Written by: Liang Yu
Edited by: Zhao Yidan
In late February 2026, a commercial building located at 92-96 Wellington Street in Central Hong Kong is undergoing a profound transformation from physical space to digital rights. This commercial property, known as "Delin Building," previously had its value reflected in a unit price of over 25,300 Hong Kong dollars per square foot and its geographical location just a five-minute walk from the International Financial Centre; in the near future, its ownership will be divided into countless digital tokens that can circulate in compliance with regulations.
On February 26, Delin Holdings Group Limited (01709.HK) announced that its two RWA (Real-World Assets) tokenization products have received a "No Objection Letter" from the Hong Kong Securities and Futures Commission (SFC). This marks the formal regulatory approval for Hong Kong's first real estate RWA project. The two approved projects include a limited partnership fund (LPF) that holds the Delin Building in Central Hong Kong and a limited partnership fund that invests in private equity projects like Animoca Brands.
Globally, the underlying asset categories of RWA are quite diverse, ranging from private credit, listed equity to commodities, among others. However, past tokenization explorations in Hong Kong have focused more on financial products. Although in 2023, Bank of Taiwan collaborated with Ripple to promote a real estate tokenization plan during the Hong Kong Monetary Authority's digital Hong Kong dollar pilot program, truly established RWA cases in traditional fields have been rare. Therefore, when physical assets in the Central Business District embark on the path of compliant tokenization, the industry's focus extends far beyond just the technical act of "going on-chain."
This is not merely an innovation in corporate financing; it is a key move in Hong Kong's chess game for the global RWA center status. It showcases a replicable compliance methodology to the market and provides the first regulatory-verified "compliance benchmark" for the integration of traditional commercial real estate and digital finance.
1. How Did the Regulators Approve It? Insights from the "No Objection Letter" on Hong Kong’s Approval Logic
On February 24, 2026, a "No Objection Letter" from the Hong Kong SFC officially granted regulatory approval for Delin Holdings' two RWA tokenization plans. The recipients of this letter include Delin Securities and Delin Digital Family Office, and the business plans involved are the distribution of RWA tokens and the tokenization of the fund equity managed by them.
The choice of the "No Objection Letter" as a regulatory tool itself reveals the SFC's approval mindset. It is neither a license nor a formal authorization document, but rather a declaration from the regulatory body indicating "no opposition" to a specific business plan. The advantage of this method lies in its flexibility—allowing innovation projects to land while maintaining dynamic control over risks through case-by-case approval rather than blanket rules during an early exploratory stage of RWA that lacks mature precedents.
From a regulatory framework perspective, Hong Kong's regulation of RWA follows a penetrating principle of "same business, same risks, same rules." This means that the regulatory body first determines the legal nature of the token—if the token represents securities or fund equity, then that project must fall under the regulatory scope of the Securities and Futures Ordinance, fulfilling corresponding disclosure obligations and requiring the operator to operate with a license. In the Delin project, Delin Digital Family Office holds a Type 9 (Asset Management) license, and Delin Securities holds a Type 1 (Securities Trading) license, which forms the compliance basis for advancing their tokenization business.
Notably, both of the approved assets adopt a limited partnership fund (LPF) structure. The LPF holding the Delin Building and the LPF investing in Animoca Brands are already recognized by Hong Kong law as fund vehicles. Tokenization does not create a new asset category but serves as a digital representation of existing fund equity. This dual-layer structure of "traditional assets + technical shell" aligns closely with the definition of "tokenized securities" outlined by the SFC in its 2023 circular regarding intermediaries engaging in tokenized securities activities—where the underlying assets remain subject to existing regulations, and the technology layer must meet additional disclosure and compliance requirements.
In terms of the approval timeline, Delin Holdings first disclosed its RWA tokenization plan in October 2025 and received a no objection letter in February 2026, taking about four months. This timeline is not considered long in the field of financial innovation, reflecting the Hong Kong regulatory body's balance between prudence and efficiency. For subsequent institutions hoping to engage in RWA, the approval process of the Delin project provides a communicative reference model: it is necessary to clarify the legal attributes of the assets, ensure licensed operations, establish a complete technical infrastructure, and investor protection measures, and then conduct sufficient preliminary communications with the regulators.
On the technical implementation level, the Delin project chose the HashKey Chain blockchain protocol and XRP ledger for token issuance, with technical support provided by Asseto Fintech, a tokenization comprehensive solution provider. This marks the first use of a dual-chain parallel technical solution in real estate RWA projects by a licensed institution in Hong Kong, considering both the regulatory friendliness of the compliance chain and the liquidity and ecosystem access capabilities of the public chain.
2. Why "Central Business Estate"?
The Delin Building is located at 92-96 Wellington Street in Central Hong Kong, approximately a five-minute walk to the International Financial Centre and about seven minutes to Landmark. This commercial building was developed by Capital Strategies Real Estate, and Delin Holdings acquired all units on its top five floors and naming rights in 2023 for over 280 million Hong Kong dollars, with a price per square foot of over 25,300 Hong Kong dollars. So, why would Hong Kong's first real estate RWA choose such a building? There are multiple considerations behind this.
First is the scarcity of the asset and the consensus on its value. Central is Hong Kong's core commercial district, with very limited land supply, and high-quality commercial properties have long been regarded as "hard assets" by international capital. This consensus on the value of such assets transcends cycles and borders, providing a natural trust base for the value of the tokens. In the world of digital finance, trust is the real scarce resource, and Central real estate is precisely the embodiment of trust.
Second is the clarity of the asset ownership. As a single property, the ownership structure of the Delin Building is relatively simple, and since Delin Holdings directly owns part of the floors, it avoids complex shared ownership or layered ownership disputes. This clear ownership relationship clears legal obstacles for subsequent tokenization and rights distribution. According to the common process for issuing RWAs, confirming the ownership of the underlying assets is the first and most crucial step—only after legally confirming ownership off-chain can asset mapping on-chain occur.
Third is the moderate scale of the asset. The purchase price of 280 million Hong Kong dollars implies that the entire building is valued in the hundreds of millions of Hong Kong dollars. This scale is large enough to attract the attention of institutional investors while not being excessively large, making it feasible to complete the entire process verification in the pilot phase. If an ultra-large asset worth tens of billions is chosen right from the start, the cost of trial and error would be prohibitively high.
More importantly, the Delin project does not involve a direct transfer of property rights but tokenizes the equity of the limited partnership fund (LPF) holding the building. This structural design is quite clever: LPFs are recognized by Hong Kong law as fund vehicles, and the transfer and division of their shares have a mature legal basis; through this intermediate layer of LPF, it avoids the complex procedures of directly disposing of property rights while enabling standardized asset division.
From an investment perspective, the goal of this tokenization is not merely financing but to provide qualified investors with a new tool for low-threshold allocation of core Hong Kong assets. In the past, the threshold for investing in an entire floor of office space in Central typically required hundreds of millions of Hong Kong dollars, which excluded most investors. With the tokenization of LPF shares, this threshold can be reduced to tens of thousands of dollars or even lower, greatly broadening the potential investor base.
From the perspective of industry evolution, the asset selection of the Delin project provides a "selection standard" that can reference subsequent RWA projects: the asset itself must possess scarcity and a consensus on value, have a clear ownership structure, be appropriately valued, and be able to achieve risk isolation through SPV or fund vehicles. Assets meeting these criteria could become candidates for the next wave of RWA, whether in Hong Kong or other markets.
It is worth noting that another approved asset in the Delin project—the LPF investing in Animoca Brands—represents another type of RWA: tokenization of private equity assets. Unlike real estate assets, the valuation of private equity is more complex and has poorer liquidity, but tokenization allows for the division and transfer of shares as well. The simultaneous approval of these two types of assets sends a signal to the market: Hong Kong’s regulatory attitude toward RWA is not limited to a specific asset class but is based on the principle of "substance over form," maintaining an open stance toward various assets that meet compliance requirements.
3. The Mainland Has Issued Regulations, Hong Kong Has Approved Projects, How Do the Two Regions Coordinate Rules?
The landing of the Delin project coincides with a key macro time node. Recently, the People's Bank of China and eight other departments jointly issued a "Notice on Further Preventing and Disposing of Risks Related to Virtual Currency" (hereafter referred to as the "Notice"), and the China Securities Regulatory Commission simultaneously published the "Regulatory Guidelines for Issuing Asset-Backed Securities Tokens of Domestic Assets Abroad" (hereafter referred to as the "Guidelines"). These two documents are collectively referred to as the "New RWA Regulations" in the industry, which clearly state the official definition of RWA tokenization in the context of mainland China, namely, the use of encryption technology and distributed ledgers or similar technologies to convert property rights, income rights, etc., into tokens and to engage in their issuance and trading activities.
The "Notice" clarifies the regulatory principle of "same business, same risks, same rules," implementing strict regulatory measures on domestic entities conducting RWA-related business abroad. Economic Observer interprets this as "two sets of interfaces for one chess game": the mainland interface maintains the financial safety bottom line with a "negative list + responsibility chain"; the Hong Kong interface connects global capital and regulatory systems with a "compliance structure + financial infrastructure."
Under this macro layout, Hong Kong's role positioning becomes increasingly clear.
The deeper meaning of the approval of the Delin project lies in providing a perfect example for the core path of "issuing overseas assets abroad." It proves that even if the underlying assets and operational entities are both offshore (in Hong Kong), as long as they comply with Hong Kong's regulatory rules, they can gain compliance recognition and attract international capital. This clears the uncertainty along the path for the future model of "mainland assets, issued by Hong Kong, traded globally."
Industry insiders generally expect that until further clarifications are made in the mainland regulatory details, the focus for RWA issuance in Hong Kong in 2026 will still be on issuing offshore assets abroad, accelerating the exploration through commercialization. Hong Kong's existing advantages lie not only in its common law system aligned with international standards but also in that, once disputes or defaults arise, the arbitration or litigation outcomes in Hong Kong can be directly enforced in the mainland. This certainty of legal protection is a competitive barrier that other offshore financial centers, such as Singapore and Dubai, find it difficult to match.
4. One Project Is Not Enough, What Major Initiatives Should Hong Kong Undertake This Year?
The Financial Secretary of Hong Kong has repeatedly emphasized in recent public appearances the desire to make 2026 a "year of execution" for digital assets and Web3—not just to remain at the level of slogans and pilots, but to push critical aspects such as stablecoins, RWA, custody, and trading liquidity toward scalable, auditable, and sustainable market-oriented implementation.
To achieve the leap from "individual cases" to "ecosystem," Hong Kong needs to work simultaneously on multiple dimensions.
Firstly, there is a need to improve the stablecoin infrastructure. Stablecoins are the "blood" of the RWA ecosystem, performing core functions of value exchange and settlement. Hong Kong has implemented the "Stablecoin Ordinance", establishing a licensing system for fiat-backed stablecoin issuers, with the first licenses expected to be issued in March 2026. The implementation of this system will provide a compliant fiat entrance and exit channel and on-chain settlement tools for RWA transactions, filling a critical gap in the ecological loop.
Secondly, there is a need for institutional arrangements for trading depth and liquidity. The ASPIRe roadmap released by the SFC has prioritized "accessing deeper global liquidity," with subsequent measures including allowing licensed virtual asset trading platforms to access group-level overseas liquidity through "shared order books." The underlying strategic intent is to transform Hong Kong from a "qualified island" into a "compliance gateway," exchanging regulatory certainty for global order flow and market-making resources.
Thirdly, regulatory coverage is needed for key nodes such as brokerage, custody, and settlement. The Financial Secretary stated that Hong Kong is improving new licensing systems for digital asset brokers and custodians, with the goal of promoting relevant legislation this summer, thereby ensuring that regulatory oversight extends across the entire digital asset ecosystem. This aligns with Hong Kong's regulatory logic of "the same industry, the same responsibilities; the same risks, the same rules"—as products extend from trading to custody, lending, and derivatives, regulation must expand concurrently.
From a data perspective, the trend of institutional participation has already emerged. The Financial Secretary disclosed that by the end of 2024, the total digital assets custodied by the Hong Kong banking system would exceed 14 billion Hong Kong dollars, a year-on-year increase of approximately 180%; the total value of tokenized deposits reaches 29 billion Hong Kong dollars. This data indicates that institutional participation is no longer limited to the trading side but has begun entering bank custody and liability services, thereby thickening the market's "credible foundation."
Conclusion: From "One Project" to an Era
The approval of the tokenization of Delin Building holds significance far beyond just a financing innovation for one company. It represents a "map" created by Hong Kong in the competition for global RWA center status, intertwining compliance and innovation. This map clearly marks the logic of asset selection, the path of regulatory communication, the framework of technical implementation, and the nodes of risk control.
Hong Kong's role in the field of RWA can ensure risk control through licensed regulation and information disclosure mechanisms, thereby guaranteeing effective and consistent regulation. It can become a "window" for global institutional innovation and promote interconnection among international digital financial markets.
The landing of this chess piece accurately delineates the coordinates where traditional finance intersects with the digital world. It proves that under regulatory guidance, the most imaginative innovations often occur atop the oldest, most solid assets. When a Central property achieves a "digital twin," we have reason to believe that logistics warehouses in Kai Tak, infrastructure charging rights on Hong Kong Island, and even infrastructure assets in the Greater Bay Area could all become the next stars on the digital stage.
The question left for the industry is: now that the compliant "map" has been drawn, who will be the next pioneer to tread this path? The wave of RWA has just begun to lap against the shores of traditional finance. For Hong Kong, true victory does not lie in how many "firsts" it can claim, but in whether it can turn individual case experiences into replicable ecosystem rules, becoming a value hub connecting the East and the West in the new era of digital finance.
(RWA Research Institute notes: Tokenization is a technical means to enhance asset liquidity, which does not eliminate investment risk. Investors should prudently assess the quality of underlying assets, issuer credit, and market volatility, among other traditional financial risks while paying attention to innovative opportunities. This article is based on publicly available information and authoritative media reports for analysis and does not constitute any investment advice.)
Reference Materials:
1. "Caijing" Magazine. (February 27, 2026). Hong Kong Approves First Real Estate RWA Project. Sohu.
2. Jingu Wealth News. (February 26, 2026). Delin Holdings (01709.HK) RWA Tokenization Plan Receives No Objection Letter from Hong Kong SFC, Advancing Tokenization of Delin Building and Animoca Brands LPF. Securities Star.
3. Delin Holdings Group. (February 26, 2026). Voluntary Announcement Concerning the Latest Information on RWA Tokenization Business Plan for Delin Building LPF and ANIMOCA BRANDS LPF. Securities Star.
4. Yuanda Securities (Hong Kong). (February 26, 2026). Delin Holdings (01709.HK): Regulatory Milestone Achieved for RWA Tokenization Plan Involving Central Properties and Animoca Fund.
5. ChainCatcher. (February 28, 2026). Hong Kong's First Real Estate RWA Project Approved, Delin Holdings’ Two Assets Tokenization Products Launched.
6. Zhitong Financial. (February 26, 2026). Delin Holdings (01709) Now Able to Advance Tokenization and Distribution of Delin Building LPF and Animoca Brands LPF. Investing.com Hong Kong.
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