In early November 2025, the Hong Kong Securities and Futures Commission issued a circular allowing virtual asset trading platforms to share global order books; just a few months earlier, the Hong Kong SAR government had released the "Digital Asset Development Policy Declaration 2.0," and the Monetary Authority had 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 global order books 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 outlines the four pillars of Hong Kong's digital asset development: 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 Hong Kong Monetary Authority officially implemented the stablecoin issuer regulatory system on August 1, providing a key 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 over a thousand 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 RWA settlement tools 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 Hong Kong's 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 global order books 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 revealed 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 financial technology development blueprint would be launched to consolidate Hong Kong's position as an international financial center and lead the forefront 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 ecology.

On the regulatory technology front, reports from Hong Kong Economic Daily indicate 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 Cases: RWA from Concept to Implementation

According to incomplete statistics from Yicai, over 13 institutions have tested RWA in the past two years, 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 of "domestic assets - Hong Kong confirmation - global circulation."

Successful cases are concentrated in low liquidity but stable cash flow asset types. Longxin Group tokenized the revenue rights of charging piles on the 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 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 Hong Kong's 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 Enterprise 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 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 a total scale expected to reach HKD 5 billion."

China Resources Group's China Resources Longyuan is focusing on the green energy sector. After participating in the Monetary Authority's "Ensemble" sandbox program, China Resources Longyuan 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 with over 200 supply chain enterprises, processing more than 10,000 shipping orders. The platform digitizes shipping documents such as bills of lading and manifests, creating conditions for the subsequent tokenization of capacity revenue rights.

The layout of state-owned enterprises in Hong Kong's 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 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 secure cross-chain circulation of tokens between Ant Chain and Ethereum, with all transaction data being publicly transparent and tamper-proof, 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 costs of intermediary links in traditional issuances but also greatly improved clearing and settlement efficiency, showcasing the business innovation capabilities of Chinese brokerages after integrating full-chain services for virtual assets, including trading, custody, consulting, issuance, and derivatives.

China Pacific Insurance achieved a "dual layout" through China Pacific Asset Management Hong Kong. After launching Hong Kong's first on-chain money market fund "eStable MMF," the scale of on-chain assets managed by the company 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 reach HKD 300 million. The CEO of China 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 uses smart contracts to achieve automatic clearing and settlement of fund shares, 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 problem 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 path faces numerous challenges—it lacks a nationally unified specialized law or guiding documents, and pilot policies vary by region.

The legal effectiveness of asset on-chain 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, in the RWA model, whether on-chain tokens can represent legitimate rights to the 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 Lui, recently stated that there are currently no specific regulations in Hong Kong governing listed companies' participation 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 behaviors. Regarding the recent claims by some listed companies to 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

In the absence of significant advantages in financing costs and amounts, why are many mainland companies still keen on RWA in Hong Kong?

"Rather than saying it's for financing, it's more about 'integrating trends'." An RWA information consulting intermediary told Yicai that bank loans are relatively much cheaper, and most companies are not simply 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 boosting 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 can provide listed companies with additional brand effects from coin-stock linkage, thus motivating them to pursue RWA.

However, the actual financing costs of 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% when sponsoring the issuance, but some institutions waive this fee. In addition, issuers must also promise a certain rate of return to investors.

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 underlying asset selection are the primary steps in RWA issuance. It is necessary to verify the ownership, revenue rights, and disposal rights of assets through documents such as property certificates, purchase contracts, and invoices, 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 critical. 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: domestic compliant chains such as Ant Chain and Spark Chain are used to complete the confirmation of asset revenue rights; the audit documents exported from the consortium chain serve as a trusted data source for issuing 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—efficiency in cross-border blockchain flow conflicts with mainland capital controls that urgently need resolution; and insufficient cross-border judicial cooperation—stablecoins still require enhanced cross-border regulatory collaboration in terms of anti-money laundering risk prevention.

Nevertheless, the future development of the Hong Kong RWA market remains hopeful. 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 the accelerating influence of digital assets, 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 guarantee," Hong Kong has built a globally leading RWA compliance ecosystem. Its core advantages lie 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.

Sources of some materials:

• "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 'Integrating Trends'?"

Author: Liang Yu Editor: Zhao Yidan

免责声明：本文章仅代表作者个人观点，不代表本平台的立场和观点。本文章仅供信息分享，不构成对任何人的任何投资建议。用户与作者之间的任何争议，与本平台无关。如网页中刊载的文章或图片涉及侵权，请提供相关的权利证明和身份证明发送邮件到support@aicoin.com，本平台相关工作人员将会进行核查。