How far has the Hong Kong RWA ecosystem come? Looking at HashKey's "one-stop" solution to see the evolution of infrastructure.

CN
12 hours ago

Written by: Liang Yu

Reviewed by: Zhao Yidan

On February 24, 2026, HashKey Group announced the launch of aRWA one-stop issuance solution. According to reports from Sina Finance, the solution aims to provide a full chain of professional services covering tokenized compliant issuance framework design, on-chain technical support, full-process issuance services, trading and liquidity management, information disclosure, and subsequent tracking and regulation for asset issuers and professional intermediaries.

The Hong Kong Special Administrative Region government has just released the "Hong Kong Digital Asset Development Policy Declaration 2.0," and the Financial Secretary, Paul Chan, clearly stated that the declaration "demonstrates the HKSAR government's vision for the development of digital assets and showcases the substantive application of tokenization through practice, promoting the diversification of application scenarios." HashKey’s solution happens to be at the intersection of policy proclamation and market practice.

This is not just an ordinary product launch. At a critical juncture where the RWA track is moving from concept to reality, HashKey seeks to answer an industry's dilemma: when high-quality assets want to comply with being on-chain, who will bridge the long chain from issuance architecture design to liquidity management? The answer this solution provides is: rather than letting every asset party explore independently, it's better to build an "out-of-the-box" infrastructure—what industry insiders call an RWA issuance "power strip."

This article will dissect the deeper logic of this solution from two main lines: the asset side and the capital side. However, before delving into the analysis, it is necessary to clarify a basic position: this solution is still in the startup phase, and its actual effectiveness remains to be tested by the market. The following analysis is more based on deducing its design logic rather than predicting outcomes. After all, in the emerging RWA track, the infrastructure has been laid down, but the real test will always be: whether there are really assets willing to come in and whether there is really capital willing to enter.

The biggest challenge of asset issuance is not technology, but compliance.

In the context of the RWA discussion, "being on-chain" is often simplified to a technical issue—choosing the appropriate token standard, deploying smart contracts, and completing token minting. However, HashKey's solution reveals a deeper truth: for regulated mainstream financial institutions, the technical aspect of "asset being on-chain" is far from the endpoint; the compliance aspect of "asset being on-chain" is the real threshold.

HashKey's solution is spearheaded by the group's specialized tokenization service agency, HashKey Tokenisation. According to reports from BlockBeats, the solution supports compliant tokenized issuance framework design based on standards like ERC-3643, as well as on-chain asset minting and management. ERC-3643 is not an ordinary ERC-20 token standard but a token protocol that incorporates identity verification, transfer restrictions, and compliance checks—only addresses that pass KYC/AML reviews can hold and trade the tokens. This means that it directly embeds regulatory requirements into the underlying code of the token, making compliance not just an off-chain additional process but an intrinsic attribute of the asset itself.

The latest practices by BNP Paribas provide a footnote to this technical route. In February 2026, the bank issued tokenized shares of a Euro money market fund registered in France on Ethereum, also choosing the ERC-3643 standard. Julien Clausse from BNP Paribas's corporate and institutional banking department explained this choice, stating that the bank intends to "leverage Ethereum's network effect, but in order to maintain regulatory compliance and operational security, access for investors remains restricted." This case signifies a growing consensus among global mainstream financial institutions: the tokenization of RWA must occur within a compliant framework; technology is merely a means to an end, not the end itself.

Of course, it is necessary to view with caution that compliant token standards like ERC-3643 cannot automatically equate to regulatory recognition. They address the technical issues of on-chain identity verification and transfer control, but questions regarding the authenticity of off-chain assets, valuation accuracy, and custody transparency are still reliant on traditional legal frameworks and audit processes. There exists a gap that needs to be continually bridged between technical compliance and regulatory compliance.

The value of the HashKey solution for asset issuers lies precisely in transforming this consensus into operable business processes. According to official disclosures, the entire service includes project due diligence, asset issuance framework design, distribution promotion, and token custody. This means that asset parties no longer need to explore compliance paths on their own, seek technical teams, or connect with exchanges—all these fragmented processes are integrated into an "out-of-the-box" infrastructure.

This reflects a profound understanding of Hong Kong's regulatory logic. Hong Kong is "treating the virtual asset market as a 'stress test field' for digital asset regulation, and RWA will be the final crop to harvest in this experimental field." On February 11, the Hong Kong Securities and Futures Commission announced a new set of regulations at the Consensus conference, establishing a three-dimensional management system of "asset classification, risk layering, and responsibility segmentation" for digital asset leveraged trading: collateral is limited to Bitcoin and Ethereum, perpetual contracts are limited to professional investors, and market-making functions are restricted to related parties, however with added firewalls. This carefully designed set of rules essentially prepares for a "regulatory stress test" for a larger-scale RWA market—if the virtual asset market can operate under manageable risks, then the larger, less volatile real-world assets are expected to enter the compliant channel along the same logical framework.

In this sense, HashKey’s solution is not merely a technical toolkit but a "compliance converter" that codifies and streamlines the regulatory rules of the Hong Kong Securities and Futures Commission. It helps dormant, non-standard "high-quality existing assets"—be it infrastructure revenue rights, private bonds, or tokenized funds—put on the compliant "garment" and gain a "passport" to access mainstream financial markets.

According to a report released by the decentralized oracle network RedStone in November 2025, the global RWA market size is projected to grow from $35 billion at that time to $50 to $60 billion in 2026, with private credit being the largest category, estimated at about $19 billion, and tokenized government bonds currently at $8.4 billion. RedStone co-founder Marcin Kazmierczak emphasized that this growth "depends on reliable infrastructure, including asset net worth calculation, liquidity adjustments, and compliance audit tracking." HashKey's solution is a market response to this judgment—building the infrastructure before demand explodes.

However, RWA has never been a unilateral project. If there is no capital response to asset on-chain, it will only create islands on the chain. Whether the solution can truly activate the capital side is the key to its success or failure.

The key question from the capital side: how to sell the purchased RWA later?

If empowering the asset side is the "foundation" of the solution, then activating the capital side is the true "superstructure." The core of this part lies in HashKey Exchange—one of the earliest licensed virtual asset trading platforms in Hong Kong.

According to HashKey's official introduction, the solution relies on HashKey Exchange to provide compliant and convenient primary market redemption channels for tokenized assets, and can support secondary market trading through on-exchange order books or over-the-counter trading methods, paired with an immediate clearing and settlement mechanism. This statement contains several key levels.

The first level is the "primary market redemption channel." This means that RWA products can directly face a vast number of professional investors through a licensed trading exchange. For traditional financial institutions, this is a crucial node—they do not need to build a subscription system on their own, nor do they need to deal with complex on-chain operations; they can complete asset allocation through familiar exchange channels. This greatly reduces the friction cost for mainstream capital entering the RWA market.

The second level is the imagination space for "secondary market trading." Although it is still in the "subject to regulatory approval" state, this phrasing itself has released an important signal. Once RWA products can be traded in secondary markets on compliant exchanges, they will no longer just be "dead assets" that can only be held until maturity, but may become tradable financial products with liquidity. This greatly expands the exit channels for traditional fixed-income investors—liquidity is a key consideration for institutions managing billions of dollars in assets as to whether or not to enter.

The third level is "DVP instant clearing and settlement." The cash-to-cash mechanism is the standard settlement model in traditional financial markets, ensuring the simultaneous completion of securities delivery and payment, thereby eliminating counterparty risk. Introducing this mechanism into RWA trading is a key step towards making tokenized assets truly possess the attributes of "financial products."

However, building a liquidity ecosystem is no easy task; it may even face a structural paradox. Data shows that tokenized gold PAXG has effective depth on both buy and sell sides of less than $3 million on Binance's spot market, where a $4 million transaction can have slippage of up to 150 basis points, while the slippage for a comparable size of gold futures trading on the Chicago Mercantile Exchange is almost negligible. This suggests that even the most mature tokenized asset categories still have a significant liquidity depth gap compared to traditional financial markets.

The deeper question is: the value of RWA is anchored in the returns of real assets, rather than the frequency of trading. For most institutional investors, the core demand for allocating RWA is to secure stable cash flows, rather than frequent trading. If secondary market liquidity becomes the sole narrative focus, it might deviate from its essence as a yield-generating asset. A risk to be aware of is that an excessive emphasis on liquidity may spur the "financial engineering" modification of RWA—transforming originally simple revenue rights into complexstructured products through layering, packaging, and re-securitization, and the lessons from the 2008 financial crisis have already taught us that such "innovation" often comes with risk transmission and regulatory arbitrage.

HashKey's solution clearly acknowledges this challenge. In addition to relying on its own exchange to provide trading channels, the solution also lists "professional intermediary institutions" as a second core client group—law firms, accounting firms, and licensed brokers in Hong Kong can provide services based on HashKey’s infrastructure and participate in the RWA ecosystem development. This is a very pragmatic ecosystem building strategy: rather than waiting for liquidity to form naturally, it is better to actively involve intermediary institutions and allow them to cultivate the market while serving customers.

Financial Secretary Paul Chan clearly stated in his new budget proposal on February 25 that the SFC "will further promote liquidity in Hong Kong's digital asset market, providing more products and services for professional investors while ensuring investor protection, and will establish an accelerator to accelerate market innovation." HashKey's solution highly aligns with this policy direction—it is precisely targeting the professional investor group and providing "more products and services," while the upcoming "RWA One-stop Issuance Service Manual" and accompanying guidelines will also serve as a form of "accelerator" to some extent.

The other half of RWA's homework: how to reassure on-chain participants about off-chain assets.

When discussing RWA, one easily overlooked but crucial dimension is that the liquidity and trading efficiency of on-chain tokens do not automatically resolve the core governance issues of off-chain assets.

How to update asset net values in real time? This is the first question all RWA products must answer. For standardized financial assets like government bonds and money market funds, NAV calculations are relatively mature and can be updated daily or even in real-time by accessing authoritative data sources. However, for non-standard assets like private credit, infrastructure revenue rights, and real estate, valuation itself is a complicated professional judgment process—it depends on regular asset appraisal reports, audit opinions, and management's financial forecasts. Accurately and timely reflecting this information on-chain requires establishing a credible "oracle" mechanism, which is precisely a topic the industry is still exploring.

How to determine auditing frequency and pathways? In traditional finance, private fund audits are typically conducted annually, but for tokenized products circulating on exchanges, the timeliness of annual audits may not satisfy the market's information disclosure requirements. More frequent audits mean higher costs, and the question of who will bear this cost and how to strike a balance between transparency and efficiency is a matter that market participants need to explore together.

How to achieve a custody penetration mechanism? The "real-world" properties of RWA dictate that its underlying assets must be held by trustworthy custodial institutions. However, how can the certificates issued by custodial institutions establish an irrevocable correspondence with the tokens on-chain? If a custodial institution encounters problems, how will the rights of token holders be protected? These questions involve the collaboration of legal, custody, and technical parties and cannot be resolved simply by smart contracts.

In this sense, the maturity of RWA requires not only the improvement of technical infrastructure but also the synchronous evolution of off-chain governance mechanisms. HashKey's solution offers complete technical and compliance support on the issuance side, but on the governance level during the asset's life cycle—how to continuously verify asset authenticity, how to timely disclose valuation changes, and how to handle defaults and extreme situations—still await validation through market practice.

Not only Hong Kong is competing for RWA: who can emerge from Singapore, Switzerland, and Dubai?

Placing the HashKey solution in a broader context reveals a deeper proposition: it is not merely a commercial layout of a single enterprise but a systematic attempt by Hong Kong to build an RWA ecosystem.

Since the publication of its first digital asset policy declaration in October 2022, Hong Kong has been exploring paths for integrating virtual assets into the mainstream financial system. According to reports from Yicai, the latest released "Policy Declaration 2.0" proposes "to construct a more robust digital asset ecosystem that integrates prudently regulated frameworks with encouraging market innovation." This statement contains two keywords: "prudent regulation" and "encouraging market innovation"—the former is the bottom line and the latter is the goal.

HashKey's solution happens to be at the intersection of these two lines. On one hand, it strictly adheres to the requirements of the Hong Kong SFC, designing "comprehensive and implementable compliance tokenized issuance programs and frameworks" to ensure that the entire process of asset tokenization aligns with the core regulatory principle of "same business, same risks, same rules." On the other hand, within the compliant framework, it explores maximum innovation—supporting multi-chain deployment, cross-chain interoperability, and introducing professional standards such as ERC-3643, reserving space for richer future application scenarios.

However, it is necessary to approach with caution whether "innovation within a compliant framework" can genuinely evolve into exportable rules, as it depends on the fulfillment of a series of preconditions. The Project Guardian led by the Monetary Authority of Singapore has attracted numerous global financial institutions, including HSBC, Standard Chartered, and DBS, since its launch in 2022, exploring tokenized bonds, foreign exchange, and asset management products. Switzerland’s SDX (SIX Digital Exchange), as a digital asset exchange regulated by FINMA, has successfully issued and traded multiple tokenized bonds. Dubai's VARA (Virtual Assets Regulatory Authority) has attracted a large number of international crypto companies with its "sandbox" model. Each of these jurisdictions has its institutional advantages and strategic positioning; for Hong Kong to stand out among them, it needs to form truly differentiated competitive strengths.

A possible path is to leverage the extensive supply of physical assets in mainland China, making Hong Kong a "RMB-denominated offshore issuance center for RWA." However, this also faces complex issues such as cross-border capital flows, foreign exchange management, and legal applicability. Hong Kong's advantage lies in its common law system aligning with international standards, while its disadvantage is that its market scale is limited, not allowing it to solely digest large-scale asset issuances.

From this perspective, being a "rule exporter" is an overly distant narrative. A more pragmatic positioning might be as a "rule reference"—if within the next three to five years, the Hong Kong RWA framework can sustainably implement cross-border projects, forming several successful cases, and achieve a balance between liquidity and investor protection, then its regulatory model and infrastructure design may have value for reference by other jurisdictions.

Another risk: when the issuer, exchange, and liquidity provider are the same entity.

One dimension worth discussing further in HashKey's narrative is: when the same group simultaneously assumes multiple roles as asset issuer service provider, trading platform operator, and liquidity provider, are there potential conflicts of interest?

In traditional financial markets, functions like issuance, underwriting, trading, and custody are usually carried out by different institutions and isolated through strict firewall systems. For example, an investment bank underwriting a company's bonds would face strict limitations on its proprietary trading department regarding transactions on the same bonds. The core purpose of this arrangement is to prevent institutions from using information advantages to harm client interests and to maintain market fairness and order.

The HashKey solution integrates the issuance side, trading side, and liquidity management side vertically, enhancing efficiency but also bringing risks of overlapping roles. When the group simultaneously serves both asset issuers (helping them design products) and investors (providing them with trading channels), how to maintain neutrality in product pricing, information disclosure, deal matching, and other elements requires transparent systems and processes to ensure. Additionally, if HashKey Exchange becomes the core trading venue for multiple RWA products in the future, it could create a certain degree of "closed ecology"—essentially, asset issuers might prefer the issuance services of this platform for liquidity support, while investors primarily execute their allocations on this platform for convenience. If this path dependence forms, it may reduce the openness and competitive vitality of the market.

The Hong Kong SFC is not unaware of this. Its previous new regulations restricting market-making functions (limiting them to related parties while implementing firewalls) have already reflected a cautious attitude toward conflicts of interest. As the RWA market develops, regulatory authorities are likely to further strengthen their penetrative supervision over licensed institutions' "multiple roles," requiring them to establish more comprehensive internal control mechanisms and information segregation measures.

Conclusion: Infrastructure has been laid; the thoroughfare awaits.

The RWA one-stop issuance solution launched by HashKey Group is a milestone-level infrastructure practice in the RWA track. It is no longer content to be just a project service provider but attempts to systematically integrate regulatory requirements, technical standards, and market entry points, allowing high-quality assets to more easily connect with the global digital financial system.

In this process, the asset side and the capital side are tightly intertwined like a double helix: compliant asset issuance attracts mainstream capital, while enhanced liquidity, in turn, reduces issuance costs and attracts more high-quality assets. If this positive feedback loop can successfully start, Hong Kong is likely to upgrade from an "explorer of a regulatory sandbox" to a "reference model for global RWA regulatory practice."

However, it is equally important to recognize that the RWA market is still in its early stages. Issues of transparency in asset valuation, standardization of audit pathways, and reliability in custody penetration—these core off-chain governance problems have yet to be fully resolved. Cultivating liquidity takes time; the compliance framework requires continuous improvement through practice; and significant resources are needed for investor education and protection. HashKey's solution provides a solid starting point, but the real test will be in execution—when the first project comes to fruition, when the first secondary market transaction is completed, and when the first unexpected incident occurs, whether this system can genuinely deliver on its promises.

The wave of RWA has just begun. As the asset side and the capital side weave closely together on a compliant track, we may witness the birth of a whole new digital financial ecosystem. But just as the evolution of any emerging market reveals: infrastructure has been laid; the thoroughfare awaits. The real test is always on the way.

References:

· "HashKey Group Announces Launch of RWA One-stop Issuance Solution"

· "Hong Kong Annual Budget: First batch of stablecoin licenses to be issued next month, establishment of digital asset platform within the year"

· "BNP Paribas Launches Ethereum Pilot Project for Tokenizing Money Market Fund"

· "The Scale of RWA Will Reach 60 Billion USD by 2026"

· "Promoting New Measures for Hong Kong Digital Asset Trading to Stimulate Market Vitality"

· "When Large Capital Gets Serious, RWA's Liquidity Issues Are Highlighted"

· "RWA Moving Towards Scaled Implementation, Why Institutions Prefer HashKey?"

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