On March 6, the economic-themed press conference of the Fourth Session of the 14th National People's Congress was held as scheduled. In response to a question from a Shanghai Securities News reporter regarding the CSRC's next steps in risk prevention and strengthened supervision, China Securities Regulatory Commission (CSRC) Chairman Wu Qing elaborated on the regulatory approach. He stated that the CSRC will focus on strengthening supervision of new types of businesses. The general consideration is to promote benefits and avoid harms, standardize development, ensure effective supervision, and strictly control risks. Key measures include: emphasizing the principle of fairness, deepening and refining the supervision of high-frequency quantitative trading; issuing measures for the supervision of derivative trading, supporting legitimate and compliant risk management activities, and restricting excessive speculation according to rules; strengthening the supervision of Real World Asset (RWA) tokenization, adhering to the principle of "strict domestic prohibition, rigorous overseas management," establishing and improving regulatory rules for crypto assets, and cracking down severely on activities that use RWA as a pretext for违规 speculation and illegal financial activities.
Wu Qing particularly emphasized the need to resolutely build a "breakwater" against capital market risks by constructing a comprehensive system of regulatory rules. This statement quickly sent ripples through the fintech and digital asset sectors.
Just over a month ago, a notice jointly issued by eight departments including the People's Bank of China and the CSRC, titled "Notice on Further Preventing and Disposing of Risks Related to Virtual Currencies," for the first time provided an official definition of Real World Asset (RWA) tokenization and established the core principle of "strict domestic prohibition, rigorous overseas management." From the joint issuance by the eight departments to the specific emphasis by the CSRC Chairman at the Two Sessions press conference, the regulatory attitude towards this emerging field has been clearly presented.
For the RWA track, is this a "full stop" for development, or a "starting gun" for a new round of standardized progress? What exactly is prohibited within the "breakwater"? And outside the "breakwater," is there space for compliant exploration?
I. What Exactly is the "Breakwater" Meant to Protect Against?
To understand the regulatory stance, one must first clarify a core question: What exactly is RWA tokenization?
According to the notice jointly issued by the eight departments, the official definition is: activities that use encryption technology and distributed ledger or similar technology to convert asset ownership, profit rights, etc., into tokens or other equity/debt instruments with token-like characteristics, and to issue and trade them. This definition covers the complete chain from technological implementation to financial behavior.
Based on this, the regulation established the eight-character principle: "strict domestic prohibition, rigorous overseas management." The notice clearly states that conducting RWA tokenization activities within China, as well as providing related intermediary and information technology services,涉嫌 illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures businesses, illegal fundraising, and other illegal financial activities, and should be prohibited.
This means that any RWA token issuance, trading, and related services targeting the domestic public are legally defined as illegal financial activities. This is not the first time regulators have shown a red card to such behavior. As early as 2017, regulatory authorities explicitly prohibited Initial Coin Offerings (ICOs); in 2021, they further clarified that virtual currency-related business activities are illegal financial activities. This statement on RWA can be seen as a natural continuation of this regulatory logic.
However, it is worth noting that the notice also leaves an "opening": exceptions are made for related business activities carried out with the legal and regulatory approval of the competent business authorities and relying on specific financial infrastructure. The existence of this exception clause suggests that the regulation is not a blanket ban on RWA technology itself, but rather sets strict preconditions regarding "to whom it is issued, who operates it, and whether it is regulated."
Wu Qing's statement at the press conference further refined the regulatory focus. He specifically mentioned the need to "crack down severely on activities that use RWA as a pretext for违规 speculation and illegal financial activities." The key phrase here is "use RWA as a pretext." In other words, the regulatory target is behavior that uses the RWA concept as a banner while实质上 engaging in illegal financial activities, not the RWA technology itself.
At the same time, the regulation also sets red lines for overseas institutions providing services to entities within China: overseas units and individuals must not provide RWA tokenization-related services to domestic entities in any illegal form. This means that even if a project is registered overseas and issued overseas, as long as its service targets involve domestic entities, it同样 faces compliance risks.
From policy text to high-level statements, the message from the regulatory layer is consistent: RWA tokenization, as a new type of financial business, must be incorporated into the existing regulatory framework and cannot become a lawless zone. Those behaviors that attempt to exploit conceptual hype and profit in regulatory gray areas are the primary targets that the "breakwater" is meant to guard against.
II. Why Did Regulators Choose to "Draw the Sword" at This Time?
The密集 statements from regulators did not come out of thin air. Since the beginning of 2026, regulatory authorities in many regions have successively issued risk warnings pointing to illegal financial activities under the banner of virtual currencies, RWA, etc.
On January 16, the Hebei Financial Regulatory Bureau issued a "Risk Tip on Preventing Illegal Financial Activities,"点名 that illegal financial activities often wear various disguises, under the banners of pension, cultural tourism, cloud farming, RWA, etc. On January 30, the Yichun Market Supervision Administration in Heilongjiang Province issued a reminder to prevent illegal financial risks, also listing RWA alongside new concepts like blockchain, virtual currency, and cash-back apps, warning that不法分子 use these concepts to carry out illegal financial activities.
These risk warnings are not泛泛而谈. An article published by the People's Bank of China Hunan Provincial Branch at the end of January detailed the typical套路 of virtual currency investment scams: luring users to fake platforms with high returns, inducing large investments with small returns, and finally setting up obstacles at the withdrawal stage before absconding with the funds. Using the case of resident Lao Wang, the article illustrated that so-called "Bitcoin wealth management platforms with 50% annualized returns" are often just numbers on a backend; once a large withdrawal is attempted, one encounters "system maintenance" or unresponsive customer service.
More alarmingly, some不法分子 have begun using RWA as a new "disguise." The Hebei Financial Regulatory Bureau pointed out in its risk tip that illegal financial activities constantly innovate, with some不法分子 using "high guaranteed returns" and "quick profits" as bait to attract and deceive the public into participating in illegal fundraising, online fraud, financial pyramid schemes, and other illegal financial activities. RWA, being a relatively unfamiliar emerging concept for ordinary investors, is easily packaged by不法分子 as a "cutting-edge investment opportunity" for misleading purposes.
From an industry insider's perspective, there确实 exist some projects in the market that use the RWA concept for违规宣传. Some projects claim to have overseas physical asset backing, issuing so-called "tokenized securities," but cannot provide clear asset verification and legal guarantees. Some projects even directly solicit funds from the domestic public, promising high returns, essentially crossing the red line of illegal fundraising.
Shi Zihan, a lawyer at Beijing Dacheng Law Office and a specially appointed expert at the Law School of Zhejiang University City College, stated in a media interview that investors who find themselves potentially caught in a virtual currency investment scam can collect evidence such as promotional materials, investment agreements, payment records, WeChat chat records, and report to the public security authorities together with other investors in similar situations. This suggests that judicial crackdowns on such illegal activities are already underway.
From the regulatory perspective, "drawing the sword" at this time involves at least three considerations. The first is investor protection. Learning from past lessons, from the P2P collapse to air coin speculation, a large number of retail investors lacking professional judgment suffered heavy losses induced by high-return rhetoric. RWA involves complex cross-border, cross-market structures, making it even harder for ordinary investors to identify risks. Building a "breakwater" in advance is a necessary protective measure.
The second is preventing financial risk. The essence of RWA is combining real-world assets with digital technology. If divorced from the real value of the实体 economy and used for excessive financial leverage operations through tokenization, its risks could affect the traditional financial system through complex transmission chains. Wu Qing's mention of "restricting excessive speculation" reflects this consideration.
The third is establishing regulatory expectations. As reflected in the eight-department notice, the regulation is not prohibiting RWA technology itself, but rather establishing clear rule boundaries for this emerging business. Within these boundaries, compliant exploration can proceed orderly; outside these boundaries, illegal and违规 activities will be severely cracked down upon. This approach of "combining疏导 and堵" helps avoid the industry falling into a cycle of "chaos upon loosening, death upon tightening."
III. Under Regulation, Where are the Chinese Opportunities for RWA?
If we look at a broader perspective, we find that while mainland regulators明确 the stance of "strict domestic prohibition," the practice of RWA in the Hong Kong Special Administrative Region is迎来 substantive breakthroughs.
In late February, Hong Kong's first real estate RWA project was officially approved. Delin Holdings Group announced that its two RWA tokenization products had received "no further comments" regulatory recognition from the Hong Kong Securities and Futures Commission (SFC), allowing the relevant business plans to proceed. This means that after months of communication, the Hong Kong SFC has given the green light to this business model.
The underlying assets approved include two major parts: one is a limited partnership fund holding the Delin Building in Central Hong Kong, and the other is a limited partnership fund investing in the private equity project Animoca Brands. The Delin Building is located on Wellington Street in the core Central business district of Hong Kong, a five-minute walk from the International Finance Centre. Delin Holdings purchased the top five floors and naming rights for over HK$280 million in 2023. This is the first time实体 assets in Hong Kong's core business district have been tokenized for qualified investors.
In terms of specific implementation, Delin Securities will act as the proposed token distributor, establishing the necessary operational infrastructure and product listing processes; Delin Digital Family Office will act as the investment manager, partnering with tokenization solution provider Asseto to tokenize and issue the relevant fund interests using blockchain technology.
William Li, a partner at Delin Holdings, stated in an interview with Caijing that the project involved in-depth communication with the Hong Kong SFC from scratch and underwent months of review before receiving "no objection" regulatory recognition. "This is not just the approval of a single product, but the regulatory recognition of the RWA business model, allowing it to be further advanced."
The significance of this case lies in demonstrating a feasible path for the compliant implementation of RWA under a strict regulatory framework. The tokenization guidelines issued by the Hong Kong SFC require that tokenized products must follow existing licensing systems, ensuring investor protection measures are in place. The Delin project was approved precisely because it relies on licensed institutions, targets qualified investors, and strictly follows disclosure requirements.
This pattern of "strict mainland management, Hong Kong exploration" actually forms a strategic complementarity. Mainland regulatory guidance emphasizes risk prevention and clear boundaries, while Hong Kong, under its licensing regulation and investor protection framework, allows compliant institutions to explore for qualified clients. The latest global RWA product models, technical standards, and risk management solutions can be piloted first in Hong Kong. Their successes and failures can provide reference for future policy formulation in the mainland and other regions.
So, against the background of "strict domestic prohibition" in the mainland, is there still room for compliant participation in the RWA field?
Judging from the policy text, the phrase in the eight-department notice—"exceptions are made for related business activities carried out with the legal and regulatory approval of the competent business authorities and relying on specific financial infrastructure"—leaves theoretical space for compliant exploration. This means that if they meet regulatory requirements, obtain approval from the competent business authorities, and rely on compliant financial infrastructure, related RWA explorations are not an absolute forbidden zone.
From a practical direction, there are at least three possible paths. The first is technological innovation serving the financing of实体 enterprises. Under the current Securities Law framework, using blockchain technology to enhance the transparency and circulation efficiency of non-standard assets like supply chain finance and financial leasing属于 business process optimization rather than issuing security tokens, and carries relatively controllable policy risks. The core of such exploration lies in not touching the red line of "issuing and trading to the public."
The second is internal-external linkage using Hong Kong as a pivot. Mainland institutions can cooperate with licensed institutions in Hong Kong to issue compliant RWA products to professional investors. Such operations must strictly adhere to the firewall principle of "capital not leaving the country, assets not entering the country," ensuring no fundraising from the domestic public and no provision of trading services to the domestic market. Hong Kong's existing regulatory framework and judicial mutual recognition arrangements provide a basis for this type of cooperation.
The third is the role of technology output as "water sellers." Since issuing tokens is prohibited, providing RWA-related technical solutions, smart contract audits, and asset custody technical services to compliant financial institutions becomes a blue ocean market with lower policy risks. The mainland has abundant technical talent reserves and mature blockchain development capabilities, giving it a competitive advantage in this field.
It must be emphasized that the exploration of these paths must be based on strict compliance and regulatory communication, and absolutely does not encourage public participation in speculation. As Charles Li Xiaojia recently emphasized when discussing RWA, tokenization cannot reduce the risk of the real-world underlying assets. This statement points to the essence of the problem: no matter how innovative the technology, the quality of the asset, the cash flow of the asset, and the legal ownership of the asset始终 are the fundamental determinants of investment value.
From the joint issuance by the eight departments to the CSRC Chairman's statement at the Two Sessions, the "breakwater" delineated by regulators for RWA tokenization is now clearly visible. This "breakwater" not only blocks the stormy waves of illegal activities under the guise of concepts but also provides a stable environment for compliant exploration within the harbor.
For practitioners, the key now is not to complain about strict regulation, but to re-examine: within the existing legal framework, what kind of实体 asset circulation can RWA technology truly create value for? Should one continue to operate in gray areas, trying to bypass regulation; or return to the original purpose of serving the实体 economy,寻找 innovation space under the premise of compliance? The answer is self-evident.
The "breakwater" is not a "full stop." On the contrary, it points the way forward for the industry: only innovation that is纳入 regulatory视野, serves the实体 economy, and withstands risk testing can truly sail into broader waters. Those ships that attempt to bypass the "breakwater" and冒险 forward in the storm will eventually be swallowed by the waves.
(RWA Research Institute Note: The discussion about future paths for RWA in this article is based on logical deduction within the current regulatory framework. Any RWA-related business exploration must be conducted within the scope permitted by national laws, regulations, and financial regulatory authorities. Currently, the mainland maintains a high-pressure stance against any token issuance and financing activities targeting the non-specific public. Practitioners are urged to firmly adhere to the compliance bottom line and never test the law.)
