Author: BlockWeeks

Recently, the narrative surrounding the digitalization of the Renminbi presents two starkly contrasting yet intrinsically connected pictures. On one side, multiple media outlets have revealed the cautious attitude of mainland regulators towards companies applying for stablecoin licenses in Hong Kong and related offshore digital asset businesses, akin to lighting a cautious "signal light"; on the other side, an offshore Renminbi stablecoin named AxCNH has quietly emerged under the regulatory framework of Kazakhstan, targeting trade settlements along the "Belt and Road" initiative, carving out a shrewd "flanking" path.

This "retreat and advance" is not a contradiction but precisely outlines the core dilemma faced by the Renminbi stablecoin in the past, present, and future: How to respond to the global market's immense demand for a programmable, high-efficiency digital Renminbi under the "absolute red line" of national financial sovereignty and capital controls?

Wilderness and Prelude — The "Prehistoric Era" of Renminbi Stablecoins

Before the official regular army entered the scene, the landscape of Renminbi stablecoins had long been cultivated by the spontaneous forces of the market. This "prehistoric era" is mainly composed of two forces:

1. Gray Area Trading Medium: Represented by CNHt

   • Product Form: Some issuers, including Tether, have launched stablecoins pegged to offshore Renminbi (CNH), such as CNH₮ (CNHT). These tokens are visible on various crypto data platforms and exchanges and are used for fiat currency channels and trading settlements. Issuers typically claim to have reserve support, but the transparency and auditing of these reserves have always been a focal point of market concern.
   • Core Function: Its birth was not aimed at the internationalization of the Renminbi but rather as a "fiat currency entry and exit channel" within cryptocurrency exchanges. It provides users in Chinese-speaking regions with a tool to circumvent regulation and conveniently enter and exit the crypto market, while also becoming a covert channel for capital flow to some extent.

   The existence of tokens like CNHt itself is a strong market signal. It proves that there is a huge, unmet demand for digital Renminbi on the market side. However, its unregulated nature and its natural association with sensitive terms like "capital outflow" destined it to struggle for sovereign recognition and large-scale retail adoption, becoming a key concern for regulators. Its historical mission was to validate the feasibility and risks of the track before the official entry.

2. Official Orthodox Successor: The Grand Narrative of Digital Renminbi (e-CNY)

   • Product Form: Issued by the People's Bank of China, the central bank digital currency (CBDC) is the digital form of legal tender, classified as central bank liabilities (M0), and carries national credit. Its design leans towards centralization and permissioned systems, emphasizing controllability over currency circulation and identity verification.
   • Core Function: Its primary goal is domestic, namely to optimize the domestic retail payment system, break the existing mobile payment pattern, enhance the transmission efficiency of monetary policy, and achieve "controllable anonymity." However, commercialization and large-scale promotion must overcome the complexities of technology, compliance, and inter-organizational connections. Its cross-border payment function, such as through the exploration of mBridge (Multilateral Central Bank Digital Currency Bridge), remains in a cautious experimental stage.

   Fundamentally, e-CNY is not a "stablecoin" in the crypto sense. It is a centralized, permissioned system, and its design philosophy is "control" rather than "openness." The development path of e-CNY clearly indicates that the highest priority for the Chinese government regarding currency digitalization is to maintain national financial sovereignty and the independence of monetary policy. All technological applications must serve this highest goal.

These two paths represent a wild growth from the market bottom-up and a top-down design from the state. They have essential differences in goals, governance, and regulatory attributes: the former represents innovation and flexibility, while the latter represents market sovereignty and controllability. They have developed in parallel over the past few years with almost no intersection, together forming the prelude to the Renminbi stablecoin.

Hong Kong Experimentation Zone — Ideals, Reality, and the Invisible Hand

As Hong Kong vigorously promotes itself as a global virtual asset center, a new possibility has emerged: Can a compliant, controllable offshore Renminbi stablecoin that connects with the global crypto ecosystem be created in Hong Kong's unique "one country, two systems" window?

This was once the market's most optimistic expectation. The Hong Kong Monetary Authority's stablecoin regulatory sandbox was seen as a tailored incubator for "Hong Kong dollar stablecoins" and even "offshore Renminbi stablecoins." The market widely speculated that state-owned financial giants would be the first to enter, issuing CNH stablecoins tacitly approved by the authorities, which would serve as an excellent springboard for the internationalization of the Renminbi.

However, recent media reports have poured cold water on this optimism. The "window guidance" from mainland regulators clearly conveyed several core concerns:

• Firewall Against Financial Risks: How can a CNH stablecoin that circulates freely on a public chain ensure it does not become a new tool for circumventing mainland capital controls? Will its price volatility and reserve security issues negatively impact the financial stability of the mainland?
• Extension of Monetary Sovereignty: Who holds the issuance, governance, and clearing rights for a digital currency pegged to the Renminbi issued in the offshore market? This directly touches on the core issue of monetary sovereignty.
• Conflict with e-CNY's Positioning: If a CNH stablecoin issued by a commercial entity circulates widely globally, will it undermine e-CNY's strategic layout in the cross-border payment field?

Behind this lies the classic "Mundell's Impossible Trinity" theory projected into the digital age. This theory states that a country cannot simultaneously achieve free capital movement, fixed exchange rates, and an independent monetary policy. An ideal, public-chain-based CNH stablecoin inherently possesses the attribute of "free capital movement." However, China's core demand is to maintain a relatively stable exchange rate and absolute independence of monetary policy. This means that the free movement of capital must be strictly limited.

Therefore, the cautious attitude of mainland regulators does not negate Hong Kong's innovation but is a necessary choice made in the face of this fundamental structural contradiction. Before controllability is absolutely guaranteed, any potential threat to the effectiveness of capital controls will not be easily opened.

Insights from a New Model — Exploration in Specific Scenarios

Just as the "main thoroughfare" in Hong Kong seems to be obstructed, the emergence of AxCNH provides a case for a "flanking path." The characteristics of this model offer us a new perspective for observing the industry:

• Choosing Regulatory Pathways: It did not apply directly in mainstream but strictly regulated areas like Hong Kong or Singapore, but instead chose a region that is relatively friendly to cryptocurrencies and geopolitically close to China as its registration and licensing location.
• Focusing on Specific Narratives: It strives to avoid positioning itself as a crypto asset aimed at retail investors for speculative trading. Instead, it positions itself as a B-end fintech tool serving specific strategies (such as the "Belt and Road"). Its announced partners are large entities, and its application scenarios are cross-border trade settlements.
• Limiting Risk Scope: By focusing on specific scenarios and partners, this model confines its business scope and potential risks to a relatively narrow and controllable range. This significantly reduces the possibility of risk spillover compared to a stablecoin that is open to everyone on a public chain.

This model can be seen as an adaptive strategy to the current environment. It does not attempt to challenge the red line of capital controls but seeks survival space in a sensitive regulatory environment by positioning itself as an "industrial tool" rather than a "general financial product."

While this model may face challenges in liquidity, universality, and market credibility, it represents a possible path for the private sector to explore Renminbi stablecoins under strong regulatory environments: abandoning the grand goal of becoming a universal currency and instead becoming a dedicated settlement tool within specific industrial chains or ecosystems.

However, it is important to emphasize that such practices still face challenges in compliance and business sustainability: cross-border clearing connections, sources of reserve funds (especially involving foreign exchange controls), and the implementation of redemption mechanisms are key variables determining whether it can scale and sustain long-term. In other words, whether the flanking path can go far depends on whether a clear and regulatorily acceptable compliance chain can be built in legal, foreign exchange, and business connections.

Future Outlook — The Triptych of Digital Renminbi

In summary, the future of Renminbi stablecoins is unlikely to be a single path but is more likely to evolve into three parallel yet occasionally intersecting paths:

1. Path One: Official Sovereign Level — e-CNY's "Walled Garden"
   • Core: e-CNY will continue to serve as the only officially recognized digital legal currency, accelerating its domestic adoption. Its cross-border applications will mainly be conducted through mBridge and other multilateral, central bank-led, permissioned clearing networks, achieving point-to-point "wholesale" cross-border payments.
   • Characteristics: Safe, controllable, compliant. However, efficiency and openness will be limited by the complexities of multilateral negotiations and system integrations. This is a "strong control" path centered on sovereign credit.
2. Path Two: Offshore Compliance Level — Hong Kong's "Limited Open" Sandbox
   • Core: The mainland's cautious attitude does not imply a permanent ban. In the future, when regulatory technologies and frameworks mature, it is likely to approve a few well-capitalized institutions with strong risk control capabilities to issue highly restricted CNH stablecoins in Hong Kong.
   • Characteristics: Such stablecoins may be based on permissioned chains or public chains with whitelist mechanisms, and transactions will be subject to strict KYC/AML scrutiny and monitoring. Their main function will be to serve institutional-level financial market businesses such as commodity trade and bond connect, rather than retail and crypto trading. This is a "semi-open" path that tests pressure within sovereign boundaries.
3. Path Three: Market Application Level — "Deep Cultivation" in Specific Scenarios
   • Core: More projects may adopt the aforementioned flanking path's ideas, abandoning fantasies about mainstream markets and instead delving into specific industrial scenarios, such as trade settlements in specific countries, supply chain finance, and cross-border e-commerce.
   • Characteristics: These projects will exhibit high degrees of scenario-based, vertical, and fragmented characteristics. Their success will not depend on the bull or bear market of cryptocurrencies but on whether they can genuinely reduce costs and increase efficiency for specific industries. This is a "pragmatic" path that avoids direct regulation and serves the real economy.

Conclusion

The development of Renminbi stablecoins is essentially a microcosm of the eternal game between global liquidity and the financial sovereignty of a single country in the digital age. From the early chaotic landscape of CNHt to the national will of e-CNY, and then to Hong Kong's institutional ambitions and market participants' alternative paths, what we see is not a linear evolution but a complex ecology of multiple forces probing, compromising, and coexisting.

The cautious guardianship of mainland regulators protects the bottom line of national financial security, while market innovation demonstrates its resilient tenacity. In the future, the picture of digital Renminbi will not be singular; it will be a "triptych" composed of the solemn main theme of e-CNY, the cautious concerto of Hong Kong's compliant stablecoins, and the flexible variations of numerous scenario-based stablecoins. And the conductor of this symphony will always be that invisible yet powerful hand pursuing "stability" and "controllability."

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