Author: Liang Yu
Editor: Zhao Yidan
In early November 2025, the Hong Kong Securities and Futures Commission issued a circular allowing virtual asset trading platforms to share a global order book; just a few months prior, the Hong Kong SAR government had released the "Digital Asset Development Policy Declaration 2.0," and the Monetary Authority implemented new regulations for stablecoin issuers. Behind this series of policies, Hong Kong is quietly building a globally leading ecosystem for the tokenization of real-world assets.
In the second half of 2025, the Hong Kong digital asset market welcomed a series of key policy adjustments. On November 3, the Hong Kong Securities and Futures Commission released a circular that for the first time allowed licensed virtual asset trading platforms to share a global order book with compliant overseas platforms, significantly enhancing market liquidity.
This initiative is in line with the "Hong Kong Digital Asset Development Policy Declaration 2.0" released by the Hong Kong SAR government six months ago. The "LEAP" framework proposed in the declaration systematically plans four major pillars for the development of digital assets in Hong Kong: optimizing legal and regulatory frameworks, expanding the variety of tokenized products, promoting application scenarios and cross-sector collaboration, and developing talent and partnerships.
At the same time, the stablecoin issuer regulatory system officially implemented by the Hong Kong Monetary Authority on August 1 provides a crucial payment and settlement infrastructure for RWA. Furthermore, on June 25, the day before the release of Policy Declaration 2.0, the WCS·2025 RWA Industry Conference held by the Hong Kong University of Science and Technology attracted thousands of attendees to discuss the implementation path for the tokenization of real-world assets.
1. Policy Declaration and Regulatory Framework: Hong Kong's RWA "LEAP" Strategy
The Hong Kong RWA regulatory system is centered around the "LEAP framework," forming a systematic project from experimentation to ecological prosperity. The "Digital Asset Development Policy Declaration 2.0" released in June 2025 positions stablecoins as settlement tools for RWA and officially implemented the "Stablecoin Ordinance" in August 2025, requiring issuers to operate under a license and comply with reserve isolation and redemption guarantee rules.
The Policy Declaration 2.0 indicates that the SAR government's governance framework for digital assets has shifted from "principle initiatives" to "institutional engineering," marking a transformation of the Hong Kong digital asset market from policy pilot to rule implementation, and from industry initiation to ecological cultivation.
The strategic core of Hong Kong is the government's direct involvement in promoting the implementation of tokenization technology to inject confidence into the market. On one hand, Hong Kong is normalizing the tokenization of sovereign bonds, having successfully issued two batches of tokenized green bonds totaling HKD 6.8 billion, and the government announced plans to regularize these issuances while exploring multi-currency and multi-term structures.
On the other hand, the Hong Kong Monetary Authority launched the "Ensemble Project," collaborating with the Securities and Futures Commission to create an interbank tokenized deposit settlement system to address the pain points of fund circulation efficiency.
This systematic layout has recently been further expanded. According to a report by the 21st Century Business Herald on November 3, the CEO of the Hong Kong Securities and Futures Commission, Ashley Alder, announced at the 2025 Hong Kong FinTech Week that two new guidelines would be introduced, focusing on broadening global liquidity for virtual asset trading platforms and fully opening the virtual asset market to professional investors.
The new guidelines allow platforms to share a global order book with compliant overseas institutions, enabling Hong Kong investors to directly access international liquidity while attracting global funds to Hong Kong.
2. Regulatory Ecology and Division of Labor: Sandbox Mechanism and Classified Regulation
Hong Kong adopts a dual-track mechanism of "sandbox experimentation + classified regulation." The Monetary Authority's Ensemble sandbox provides temporary compliance exemptions for RWA projects, allowing testing of data on-chain and stablecoin settlement processes in a controlled environment.
At the same time, the Securities and Futures Commission categorizes RWA into three types: securities-type, utility-type, and prohibited-type, implementing "green light fast review" for compliant assets such as green bonds and trade receivables, while setting red lines for real estate and virtual currency derivatives.
A report by Hong Kong Economic Journal on October 30 further reveals the development thinking of regulatory agencies. The President of the Hong Kong Monetary Authority, Eddie Yue, announced in an article for "Finance" that the next phase of the fintech development blueprint would be launched to consolidate Hong Kong's position as an international financial center and lead the frontier of financial technology.
Eddie Yue pointed out that the Monetary Authority is committed to establishing a comprehensive digital currency framework, promoting the coordinated development of various forms of tokenized currencies such as the digital Hong Kong dollar, tokenized deposits, and regulated stablecoins, forming a complementary and coexisting digital financial ecosystem.
On the regulatory technology front, a report from Hong Kong Economic Daily indicates that the Hong Kong Securities and Futures Commission has officially launched a public tender for a virtual asset trading monitoring system, with a bid deadline set for November 7, 2025, and the winning institution expected to be determined in the first half of 2026. This tender aims to build an efficient monitoring system by introducing advanced technology, enhancing the identification and early warning capabilities for unusual virtual asset trading activities.
3. Market Practice and Case Studies: RWA from Concept to Implementation
According to incomplete statistics from Yicai, over the past two years, more than 13 institutions have tested RWA, including well-known companies such as Longxin Group, Huaxia Fund, and Pacific Insurance, with underlying assets covering new energy equipment, financial products, and even agricultural products. Behind them are technology supporters like Ant Group and OSL, jointly constructing a new pathway for "domestic assets - Hong Kong confirmation - global circulation."
Successful cases are concentrated in low liquidity but stable cash flow asset types. Longxin Group has tokenized the revenue rights of charging piles through Ant Chain, completing the first cross-border RWA financing within the sandbox of the Hong Kong Monetary Authority. This project replaced financial statements with operational data, automatically distributing profits through smart contracts, achieving HKD 100 million in financing and validating the feasibility of cash flow tokenization for non-standard assets. GCL-Poly Energy issued tokens representing partial revenue rights based on an 82MW household photovoltaic power station, completing revenue distribution and investor settlement through on-chain smart contracts, opening up new pathways for cross-border financing of green energy assets.
Hong Kong has also made significant progress in the innovation of virtual asset products. According to Caixin, the Hong Kong Securities and Futures Commission has officially recognized the "Huaxia Solana ETF" for issuance and listing on the Hong Kong Stock Exchange, marking another important development in the Hong Kong virtual asset market. Notably, although the Hong Kong regulatory framework has allowed spot ETFs to provide collateral services, this product did not include such functionality in its issuance, reflecting the regulatory balance between promoting innovation and ensuring safety.
4. State-Owned Enterprises' Practice: From Pilot Projects to Scaled Exploration
As the policy and regulatory framework in Hong Kong gradually improves, RWA market practices have quietly started, with the performance of state-owned enterprises particularly noteworthy.
The RWA project of Hong Kong and China Gas demonstrates the innovative transformation of traditional public utility companies. The underlying asset chosen by the company—a HKD 100 million credit line—will mainly be used for artificial intelligence data centers, AI IoT, and cross-border infrastructure construction. By putting loan information on-chain, Hong Kong and China Gas has achieved real-time transparency of key financial and operational data, laying the foundation for further asset tokenization.
The Executive Director and Chief Financial Officer of Hong Kong and China Gas stated at the project launch that "this RWA tokenization is a key step in the group's digital transformation, and we plan to include more eligible assets in the tokenization category over the next three years, with an expected total scale of HKD 5 billion."
China Resources Group's China Resources Land focuses on the green energy sector. After participating in the Monetary Authority's "Ensemble" sandbox program, China Resources Land is developing an RWA product structure based on the revenue rights of electric vehicle charging stations. This product plans to package and tokenize future revenues from charging piles distributed across various districts in Hong Kong, allowing investors to share in the revenue from charging services by holding tokens.
COSCO Shipping Technology's "Shipping Chain" platform has entered a substantial operational phase. This blockchain-based shipping data platform has already connected over 200 supply chain enterprises, processing more than 10,000 shipping orders. The platform has created conditions for the subsequent tokenization of capacity revenue rights by digitizing shipping documents such as bills of lading and manifests.
The layout of state-owned enterprises in the Hong Kong RWA market is not limited to individual pilots but shows a systematic and scaled development trend.
Guotai Junan International, as a representative of traditional brokerages, has made landmark progress in the RWA field. According to a report by the China Banking and Insurance News on September 23, 2025, Guotai Junan International has successfully launched its first batch of structured product tokens, including redeemable fixed-income token products and capital-protected token products linked to US stock ETFs. These products utilize Ant Group's blockchain technology and RWA solutions, innovatively achieving cross-chain secure circulation of tokens between Ant Chain and Ethereum, with all transaction data being publicly transparent and immutable, allowing investors to verify independently at any time.
This issuance is regarded as the first practice of financial asset RWA, with the underlying assets being financial contracts and commitments issued by Guotai Junan International as a licensed financial institution. This move not only significantly reduced the intermediary costs in traditional issuances but also greatly improved the efficiency of clearing and settlement, showcasing the business innovation strength of Chinese brokerages after integrating the full-chain service capabilities of virtual assets, including "trading, custody, consulting, issuance, and derivatives."
China Pacific Insurance achieved a "dual layout" through Pacific Asset Management Hong Kong. After launching Hong Kong's first on-chain money market fund "eStable MMF," the company’s on-chain asset scale reached USD 200 million within three months. Meanwhile, the design of a new energy asset package in collaboration with GCL-Poly has entered the final stage, with the first batch expected to be HKD 300 million. The CEO of Pacific Asset Management Hong Kong stated at a recent performance briefing that "the successful issuance of the on-chain fund proves the feasibility of tokenizing traditional financial products, and we will continue to explore new pathways for insurance funds to participate in infrastructure investment through the RWA model."
CMB International's dollar money market fund tokenization project demonstrates the value of technological innovation. This project achieves automatic clearing and settlement of fund shares through smart contracts, shortening the traditional T+2 trading cycle to nearly real-time. More importantly, this system supports multi-currency subscriptions and redemptions in USD, HKD, and offshore RMB, providing great convenience for cross-border investors.
Bank of China International's trade finance digitalization practice has industry demonstration significance. The bank's blockchain-based trade letter of credit platform has processed over 100 cross-border trade financing transactions, totaling USD 300 million. By digitizing traditional paper letters of credit, Bank of China International has reduced the business processing time from 5-7 days to less than 24 hours, while significantly lowering the risks of human error and fraud.
5. Real Challenges: The Triple Constraints of RWA Scaling
Despite the high market enthusiasm, the development of RWA business still faces three key challenges.
The regulatory barriers to cross-border capital flow are the first key challenge. Currently, the vast majority of RWA projects intended for issuance or testing in Hong Kong have their underlying assets located in mainland China, while the project issuers are established in Hong Kong or other offshore financial centers.
This structural design, while compliant with traditional capital market operational practices, faces a dual challenge of capital entry and exit in the special financial scenario involving RWA and crypto assets.
The QFLP (Qualified Foreign Limited Partner) channel was once seen as a potential solution. However, in practice, the QFLP pathway faces numerous challenges—it lacks a nationally unified specialized law or guiding documents, and pilot policies vary across regions.
The legal validity of asset tokenization is the second constraint faced by RWA business. The process of converting real-world assets into on-chain tokens involves the transfer and representation of asset ownership or revenue rights.
In the traditional financial system, asset ownership is confirmed by specific legal documents and registration systems; however, under the RWA model, whether on-chain tokens can represent legal rights to underlying assets and whether this representation can gain recognition from the judicial system remains significantly uncertain.
The third dilemma of RWA business lies in the ambiguity of regulatory jurisdiction and the lack of clarity in product positioning. According to a report by Hong Kong Wen Wei Po, the Chairman of the Hong Kong Securities and Futures Commission, Tim Huang, recently stated that there are currently no specific regulations in Hong Kong governing the participation of listed companies in cryptocurrency investments.
He revealed that the Securities and Futures Commission will continue to closely monitor market dynamics and begin researching and formulating relevant guidelines to regulate such activities. In response to recent claims by some listed companies that they will adopt digital asset treasury practices, he specifically reminded investors to carefully discern the substantive content of DAT and its underlying real value.
6. Financing or Trend Integration: The Market Heat and Real Temperature of RWA
Given that financing costs and amounts do not have significant advantages, why are many mainland companies still keen to pursue RWA in Hong Kong?
"Rather than saying it is for financing, it is more about 'trend integration'." An RWA information consulting intermediary told Yicai reporters that bank loans are relatively cheaper, and most companies are not solely seeking financing but are focused on the diverse value of RWA.
For example, paving the way for companies to go global, bringing brand exposure, and even driving up stock prices. Many companies have seen significant increases in their stock prices after promoting RWA, a phenomenon referred to by some market participants as "market value management" or "coin-stock linkage."
Currently, more listed companies are engaging in RWA. First, they can afford higher intermediary fees; second, RWA issuance not only provides financing but also brings additional brand effects of coin-stock linkage to listed companies, thus motivating them to pursue RWA.
However, the actual financing costs for RWA in Hong Kong cannot be ignored. Yicai reporters learned from several industry insiders that the total costs for issuing RWA projects in Hong Kong typically do not fall below HKD 2.5 million, depending on the complexity of the project.
Some institutions charge a commission of 3% to 5% during the sponsorship of the issuance, but some institutions waive this fee. In addition, issuers must also promise investors a certain rate of return.
5. Real Challenges: The Triple Constraints of RWA Scaling
In the face of a complex regulatory environment, RWA projects need to build a comprehensive compliance framework.
Asset confirmation and the selection of underlying assets are the primary steps in RWA issuance. It is necessary to verify the ownership, revenue rights, and disposal rights of assets through property certificates, purchase contracts, invoices, and other documents, and to commission lawyers to issue a "legal opinion" to eliminate potential ownership disputes.
Currently, successful cases are concentrated in low liquidity but stable cash flow asset types, including new energy infrastructure, financial assets, and physical assets.
To address cross-border regulatory and bankruptcy risks, Hong Kong RWA projects generally adopt a "dual-layer SPV structure": the first layer establishes an SPV company in Hong Kong as the token issuance entity, independently bearing legal responsibility; the second layer controls or acquires the mainland SPV through agreements, holding the revenue rights of the underlying assets.
This structure must ensure the isolation of risks between the assets and the original operators and clarify the independence of each investment portfolio's assets through the articles of association.
The compliance path for cross-border data flow is also crucial. RWA projects face strict restrictions under Article 31 of the mainland's "Data Security Law" (important data going abroad) and Article 38 of the "Personal Information Protection Law" (cross-border personal information).
In compliance operations, a "dual-chain collaborative structure" is often used: utilizing compliant domestic chains such as Ant Chain and Spark Chain to complete the confirmation of asset revenue rights; using the audit documents exported from the consortium chain as a trusted data source to issue tokens on the public chain.
8. Future Outlook: Cross-Border Collaboration and Institutional Evolution
The development prospects of the Hong Kong RWA market are broad, but a series of challenges still need to be overcome.
The core challenges currently faced include legal qualification conflicts—mainland authorities classify token financing as illegal financial activities, creating a systemic gap with Hong Kong's legalized regulation; the contradiction between technological and legal lag—conflicts between the efficiency of blockchain cross-border flow and mainland capital controls need to be resolved; and insufficient cross-border judicial cooperation—stablecoins still require strengthened cross-border regulatory collaboration in anti-money laundering risk prevention.
Nevertheless, the future development of the Hong Kong RWA market remains promising. In terms of policy upgrades, the Hong Kong Securities and Futures Commission proposed in October 2025 to amend the "Code on Unit Trusts and Mutual Funds," allowing retail funds to invest in low liquidity assets, paving the way for RWA fundization.
In terms of improving technological infrastructure, the testing of digital renminbi and Hong Kong dollar stablecoin exchanges will enhance settlement efficiency. In terms of expanding asset types, the normalization of government bond tokenization and the expansion of asset categories such as gold and renewable energy will drive RWA from experimentation to scaling.
In the next 1-2 years, the development of RWA business will mainly rely on meticulous cultivation within the "regulatory sandbox." Whether it is the Hong Kong Monetary Authority's "Ensemble Project Sandbox" or various fintech innovation regulatory pilot programs in the mainland, they will become the main breeding grounds for compliant RWA products.
The recent remarks by Hong Kong's Financial Secretary, Paul Chan, further reveal the direction of Hong Kong's development. According to a report by Financial界 on October 20, Chan pointed out at the International Monetary Fund and World Bank Group Annual Meetings that all economies recognize that the influence of digital assets is accelerating, and relevant blockchain technologies have been implemented in multiple real-world scenarios, especially in enhancing intra-regional trade efficiency and addressing cross-border settlement pain points.
He emphasized that digital assets have significant development potential, but the international community must strengthen collaboration to prudently manage the risks they may pose to global financial stability.
Through a three-tiered approach of "policy declaration - regulatory sandbox - legislative protection," Hong Kong has built a globally leading RWA compliance ecosystem. Its core advantage lies in providing technical compliance guarantees through the "Stablecoin Ordinance" and the Ensemble sandbox, while also addressing cross-border capital flow challenges through the dual-layer SPV structure and QFLP channel.
With the continuous improvement of regulatory technology and the deepening of international cooperation, Hong Kong is expected to find a balance between prudent regulation and innovation incentives, providing a more mature and stable market environment for the tokenization of real-world assets.
For mainland enterprises, Hong Kong is not only a financing window but also an innovative platform for testing asset tokenization and connecting with international standards.
Some sources of information:
· "Hong Kong Digital Asset Development Policy Declaration 2.0"
· "Hong Kong to Build a Trustworthy and Innovative Digital Asset Ecosystem"
· "The Frenzy of RWA in Hong Kong: Financing or 'Trend Integration'?"
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