China's new regulations for overseas issuance of RWA come into effect, with beneficiaries emerging: Hong Kong VATP leverages its unique institutional advantages to facilitate asset "going abroad"
Written by: Liang Yu
Edited by: Zhao Yidan
In February 2026, China’s regulators clearly outlined the future path for real-world assets (RWA) and virtual assets: strict domestic regulation and encouraging compliant operations abroad. This clear signal of “opening” and “restricting” has pointed the industry in the right direction.
On February 6, the China Securities Regulatory Commission (CSRC) issued the “Regulatory Guidelines on Overseas Issuance of Asset-Backed Securities Tokens Based on Domestic Assets,” establishing for the first time a clear filing framework for domestic assets issuing RWA overseas. The following day, eight departments including the People’s Bank of China jointly issued a statement strictly prohibiting any unapproved issuance of offshore RMB stablecoins. This combination of measures firmly establishes the core principle that “physical assets can be legally exported, but monetary sovereignty must not be touched.”
Once domestic assets obtain the legal clearance to go abroad, where will they go? Currently, among institutions capable of providing compliant listing, custody, and trading services across the entire chain overseas, licensed virtual asset trading platforms (VATPs) in Hong Kong are a distinctive and highly advantageous option. Singapore and other regions also have licensed platforms offering similar services, but Hong Kong has an irreplaceable advantage in the asset categories (tokenized securities) and policy coordination. Unlike traditional Type 1 licensees limited to distribution, VATPs serve as a crucial hub connecting compliant assets with global investors. More transformative is the upcoming approval for Hong Kong VATPs to offer margin trading, meaning RWAs will be fully integrated into the efficient trading logic of traditional finance, with capital leverage efficiency far exceeding that of DeFi models requiring full pre-funding.
China’s new regulatory measures are forming a powerful synergy with Hong Kong’s unique market functions. Mainland China has established a secure “export standard,” while Hong Kong, leveraging its unparalleled institutional advantages, is preparing to upgrade into a “global trading hub” with both depth and efficiency. A new chapter driven by policy, focusing on RWA development in Hong Kong, has already begun.
- The Formal Establishment of China’s RWA Regulatory Framework
After months of market speculation and guidance, China’s domestic assets issuing RWA abroad have gained clear legal recognition. On February 6, 2026, the CSRC issued Announcement No. 1 of 2026, marking the formal establishment of the regulatory framework in this field.
This document, titled “Regulatory Guidelines on Overseas Issuance of Asset-Backed Securities Tokens Based on Domestic Assets,” officially defines RWA from an official perspective for the first time. According to the guidelines, such activities refer to “using cash flows generated by domestic assets or related rights as repayment support, utilizing encryption technology and distributed ledger or similar technology, to issue tokenized equity certificates overseas.”
The core principle of regulators is “same business, same risk, same rules.” This means that tokenized securities are not exempt from regulation due to their technological form but are managed within the existing securities regulatory system.
In terms of responsibilities, the CSRC oversees equity-type and asset securitization RWAs, while the National Development and Reform Commission (NDRC) is responsible for foreign debt RWAs. As with traditional overseas financing, the foreign exchange authorities regulate the repatriation of funds raised abroad. This clear delineation of responsibilities provides market participants with a transparent compliance pathway.
- The Unique Position and Evolution of Hong Kong VATPs
Once the mainland policy clarified the basic path of “domestic assets, overseas issuance,” Hong Kong’s role as a “super connector” became crucial. The licensed virtual asset trading platform in Hong Kong is the core hub for this role.
Hong Kong VATPs have long transcended being mere trading venues. They are currently the only overseas platform capable of simultaneously providing compliant listing, custody, and trading in a “one-stop” manner. In contrast, traditional Type 1 licensees (securities firms) have limited functions in this area, mainly engaging in distribution.
Recently, Hong Kong’s 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 and redeem tokenized products in the primary market, with liquidity severely constraining market depth. Opening the secondary market will enable tokenized securities to be bought and sold freely like traditional securities, greatly enhancing capital efficiency and market attractiveness.
Most importantly, Hong Kong has established the clearest and most direct regulatory framework worldwide for tokenized securities trading on virtual asset platforms. Through a dedicated licensing regime, the SFC explicitly permits licensed VATPs to serve retail investors in such activities. Compared to Singapore’s approach of covering these activities under existing securities licenses and the EU’s ongoing regulation implementation, Hong Kong’s system offers a unique institutional advantage and first-mover edge in building a “hybrid asset” trading market. Investors are eager to experience seamless trading from Bitcoin to tokenized government bonds within a single account.
- Complementarity and Synergy: How Policies in Both Regions Form a Strategic Loop
Looking beyond individual documents, a highly strategic and coordinated picture is emerging from recent regulatory actions in mainland China and Hong Kong. The mainland’s regulatory framework addresses the questions of “where do assets come from” and “how to comply when going abroad.”
The filing system established by the Guidelines creates a clear compliant pathway for high-quality domestic assets (such as infrastructure revenue rights, receivables, leasing claims) to be transformed into tradable digital securities overseas via technological means. Meanwhile, Hong Kong’s evolving market addresses “where to trade after going abroad” and “how to ensure efficient circulation.”
The liquidity provided by Hong Kong VATPs in secondary markets, the upcoming margin trading mechanisms, and the open environment for global investors create a mature market for these “going overseas” RWAs, enabling value discovery and efficient circulation. The policies in both regions, one leading and one following, form a complete business cycle from asset origination to trading.
This synergy not only enhances market efficiency but also supports higher-level financial strategies. In the context of RMB internationalization and financial opening, allowing domestic assets to connect with global capital markets through controlled, transparent RWA structures is an active exploration of new cross-border financing channels. Hong Kong, with its common law system, free capital flow, and internationalized market environment, serves as an ideal “testing ground” and “firewall” for this strategy.
- Market Impact: How New Regulations Will Change the Rules of the Game
The new regulatory landscape sets new action quadrants for different market participants. For domestic asset holders (such as enterprises and financial institutions), the clear filing process presents opportunities. They can leverage RWA structures to unlock previously illiquid assets or reduce cross-border financing costs, seeking better financing conditions and a broader investor base abroad.
For international capital and professional investors, a compliant RWA market supported by China’s underlying assets and traded on Hong Kong’s compliant platforms offers an attractive alternative investment option. Unlike highly volatile cryptocurrencies, these are assets backed by real cash flows, enjoying legal and regulatory protections in Hong Kong.
For fintech companies and service providers, opportunities exist on both ends. In mainland China, opportunities include providing compliant RWA structure design, technical support, and filing guidance for asset owners. In Hong Kong and overseas, opportunities lie in offering technological solutions to enhance liquidity, security, and user experience for trading platforms, custodians, and market makers.
However, challenges coexist with opportunities. Compliance costs are a primary barrier, as cross-departmental filings involve complex procedures. Technical risks such as blockchain security, interoperability, and smart contract reliability are fundamental. Additionally, market education remains a significant task—explaining the structure, risks, and value of China’s RWA products clearly to global investors.
- Defining the Red Line: Why the Issuance of RMB-Linked Stablecoins Is Strictly Prohibited
Alongside the RWA Guidelines, a more stringent document was issued. The People’s Bank of China (PBOC), together with the NDRC, CSRC, and six other departments, released the “Notice on Further Preventing and Disposing of Risks Related to Virtual Currencies and Other Issues.”
Known as the “strictest ever” in the industry, this notice reaffirms that virtual currency-related activities are illegal financial activities and draws a red line that must not be crossed regarding monetary sovereignty.
The notice explicitly states that “no units or individuals within or outside China shall issue stablecoins pegged to RMB abroad without approval from relevant authorities.”
The regulatory logic is that stablecoins linked to legal tender effectively perform some functions of legal currency in circulation, impacting monetary sovereignty and financial stability. The move aims to cut off the issuance channels of “shadow currencies” that could threaten the RMB’s status and prevent them from becoming vehicles for illegal cross-border capital flows.
It is noteworthy that the notice also clarifies attitudes toward RWA tokenization activities, distinguishing them from pure virtual currency speculation. While activities related to RWA tokenization conducted domestically and mediated by authorized entities are suspected of being illegal financial activities, an exception is made for “business activities conducted in accordance with laws and regulations, relying on specific financial infrastructure.”
This reflects a regulatory approach of “blocking illegal activities while allowing compliant ones,” leaving space for the regulated development of RWA under strict frameworks.
- Future Outlook: Three Major Trends in RWA Development
With the regulatory framework now in place, the development path for China’s RWA market is gradually becoming clearer. First, asset types will evolve from simple to more complex. Initially, stable cash flow and clear structures—such as receivables, leasing claims, and money market funds—will dominate.
As the market matures and regulatory experience accumulates, more complex assets like commercial real estate, infrastructure revenue rights, and even intellectual property may be included.
Second, Hong Kong’s trading ecosystem will become increasingly rich and specialized. Beyond spot trading, functions like margin trading, lending, and derivatives related to RWAs are likely to develop, boosting overall capital efficiency and financial depth. Traditional financial intermediaries such as market makers, rating agencies, and auditors will be introduced, making the market more robust.
Finally, regulatory technology (RegTech) and compliance technology (SupTech) will experience explosive growth. Continuous monitoring of on-chain RWAs, ensuring funds are used according to filings, and preventing money laundering will generate huge demand for advanced RegTech and SupTech solutions. Tech firms capable of providing transparent, automated regulatory solutions will gain a competitive edge in this new wave of financial infrastructure upgrades.
The global wave of RWAs is unstoppable. Industry data shows that by the end of 2025, the total issuance value of global RWAs exceeded $18 billion, growing at a rate of eightfold. China’s mainland and Hong Kong are actively driving this transformation through a dual approach of “regulatory frameworks” and “market practices.”
In the future, when investors in Hong Kong’s compliant trading platforms effortlessly buy and sell tokenized securities backed by assets like Chinese highway revenue rights, they may truly realize how the two seemingly separate announcements in February 2026 are quietly reshaping the global asset flow map.
Source references for some materials:
· “Breaking! Hong Kong SFC considers allowing retail trading of tokenized securities: The ‘Hong Kong Moment’ for RWA?”
· “PBOC and eight departments: No issuance of RMB-pegged stablecoins abroad without approval”
· “Caixin: Chinese government releases regulatory framework for domestic asset issuance of RWA abroad”