The wave of tokenization of Real World Assets (RWA) is striking the boundaries of traditional finance with unprecedented force. This is not only a technological innovation but also a profound game of national strategy and regulatory philosophy. From Singapore's collaborative ecosystem to Thailand's inclusive bonds, from Switzerland's wholesale digital currency to Dubai's fragmented real estate, countries around the world are drawing regulatory blueprints along divergent paths. A multi-centered competition, led by nations, coordinated by institutions, and driven by markets, has already begun, and its outcome will reshape the flow of global capital and the future landscape of finance.
I. Overview of Global RWA Regulatory Models
The tokenization of Real World Assets (RWA) as a key area of integration between blockchain technology and traditional finance is attracting widespread attention from global regulatory bodies. Based on the economic environment, financial market characteristics, and regulatory philosophies of various countries, the current global RWA regulatory landscape has mainly formed three differentiated models: state-led, institutionally coordinated, and market-oriented. These models reflect the different trade-offs made by various jurisdictions in promoting innovation while maintaining financial stability.
Table 1: Main Global RWA Regulatory Models and Representative Countries
The formation of these three regulatory models is deeply influenced by the financial traditions, legal systems, and industrial policies of different regions. The state-led model is common in areas where the government has a strong guiding ability over financial markets; the institutionally coordinated model is often found in open economies that heavily rely on international trade and financial cooperation; the market-oriented model typically exists in jurisdictions with highly developed financial markets and mature regulatory systems.
It is noteworthy that these models are not mutually exclusive but rather reflect a spectrum of regulatory strategies for RWA across different jurisdictions. As markets develop, some countries are also adjusting their regulatory stances. For example, Japan has recently shifted from high-intensity comprehensive taxation to separate taxation through tax rate reforms, marking a gradual transition in its policy direction from risk prevention to market incentives.
II. State-Led Regulatory Model
The fundamental characteristic of the state-led RWA regulatory model is that the government and regulatory agencies play a core role in the development of the RWA ecosystem, guiding the RWA market to develop in a direction that aligns with national strategies through policy guidance, infrastructure construction, and even direct participation. This model is common in countries where the government has a strong willingness and capability to guide financial markets.
1. Mainland China: Balancing Prudential Control and Pilot Innovation
Mainland China's regulation of RWA exhibits a clear dual characteristic of prudential control and pilot innovation. At the macro policy level, China maintains a strict prohibition on activities related to virtual currencies. The People's Bank of China and ten other ministries issued a notice in 2021 that clearly categorizes activities related to virtual currencies as illegal financial activities. This strict regulatory stance has created institutional barriers for the issuance of RWA products with financial attributes domestically. However, while prohibiting financial speculation, China is also promoting compliant pilot projects through local governments and industry associations, exploring non-financial and scenario-based applications of RWA.
In China's exploration of tokenization of Real World Assets (RWA), the digital renminbi (e-CNY) plays a crucial core role, serving as a key bridge connecting technological innovation and financial compliance under the state-led model. Unlike many other countries that directly tokenize various assets on-chain, China's prudent strategy is reflected in its strict limitations on private crypto assets while fully constructing and promoting a central bank-backed legal digital currency, aiming to lay a secure and controllable foundational infrastructure for the potential large-scale digitalization of assets in the future.
The strategic positioning of the digital renminbi goes far beyond a simple electronic payment tool. It is explicitly viewed as a national-level financial infrastructure and a cornerstone of the digital financial era. Its strategic significance lies in two aspects: first, against the backdrop of the rapid development of global stablecoins, the digital renminbi is a key measure to consolidate national currency sovereignty and ensure the dominant position of the renminbi in the digital economy. Second, through its "payment as settlement" and programmable features, the digital renminbi opens up technological space for exploring efficient and low-cost compliant financial transactions in the future, such as theoretically providing more efficient clearing and settlement solutions for bond issuance, trade financing, or the circulation of specific asset rights.
In practice, the promotion of the digital renminbi is extending from retail scenarios to broader fields. The authorities are committed to expanding its application from daily small payments to "large-scale inclusive" scenarios, including corporate payments, government payments, and supply chain finance. This expansion is essentially building a rich application ecosystem for the digital renminbi, enabling it to support more complex financial activities in the future. A significant development is that in 2025, the People's Bank of China established an international operation center for the digital renminbi in Shanghai, signaling that China is actively exploring the use of the digital renminbi to optimize the settlement processes for cross-border trade and investment, enhancing the efficiency of cross-border capital flows, and laying a forward-looking foundation for the future digital flow of cross-border assets under state leadership.
At the same time, Chinese regulatory agencies maintain strict and clear boundaries regarding unofficial digital asset forms. The domestic environment continues to exert high pressure on activities such as virtual currency trading and ICOs, creating an undisturbed internal environment for the research and pilot of the digital renminbi. This regulatory philosophy of "opening the front door while blocking the side doors" ensures that the leading role in financial innovation remains firmly in the hands of the state and the central bank. Even innovative pilot projects conducted by local governments or state-owned enterprises, such as digital certificates for agricultural assets or advertising rights, are strictly limited to the scope of consumer rights or specific services, avoiding involvement in financialization and securitization, with their technological paths and potential future synergies with the digital renminbi ecosystem all within the purview of national regulation.
China's RWA development path exhibits a distinct characteristic of "centered on the digital renminbi, based on national credit, and bounded by prudent compliance." The current focus is not on encouraging the free tokenization of various assets but rather on prioritizing the solidification of state-led digital financial infrastructure. By vigorously promoting the digital renminbi, China is building a secure, efficient, and fully regulated core payment and settlement track for the potentially larger wave of asset digitalization that may come in the future.
2. Hong Kong: A Regulatory Model of Openness and Strict Access
Hong Kong, leveraging its status as an international financial center, has constructed a more inclusive and innovative RWA regulatory framework while maintaining strict access standards, reflecting a compromise model of "openness + strict access." The Hong Kong Special Administrative Region government has established a "dual regulatory agency" system centered on the Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA) to implement differentiated regulation of RWA.
Hong Kong's practices in the field of Real World Assets (RWA) have formed a coherent advancement system, with the regulatory sandbox mechanism serving as an important foundation. For example, platforms like the "Ensemble Project" allow companies to test cross-border RWA issuance models, with cases such as GCL-Poly Energy and Xunying Technology successfully completing issuances through this mechanism. Building on this, the Hong Kong Monetary Authority launched the "Digital Bond Funding Scheme" in November 2024 to encourage the widespread application of tokenization technology in the capital market, with eligible companies able to receive up to HKD 2.5 million in funding, thereby creating a policy environment that incentivizes innovation. The effectiveness of this series of measures is reflected in specific cases— in August 2025, Guotai Junan International collaborated with Ant Group to successfully issue the first batch of structured product tokens based on Ant Chain technology, achieving cross-chain circulation to Ethereum through a "two chains and one bridge" structure, effectively connecting mainland Chinese assets with global trading markets and showcasing Hong Kong's practical achievements in promoting asset digitalization and cross-border flow.
3. Thailand and Vietnam: Inclusive Financial Practices Backed by National Credit
Southeast Asian countries exhibit unique state-led characteristics in the RWA field, particularly Thailand and Vietnam, which leverage national credit to promote RWA towards inclusive finance.
Thailand's G-Token project is a typical case of the state-led model. Led by the Thai Ministry of Finance, G-Token is the world's first tokenized government bond aimed at retail investors, with an initial issuance amount of 5 billion baht (approximately USD 153 million) and a minimum investment threshold of only 100 baht, significantly lowering the investment barrier for ordinary citizens. This project not only enhances the liquidity of government bonds but also effectively promotes the legalization and maturation of Thailand's domestic digital asset market.
Vietnam, on the other hand, is advancing the application of RWA technology in the modernization of national governance through the collaboration between the Ministry of Finance and the Vietnam Postal Savings Bank, focusing on putting accounting, bills, and cross-border trade data on-chain rather than purely on financial innovation.
III. Institutionally Coordinated Regulatory Model
The core feature of the institutionally coordinated regulatory model is the close collaboration between government agencies, financial institutions, and technology companies, testing and refining the RWA framework in a controlled environment through mechanisms such as regulatory sandboxes and industry standard-setting. This model is common in open economies that heavily rely on international trade and financial cooperation.
1. Singapore: A Model of Global Coordination and Mutual Recognition of Standards
The RWA regulatory path promoted by the Monetary Authority of Singapore (MAS) is regarded as a model of institutional coordination. Its core project, Project Guardian, has attracted over 40 international financial institutions, forming a highly collaborative global financial ecosystem. This project is not only a technology testing platform but also aims to address interoperability issues in the RWA market by establishing a shared industry framework, avoiding fragmentation in the early stages of technology application.
Singapore has introduced a series of innovative measures in RWA regulation, with the triple licensing system forming an important foundation of its regulatory framework. For example, DigiFT, as the world's first RWA platform to obtain a triple license for capital market services, successfully crossed the three regulatory thresholds required for securities trading platforms, including trading venue licenses, capital market service licenses, and custody service qualifications.
On the technical level, the platform deeply integrates the DPoS (Delegated Proof of Stake) mechanism built on Ethereum with compliance requirements, leveraging on-chain transparent ledgers to achieve regulatory penetration, ensuring that every transaction generates an audit trail that meets the standards of the Monetary Authority of Singapore (MAS). Furthermore, DigiFT constructs a "iron triangle" business closed-loop model, integrating an AMM-based liquidity engine, a compliance firewall that automatically executes KYC/AML verification through smart contracts, and a technical platform that uses zero-knowledge proofs to protect privacy, systematically addressing the three core pain points of liquidity challenges, compliance barriers, and technical thresholds that have long plagued the RWA field.
2. European Union: Coordinated Regulation Under a Unified Framework
The European Union adopts a regulatory strategy that promotes policy coordination among member states through a unified framework, gradually achieving standardized regulation through the "Digital Finance Package," MiCA (Markets in Crypto-Assets Regulation), and DLT pilot regime, while maintaining compliance consistency within the region. EU regulatory bodies have made it clear that tokenized securities are still securities, and market participants must consider and comply with securities laws when trading these instruments.
The EU demonstrates a systematic approach to RWA regulation, with its core focus on providing clear legal certainty, effectively reducing market compliance uncertainty through clear classifications and regulatory requirements for tokenized assets. On this basis, the EU emphasizes cross-border coordination, facilitating regulatory mutual recognition among member states through a unified rule system, providing convenience for the cross-border expansion and operation of RWA projects. At the same time, the EU has introduced innovative pilot mechanisms, with its dedicated DLT pilot regime providing temporary regulatory exemptions for innovative projects, allowing companies to test their new products and technologies in real market environments. This series of measures collectively forms a regulatory framework that is normative, open, and encourages innovation.
3. Switzerland and South Korea: Precise Legislative Practices of Institutional Coordination
Switzerland's Project Helvetia is one of the most influential RWA projects globally. Launched jointly by the Swiss National Bank (SNB) and the Bank for International Settlements (BIS) Innovation Hub, the core objective is to test how central bank money can be used for the settlement of tokenized assets on a distributed ledger technology (DLT) platform. Project Helvetia has entered its third phase, conducting real-time pilots using wholesale central bank digital currency (wCBDC), providing a solid technical and regulatory foundation for the digitalization of the financial system.
South Korea is advancing the legal access of on-chain securities through special legislation and exploring payment scenarios in conjunction with local stablecoins. South Korean financial regulators are actively constructing a mainstream framework based on prudent regulation. While maintaining relatively tight policy constraints in terms of regulatory intensity, they have essentially completed the reconstruction of the regulatory structure for RWA assets, ensuring that key processes such as token issuance, rights confirmation, circulation, and custody are well-regulated.
IV. Market-Oriented Regulatory Model
The fundamental characteristic of the market-oriented regulatory model is a greater reliance on self-regulation and innovation by market participants, with regulatory agencies primarily ensuring market compliance through ex-post enforcement rather than setting detailed rules in advance. This model is typically found in jurisdictions with highly developed financial markets and mature regulatory systems.
1. United States: A Complex Balance of Enforcement Regulation and Market Drive
The RWA regulatory landscape in the United States exhibits a typical federal and state-level differentiation, along with a strong inclination towards enforcement regulation. The U.S. Securities and Exchange Commission (SEC) has explicitly stated that tokenized securities are still securities, and market participants must consider and comply with federal securities laws when trading these instruments. This "the law already exists" regulatory stance forces market participants to explore feasibility in gray areas.
The United States shows significant market-oriented regulatory characteristics in the field of Real World Assets (RWA), with development primarily driven by private institutions and market demand, reflected in several landmark cases. The world's largest asset management company, BlackRock, launched the first tokenized fund on a public blockchain, BUIDL, in March 2024, marking the formal recognition and participation of traditional financial giants in the RWA model.
At the local government level, Bergen County in New Jersey plans to digitize real estate contracts worth up to $240 billion and record them on the Avalanche blockchain in collaboration with private tech company Balcony. This initiative is expected to improve contract processing efficiency by over 90%, showcasing the profound transformation of traditional asset registration processes through blockchain technology. Meanwhile, market innovation remains active, with cryptocurrency exchange Kraken collaborating with asset tokenization firm Backed Finance to promote stock tokenization in Europe, attempting to achieve 24/7 uninterrupted trading through virtual asset exchanges. These practices led by enterprises and local governments collectively outline a path for RWA development in the U.S. that prioritizes market exploration and follows up with regulation.
2. United Kingdom and Japan: Gradual Market Liberalization Path
The RWA regulatory path in the United Kingdom is closer to that of continental Europe, with rapid formation of regulations for stablecoins, market infrastructure, and tokenized securities. The Financial Conduct Authority (FCA) and the Bank of England have clear divisions of labor, providing a relatively unified logic in institutional construction. The Digital Securities Sandbox launched in the UK allows companies to test tokenized securities in a controlled environment, reflecting the regulatory approach that supports innovation while ensuring financial stability.
In recent years, Japan has experienced a significant shift in regulatory posture, using tax rate reform as a breakthrough to transition from high-intensity comprehensive taxation to separate taxation, marking a gradual shift in its policy direction from risk prevention to market incentives. This transition has enhanced Japan's attractiveness in the global RWA market competition while maintaining financial stability.
3. United Arab Emirates: Institutional Dividends Attracting Global Innovation
The United Arab Emirates (especially Dubai) has become a representative of the market-oriented model due to its regulatory certainty and market openness. Dubai has established a comprehensive framework covering tokenization, digital assets, and cross-border capital flows through institutions like DIFC and VARA (Virtual Assets Regulatory Authority). The real estate tokenization project in Dubai, led by the Dubai Land Department (DLD), aims to enhance the liquidity and accessibility of the real estate market by dividing property ownership into digital tokens.
The UAE's development in the field of Real World Assets (RWA) showcases its unique comprehensive advantages, with a low tax environment creating a significantly cost-effective experimental platform for the migration of global RWA assets through institutional zero-tax design. At the same time, the country also excels in regulatory certainty, as evidenced by DAMAC Properties' collaboration with Securrency to advance a $1 billion tokenization project for real estate and data centers on the Avalanche blockchain, providing a clear compliance entry point for institutional investors.
On this basis, the market-driven innovation model further strengthens its competitiveness by lowering the investment threshold for real estate tokenization to 2,000 dirhams (approximately $545), greatly broadening the investor base and attracting participation from around the globe, thus forming a comprehensive advantage pattern from the institutional environment to specific practices.
V. Key Dimensions of RWA Regulation and Future Outlook
1. Five Key Dimensions of RWA Regulation
As the RWA market continues to expand, the core dimensions of regulation have gradually been clearly defined. From the establishment of compliance frameworks to regulatory coordination for cross-border flows, each dimension directly relates to the legality, transparency, and global liquidity of RWA assets.
Compliance Framework and Market Standards: The compliance framework is the foundation of RWA regulation. Several global financial centers, such as Singapore and Switzerland, have established clear regulatory frameworks that provide market participants with clear rules. These countries not only ensure market safety through strict compliance systems but also promote the establishment and global mutual recognition of industry standards, ensuring the liquidity of cross-border RWA assets. For example, DigiFT's "triple licensing" model sets a clear compliance benchmark for the industry, with its DPoS mechanism built on Ethereum achieving regulatory penetration through on-chain transparent ledgers, ensuring that each transaction generates an audit trail that meets MAS standards.
Tax Policies and Accounting Standards: Tax policies and accounting standards are another key element of RWA regulation. There are differences in how various countries handle the taxation and accounting of RWA assets, which directly affects the feasibility and market activity of cross-border asset transactions. Countries like Singapore, Hong Kong, and the UAE have created relatively low-cost experimental platforms for the migration of global RWA assets through institutional zero-tax designs; Japan has transitioned from high-intensity comprehensive taxation to separate taxation through tax rate reforms, marking a shift in its policy direction from risk prevention to market incentives.
Asset Auditing and On-Chain Disclosure: With the rapid development of the RWA market, ensuring the transparency and authenticity of assets has become a primary regulatory task. Countries require independent audits by third-party institutions and mandate the public disclosure of on-chain data to ensure market transparency. In the RWA project of Longxin Group's charging piles, operational data such as electricity and status are collected in real-time through Ant Group's AIoT modules and quickly uploaded to the blockchain, with on-chain data verified by third-party independent rating agencies. This transparent data disclosure mechanism provides a reliable basis for revenue calculation and asset valuation.
Investor Protection and Risk Management: As the RWA market expands, investor protection has become a key issue. Regions like Singapore and Hong Kong ensure that market participants understand potential risks and avoid excessive speculation through strict investor suitability assessments and risk education. For example, Longxin Technology's RWA issuance in Hong Kong is only open to professional investors (PI) with risk identification capabilities, limiting retail investor participation. The Hong Kong Securities and Futures Commission imposes strict compliance requirements on platforms providing securities token trading services, including asset custody, cybersecurity, and market conduct regulations.
Cross-Border Regulatory Coordination and Standardization: Cross-border regulatory coordination is key to the effective operation of the global RWA market. Countries need to address compliance issues in cross-border transactions through international cooperation and regulatory standardization. Countries like Singapore and Switzerland have played important roles in promoting the establishment of global standards for RWA. For example, the cooperation agreement between Finloop and 1exchange specifically addresses cross-border compliance challenges, aiming to optimize RWA product structures and strengthen cross-border compliance capabilities under the regulatory frameworks of Hong Kong and Singapore.
2. Future Development Trends in Global RWA Regulation
Looking ahead, global RWA regulation will exhibit the following development trends:
Accelerated Regulatory Integration: Compliance interfaces between DeFi (Decentralized Finance) and TradFi (Traditional Finance) are forming, with regulatory technology (RegTech) becoming a new infrastructure. Regulatory agencies in major financial centers will continue to deepen cooperation, promoting mutual recognition and unification of regulatory standards. Hong Kong and Singapore have explicitly stated that they will strengthen coordination in RWA regulation and jointly promote the standardized development of the RWA market in Asia.
Upgraded Technological Regulation: As the complexity of RWA projects increases, regulatory agencies will increasingly utilize blockchain technology itself for regulation, with balancing transparency and privacy protection becoming a key issue. The application of privacy protection technologies such as zero-knowledge proofs will meet regulatory transparency requirements while ensuring data security.
Diversification of Asset Types: The current focus on government bonds, real estate, and private credit will expand to a broader range of asset classes, including intellectual property, data assets, carbon credits, and other new types of assets. Regulatory agencies need to design differentiated rules for different asset classes, as seen in China's RWA pilot, which clearly distinguishes between financial assets and consumer rights assets.
Coexistence of Cross-Border Regulatory Competition and Cooperation: Countries are competing to attract RWA innovation and investment, but they also recognize the necessity of cross-border regulatory cooperation. International collaborative projects like Project Guardian indicate that future RWA regulation will place greater emphasis on cross-border coordination.
The global RWA regulatory landscape is undergoing rapid evolution, with state-led, institutionally coordinated, and market-oriented models adapting to the economic environments and regulatory traditions of different jurisdictions. As technology continues to mature and markets expand, regulatory frameworks will further refine and improve. In the foreseeable future, regulatory compatibility, technological standardization, and cross-border collaboration will be key factors driving the healthy development of the RWA market. According to a forecast by the Boston Consulting Group, the global asset tokenization market is expected to reach $16.1 trillion by 2030, indicating that building an efficient and secure RWA regulatory framework is of crucial strategic significance.
Some sources of information include:
- "Norwegian Central Bank is building a CBDC sandbox on Ethereum, having developed infrastructure prototypes"
- "Bank of England launches consultation on regulating systemic stablecoins"
- "Vietnam launches pilot work for the cryptocurrency asset market"
Author: Liang Yu Editor: Zhao Yidan
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