Overview of Global RWA Compliance Landscape: The Asset Tokenization Process under Prudential Regulation in Hong Kong

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 prior, the Hong Kong Special Administrative Region government had released the “Digital Asset Development Policy Declaration 2.0,” and the Monetary Authority also 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 issued a circular, allowing licensed virtual asset trading platforms to share global order books with compliant overseas platforms for the first time, greatly 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 digital asset development in Hong Kong: 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 regulatory regime for stablecoin issuers officially implemented by the Hong Kong Monetary Authority on August 1 has provided a crucial payment and settlement infrastructure for RWA. Moreover, 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 thousands of participants to discuss the implementation path of real-world asset tokenization.

I. Policy Declaration and Regulatory Framework: Hong Kong RWA's “LEAP” Strategy

The RWA regulatory system in Hong Kong 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 the “Stablecoin Regulations” will be officially implemented in August 2025, requiring issuers to operate with a license and comply with reserve isolation and redemption guarantee rules.

The “Policy Declaration 2.0” shows that the SAR government's governance framework for digital assets has evolved from “principle initiatives” to “institutional engineering,” marking that Hong Kong's digital asset market is entering a transformation phase from policy pilot to rule implementation, and from industry startup to ecological cultivation.

The strategic core of Hong Kong is the government's personal involvement in promoting the implementation of tokenization technology to inject a strong boost into the market. On one hand, Hong Kong is normalizing the tokenization of sovereign bonds. After successfully issuing two batches of tokenized green bonds totaling HKD 6.8 billion, the government announced that it will normalize this issuance and explore multi-currency and multi-term structures.

On the other hand, the Hong Kong Monetary Authority launched the “Ensemble Project” in collaboration 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 been further expanded recently. According to a report by the 21st Century Business Herald on November 3, Hong Kong Securities and Futures Commission CEO Ashley Alder announced at the 2025 Hong Kong FinTech Week that two new guidelines will be launched, with the core direction being to broaden global liquidity for virtual asset trading platforms and to fully open the virtual asset market to professional investors.

The new guidelines allow platforms to share the global order book with compliant overseas institutions, enabling Hong Kong investors to directly access international liquidity while attracting global funds to the region.

2. Regulatory Ecology and Division of Labor: Sandbox Mechanism and Categorized Regulation

Hong Kong adopts a dual-track mechanism of “sandbox trial + classified regulation.” The HKMA 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 CSRC classifies RWA into three categories: 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.

An article by Zhicheng Finance on October 30 further reveals the development ideas of regulatory agencies. Eddie Yue, the Chief Executive of the Hong Kong Monetary Authority, published an article in “The Banker” titled “Building Bridges for Hong Kong's Digital Economy,” announcing the launch of the next phase of the financial technology development blueprint to consolidate Hong Kong's position as an international financial center and lead the forefront of financial technology.

Yu Weiwen pointed out that the Monetary Authority will strive to establish a comprehensive digital currency framework, promoting the coordinated development of various forms of tokenized currency such as digital Hong Kong dollars, tokenized deposits, and regulated stablecoins, forming a complementary and coexisting digital financial ecosystem.

On the regulatory technology front, a report from the Hong Kong Economic Journal indicates that the Hong Kong Securities and Futures Commission has officially launched a public tender for a virtual asset transaction monitoring system, with the bid closing date set for November 7, 2025. The winning institution is expected to be determined in the first half of 2026. This tender aims to establish an efficient monitoring system by introducing advanced technology, enhancing the ability to identify and warn against unusual virtual asset trading activities.

3. Market Practices and Cases: RWA from Concept to Implementation

According to incomplete statistics from Yicai, in the past two years, more than 13 institutions have tested RWA, including well-known companies such as Langxin Group, Huaxia Fund, and Pacific Insurance, with underlying assets covering new energy equipment, financial products, and even agricultural products. Behind them stand technical supporters like Ant Group and OSL, jointly building a new pathway of “domestic assets - Hong Kong confirmation - global circulation.”

Successful cases focus on low liquidity but cash flow stable asset types. LongNew Group has put charging pile revenue rights on the Ant Chain, completing the first cross-border RWA financing in the Hong Kong Monetary Authority sandbox. The project substitutes operational data for financial statements, automatically allocating income through smart contracts, achieving 100 million yuan financing, and verifying the feasibility of cash flow tokenization for non-standard assets. Xiexin uses an 82MW household photovoltaic power station as the underlying asset, issuing tokens that represent part of the revenue rights, completing income distribution and investor settlement through on-chain smart contracts, opening up new paths 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 “Hua Xia Solana ETF” for issuance and listing on the Hong Kong Stock Exchange, marking another important development in the growth of the virtual asset market in Hong Kong. It is worth noting that although the regulatory framework in Hong Kong has allowed spot ETFs to provide staking services, this product does not include this feature in its issuance, reflecting the regulation's effort to strike a balance between promoting innovation and ensuring safety.

IV. National Central Enterprises Practice: From Pilot Projects to Large-Scale Exploration

As the policy and regulatory framework in Hong Kong gradually improves, the RWA market practice has quietly started, with the performance of Chinese central enterprises being particularly noteworthy.

The RWA project of Hong Kong China Gas showcases the innovative transformation of traditional public utility enterprises. The underlying asset chosen by the company—the 100 million HKD credit line from Mingqi— is primarily used for artificial intelligence data centers, AI IoT, and cross-border infrastructure construction. By putting loan information on the blockchain, China Gas has achieved real-time transparency of critical financial and operational data, laying the groundwork for further asset tokenization.

The Executive Director and Chief Financial Officer of China Gas stated at the project launch conference, “This RWA tokenization is a key step in the group's digital transformation. We plan to incorporate more eligible assets into the tokenization category in the next three years, with an expected total scale of up to 5 billion HKD.”

China Resources Group's China Resources Longdi focuses on the green energy sector. After participating in the Hong Kong Monetary Authority's “Ensemble” sandbox program, China Resources Longdi is developing an RWA product framework based on the revenue rights of electric vehicle charging stations. This product plans to package the future revenues from charging piles distributed across various districts in Hong Kong for tokenization, allowing investors to share in the charging service revenues by holding tokens.

COSCO Shipping Technology's “Shipping Chain” platform has entered a substantial operational phase. This shipping data platform, based on blockchain technology, has currently connected with over 200 supply chain enterprises and has processed more than 10,000 shipping orders in total. The platform creates conditions for the subsequent tokenization of cargo capacity revenue rights by digitizing shipping documents such as bills of lading and manifest.

The layout of state-owned enterprises in the RWA market in Hong Kong is not limited to individual pilots, but shows a systematic and scaled development trend.

Guotai Junan International, as a representative of traditional brokers, has made significant progress in the RWA field. According to a report by the China Banking and Insurance News on September 23, 2025, Guotai Junan International has successfully launched its first batch of structured product Tokens, including fixed income redeemable Token products and principal-protected Token products linked to US stock ETFs. This batch of products uses Ant Financial'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 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 reduces the costs of intermediary links in traditional issuances and greatly improves the efficiency of clearing and settlement, but also demonstrates the business innovation strength of Chinese securities firms after enhancing their comprehensive service capabilities in “trading, custody, consulting, issuance, and derivatives” for virtual assets.

China Pacific Insurance has achieved a “dual layout” through CPIC Asset Management Hong Kong. After launching Hong Kong's first on-chain currency fund “eStable MMF”, the scale of on-chain assets managed by the company has reached 200 million USD within three months. Meanwhile, the design of the new energy asset package in cooperation with Xiexin Technology has entered the final stage, with the first batch expected to be 300 million HKD. The CEO of CPIC Asset Management Hong Kong stated at a recent performance briefing, “The successful issuance of the on-chain fund proves the feasibility of tokenization of traditional financial products, and we will continue to explore new paths for insurance funds to participate in infrastructure investment through the RWA model.”

The dollar money market fund tokenization project of China Merchants Bank International demonstrates the value of technological innovation. This project achieves automatic clearing and settlement of fund shares through smart contracts, shortening the traditional T+2 trading cycle to nearly real-time. More importantly, the system supports multi-currency subscription and redemption in USD, HKD, and offshore RMB, providing great convenience for cross-border investors.

The digitalization practice of trade finance by Bank of China International has industry demonstration significance. The bank's blockchain-based trade letter of credit platform has processed over 100 cross-border trade financing transactions, with a total amount reaching 300 million USD. By digitizing traditional paper letters of credit, Bank of China International has shortened the business processing time from 5-7 days to within 24 hours, while significantly reducing human errors and fraud risks.

V. Real Challenges: The Triple Constraints of RWA Scaling

Despite the high enthusiasm in the market, the development of RWA business still faces three key challenges.

Regulatory barriers to cross-border capital flows have become the first key challenge. Currently, the vast majority of RWA projects intended to be issued or tested 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.

Although this structural design conforms to the operating conventions of traditional capital markets, it faces the dual challenge of capital inflow and outflow 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 from region to region.

The legal validity 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, under the RWA model, whether on-chain Tokens can represent legal rights to the underlying assets and whether this representative relationship can be recognized by the judicial system still has significant uncertainty.

The third dilemma of the RWA business lies in the ambiguity of regulatory jurisdiction and the lack of clarity in product positioning. According to reports from Hong Kong Wen Wei Po, the chairman of the Hong Kong Securities and Futures Commission, Huang Tianyou, recently stated that there are currently no specific regulations in Hong Kong governing the participation of listed companies in cryptocurrency investments.

He revealed that the Securities Regulatory Commission will continue to closely monitor market dynamics and start researching and formulating relevant guidelines to regulate such behaviors. Regarding the recent claims by some listed companies that they will adopt digital asset treasury practices, he particularly reminded investors to carefully discern the substance of DAT and its true underlying value.

6. Financing or Momentum: The Market Heat and Real Temperature of RWA

Why are many mainland companies still keen to go to Hong Kong for RWA when there are no significant advantages in terms of financing costs and financing limits?

“Rather than saying it is for financing, it is more about 'merging influence'.” An RWA information consulting intermediary told the First Financial Reporter that bank loans are relatively much cheaper, and most companies are not solely looking for financing, but rather focusing on the diverse value of RWA.

For example, paving the way for companies to go overseas, bringing brand exposure, and even promoting stock price increases. Many companies have seen a significant rise in stock prices after promoting RWA, and this “market value management” effect is referred to by some market participants as “coin-stock linkage.”

Currently, more publicly listed companies are engaged in RWA. Firstly, they can afford to pay higher intermediary fees; secondly, the issuance of RWA can not only provide financing but also bring additional brand effects related to the linkage of coins and stocks to publicly listed companies, thus giving them more motivation to pursue RWA.

However, the actual financing costs for RWA in Hong Kong cannot be ignored. According to reporters from Yicai, multiple industry insiders have revealed that the total fees for issuing RWA projects in Hong Kong generally do not fall below 2.5 million HKD, depending on the complexity of the project.

Some institutions charge a commission of 3% to 5% when sponsoring an issuance, but there are also institutions that waive this fee. In addition, the issuer must also commit to a certain investment return rate to the investors.

5. Real Challenges: The Triple Constraints of RWA Scalability

In the face of a complex regulatory environment, RWA projects need to build a comprehensive compliance framework.

Asset confirmation and underlying asset screening are the primary steps in the issuance of RWA. It is necessary to verify the ownership, income rights, and disposal rights of the assets through documents such as property certificates, purchase contracts, and invoices, and to entrust a lawyer 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.

In response to cross-border regulatory and bankruptcy risks, Hong Kong RWA projects commonly adopt a “dual-layer SPV structure”: the first layer establishes an SPV company in Hong Kong as the issuer of the Token, independently bearing legal responsibilities; the second layer controls or acquires the mainland SPV through agreements, holding the rights to the underlying asset's returns.

The architecture must ensure the risk separation of assets from the original operator and explicitly clarify the independence of each investment portfolio's assets through the articles of association.

The compliance path for cross-border data flow is equally crucial. RWA projects face stringent restrictions under Article 31 (important data going abroad) of the Mainland's Data Security Law and Article 38 (cross-border personal information) of the Personal Information Protection Law.

In compliant operations, a “dual-chain collaborative architecture” is often used: utilizing compliant domestic chains such as Ant Chain and Starfire Chain to confirm asset income rights; using the audit working papers derived from the consortium chain as a trusted data source to issue tokens on the public chain.

8. Future Outlook: Cross-Border Collaboration and Institutional Evolution

The development prospects of the RWA market in Hong Kong are broad, but a series of challenges still need to be overcome.

The core challenges currently faced include conflicts in legal definitions - the mainland classifies token financing as illegal financial activities, creating a systemic gap with the legalization and regulation in Hong Kong; contradictions between technology and legal lag - the conflict between the efficiency of blockchain cross-border flows and mainland capital controls needs urgent resolution; and insufficient cross-border judicial cooperation - the need to strengthen cross-border regulatory cooperation in the prevention and control of money laundering risks related to stablecoins.

Nevertheless, the future development of the RWA market in Hong Kong remains promising. In terms of policy upgrades, the Hong Kong Securities and Futures Commission proposed to amend the “Code on Unit Trusts and Mutual Funds” in October 2025, allowing retail funds to invest in low liquidity assets, paving the way for the tokenization of RWA.

In terms of improving technological infrastructure, the exchange tests between the digital renminbi and the Hong Kong dollar stablecoin will enhance settlement efficiency. In terms of expanding asset types, the regularization of government bond tokenization and the expansion into asset classes 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 the various financial technology innovation regulatory pilot programs in mainland China, they will become the primary breeding ground 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 the Financial Times on October 20, Chan pointed out during the International Monetary Fund and World Bank Group Annual Meetings that various economies recognize that the influence of digital assets is rapidly expanding, and related blockchain technology has been implemented in multiple real-world scenarios, particularly demonstrating its application value in enhancing trade efficiency within the region and addressing the pain points of cross-border settlement.

He emphasized that digital assets have significant development potential, but the international community must strengthen cooperation to manage the risks they may pose to global financial stability with a prudent attitude.

Hong Kong has established a globally leading RWA compliance ecosystem through a three-tiered approach of “policy declaration - regulatory sandbox - legislative protection”. Its core advantages lie in: providing technical compliance assurance through the “stablecoin regulations” and the Ensemble sandbox, while also addressing cross-border capital flow issues with a dual-layer SPV structure and QFLP channel.

With the continuous improvement of regulatory technology and the in-depth advancement 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.

Source of some information:

· Hong Kong Digital Asset Development Policy Declaration 2.0

· “Hong Kong will build a credible and innovative digital asset ecosystem”

· “Crazy Hong Kong RWA: Financing or '融势'?”

Author: Liang Yu Editorial Review: Zhao Yidan