Original Author: ShirleyLi, Researcher at Web3Caff Research
Compliance Notice: The following content is merely an objective analysis of the latest regulatory strategies in mainland China and globally concerning RWA, stablecoins, and related fields. It does not constitute any proposals or offers, and please be aware that the issuance and investment participation in Tokens is subject to varying regulatory requirements and restrictions of different severity across different countries and regions. Especially, the issuance of Tokens in mainland China is suspected of "illegal issuance of securities," and providing Token transaction matching or other cryptocurrency trading-related activities also falls under "illegal financial activities" (readers from mainland China are strongly advised to read the "Consolidation and Key Points of Laws and Regulations Related to Blockchain and Virtual Currency in Mainland China"). Therefore, please do not make related decisions based on this information, and ensure strict compliance with the laws and regulations of your country or region, and do not engage in any illegal financial activities.
RWA (Real World Assets Tokenization) refers to the process of converting traditional financial assets such as bonds, funds, and real estate into digital certificates that can circulate and settle on the blockchain through blockchain technology. This mechanism not only provides higher efficiency in the issuance and circulation paths of traditional financial assets but also allows these assets to be integrated into the Web3 financial system, thereby forming new product combinations with stablecoins and on-chain finance. Thus, the market potential contained in the RWA sector is gaining significant attention from industry participants.
However, notable differences exist between the traditional financial system and the Web3 financial system in aspects such as transaction mechanisms, clearing models, and regulatory structures, indicating that the large-scale realization of RWA will require addressing generic issues at the infrastructure level and will heavily rely on the refinement of regulatory frameworks and the improvement of institutional norms.
In this context, since submitting the "Stablecoin Regulation Draft" at the end of 2024, the overall pace of regulatory advancement in Hong Kong has significantly accelerated.
On May 30, 2025, Hong Kong officially passed the "Stablecoin Regulation," establishing a clear regulatory framework for the issuance and operation of stablecoins. This framework establishes a licensing system for stablecoin issuers on one side while systematically requiring licensed institutions to maintain capital adequacy, reserve asset management, risk control, and operational compliance, laying the regulatory foundation for stablecoins to become reliable settlement tools in on-chain transactions (further reading: How Will Hong Kong's Passage of the "Stablecoin Regulation Draft" Propel Global Stablecoin Compliance and RMB Internationalization Strategies?).
On April 10, 2026, the Hong Kong Monetary Authority issued stablecoin issuer licenses to Dingdian Financial Technology Co., Ltd. and Hongkong Shanghai Banking Corporation Limited based on the "Stablecoin Regulation." [1]
On April 20, 2026, the Securities and Futures Commission of Hong Kong (referred to as SFC) further released a new regulatory framework, clearly allowing tokenized investment products to circulate in the secondary market for the first time. The core direction of this framework is: to allow circulation of open tokenized funds recognized by the Hong Kong SFC; to allow the relevant products to be traded on trading platforms holding SFC licenses (in some cases, over-the-counter formats may be made available). This means that tokenized products accredited by the SFC have, for the first time, gained compliant channels for secondary circulation, indicating that they possess attributes of financial products.
On the product level, during a speech at the 2026 Hong Kong Web3 Carnival, Hong Kong Legislative Council member Qiu Dagen mentioned that HashKey is currently trialing on-chain silver RWA Tokens, HSBC has released a roadmap for tokenization business, and institutions like Franklin Templeton have also issued tokenized funds in Hong Kong. [2] According to disclosures from the SFC, as of the end of March 2026, there have been 13 tokenized products sold to the public in Hong Kong, with the total asset value managed by these tokenized products growing approximately sevenfold within the past year, reaching a total value of 10.7 billion Hong Kong dollars, demonstrating the rapidly increasing market acceptance of such products. [3] From these data changes, the opening process for the circulation of tokenized assets can be considered an important practice toward a 7x24-hour real financial market on-chain.
Looking globally, the relevant regulatory frameworks in the United States and the European Union are also becoming progressively clearer.
In the United States, the "2025 U.S. Stablecoin Innovation National Guidance and Establishment Act" (referred to as the GENIUS Act) was officially signed into law in July 2025. This act aims to establish a comprehensive framework for stablecoin issuance and regulation, explicitly defining the qualifications, asset reserves, and compliance standards required for issuers. The "Digital Asset Market Clarity Act" (referred to as the Clarity Act) is also under deliberation in the Senate, focusing on providing standardized guidance to the market through unified classification and regulatory rules for on-chain assets. (further reading: The GENIUS Stablecoin Act Passed by the U.S. Senate, What Major Changes Will Web3 and RWA Welcome?, The U.S. Clarity Act is Under Review; Are Measures Favorable to DeFi, Asset Classification, Decentralization of SEC and CFTC Becoming a Turning Point for Crypto Regulation Clarity?)
In March 2026, the U.S. Securities and Exchange Commission (referred to as SEC) and the U.S. Commodity Futures Trading Commission (referred to as CFTC) issued a joint statement categorizing on-chain assets into five types: cryptocommodities, NFTs, utility tokens, payment tokens, and digital securities, explicitly stating that tokenized assets fall under the category of securities. This also provides a reference basis for further establishing regulatory boundaries for various asset types.
In the European Union, the "EU Crypto Asset Markets Regulation Act" (referred to as MiCA) came into effect in December 2024. This act establishes a unified regulatory framework and provides clear licensing systems and market access rules for trading platforms, custody services, and stablecoin issuance. The latest Digital Asset Tax Transparency Act (referred to as DAC8 Directive) also came into effect on January 1, 2026, requiring service providers of on-chain assets to disclose detailed user asset and transaction information to national tax authorities and to share this information. This means that tax authorities can regulate the holding, trading, and transfer of Web3 assets in an open and transparent manner similar to that of Web2 bank accounts.
Thus, it is evident that the regulatory framework for on-chain assets within major global economies has initially taken shape, showing a trend towards increased clarity and more defined classifications.
Comparison of On-Chain Financial Regulatory Frameworks in Hong Kong, the United States, and the European Union, created by ShirleyLi, Researcher at Web3Caff Research
However, on the whole, the regulatory frameworks in the United States and the EU primarily focus on regulating the operation of on-chain financial markets, clarifying the nature and classification of assets, while Hong Kong places greater emphasis on promoting the practical realization of on-chain financial markets. This direction aligns closely with the previously released "Roadmap for the Development of Fixed Income and Money Markets" by the Hong Kong SFC and HKMA. This roadmap highlights Hong Kong's strategic positioning as "the global center for fixed income and currency," and the regulatory strategies related to stablecoin licenses and the issuance and circulation of RWA assets naturally form an important part of Hong Kong's asset regulation framework.
It is noteworthy that the Digital Currency Research Institute of the People's Bank of China and the Hong Kong Monetary Authority jointly initiated a special test for cross-border RWA settlement using digital RMB at the end of February this year. This round of testing utilized agricultural product trade and cross-border infrastructure as carriers, validating the real-time exchange and settlement capabilities between the digital RMB and compliant stablecoins awaiting licensing in Hong Kong (currently, two companies have obtained formal licenses), successfully reducing the time required for traditional cross-border transactions from 2 hours to 3 minutes and cutting costs by more than 20%. [4] This breakthrough further reveals the feasibility of collaborative operation between digital RMB and compliant stablecoins. (further reading: Market Pulse Analysis: The "Digital RMB International Operation Center" Signals to Cross-Strait Integration, the Mainland as the Foundation, and Hong Kong as the Market)
However, the regulatory practices of the United States and the EU also provide important lessons for Hong Kong. For instance, the Office of the Comptroller of the Currency (referred to as OCC) issued trust bank licenses to five Web3 companies including Circle, Ripple, and BitGo at the end of last December, allowing them to legally participate in on-chain financial activities. However, this action triggered dissatisfaction among traditional banks. [5] This is because traditional banks believe that the responsibilities and costs they must bear in compliance are not equal to those of Web3 licensed institutions and that there is a competitive relationship between the two at the business level. Meanwhile, the EU's MiCA Act stipulates that on-chain asset service providers only need to obtain a license in one member country to operate throughout the EU, which may lead to risks of license abuse or regulatory arbitrage.
For Hong Kong, these cases provide significant reference and caution. On one hand, while fully promoting the establishment of an on-chain financial system, Hong Kong needs to clarify the boundaries of responsibilities between traditional financial institutions and Web3 institutions to avoid issues of imbalanced compliance obligations and costs; on the other hand, it is also necessary to strengthen the supervision of the actual operations of licensed institutions while establishing effective risk monitoring mechanisms to ensure the safety of user assets and achieve sustainable market development. However, overall, the current regulatory system for on-chain finance globally remains an exploratory phase, and its integration with traditional finance requires long-term observation.
Key Structure Diagram:
References
[1]Hong Kong Monetary Authority Issues Two Stablecoin Issuer Licenses
[4]Are Hong Kong Stablecoins + Digital RMB a "Fast Track" for Mainland Assets Going Abroad?
[5]Has the Bank's Cake Moved? U.S. Banking Industry Plans to Sue OCC to Block Crypto Licenses
[7]Circular Regarding the Trading of Tokenized SFC-Approved Investment Products in the Secondary Market
Disclaimer
This report is compiled by Web3Caff Research, the information contained is for reference only and does not constitute any predictions, investment advice, proposals, or offers. Investors should not rely on such information for the purchase or sale of any securities, cryptocurrencies, or for any investment strategies. The terms and expressions used in the report aim to facilitate the understanding of industry trends and promote the responsible development of Web3, including the blockchain industry, and should not be interpreted as definitive legal opinions or the positions of Web3Caff Research. The views in the report represent the personal opinions of the author as of the date stated and are unrelated to Web3Caff Research's position and may change with subsequent developments. The information and views contained in this report come from proprietary and non-proprietary sources that Web3Caff Research believes to be reliable, but do not necessarily cover all data, nor guarantee its accuracy. Therefore, Web3Caff Research does not provide any form of assurance of its accuracy and reliability and does not bear responsibility for any errors and omissions arising in any other way (including liability for any person arising from negligence). This report may contain "forward-looking" information, which may include predictions and forecasts, and this document does not constitute a guarantee of any predictions. Whether to rely on the information contained in this report is entirely at the reader's discretion. This report is for reference only and does not constitute investment advice, proposals or offers for the purchase or sale of any securities, cryptocurrencies, or for taking any investment strategies; please ensure strict compliance with the relevant laws and regulations of your country or region.
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