for PR promotion.

The most criticized aspect of the current Hong Kong model is the lack of liquidity in the secondary market. Once assets are sold to qualified investors, there are virtually no circulation venues between retail and qualified investors. To address this pain point, some micro-innovations based on pledging logic have emerged in the industry. For example, investors can pledge their held and non-flowable RWA token shares and issue an anchored non-nominative token on-chain for secondary trading. Although this method can bypass some restrictions, it remains clearly in a regulatory grey area.

The key concern within the industry regarding the "specific financial infrastructure" mentioned in Document No. 42 mainly revolves around three speculation directions. The first is a cross-border payment and settlement system based on digital renminbi 2.0, as we hope for broader application scenarios of digital renminbi abroad. The second is a government-led alliance chain project, such as the "Shanghai Pujiang Digital Chain." The last is a specific public chain with a compliant background, such as Conflux, which has a strong background in Shanghai, or a compliance-focused layer two chain like HashKey Chain.

In summary, although the issuance of Document No. 1 from the Securities Regulatory Commission is a step forward, it may not take exceptionally large strides. The priority principle for projects led by the Securities Regulatory Commission is that stability outweighs all else. For listed company clients wanting to explore RWA, my advice is to "wait a bit longer." We can wait for the first batch of truly compliant cases to emerge, observe their secondary market circulation conditions, compliance costs, and actual financing efficiency before making business evaluations.

After all, the road to Web3 is long; there is no need to rush.

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