The CSRC opens the door for RWA to go global, so why has Hong Kong VATP become the essential hub?

Article by: Liang Yu

Edited by: Zhao Yidan

On February 6, 2026, the China Securities Regulatory Commission issued the “Regulatory Guidelines on Overseas Issuance of Asset-Backed Securities Tokens for Domestic Assets” (CSRC Announcement [2026] No. 1), providing a clear official pathway for domestic assets to issue real-world assets (RWA) tokens abroad for the first time. This document, dubbed the “Open the Main Door,” not only explicitly defines RWA but also incorporates it into the existing regulatory framework based on the principle of “same business, same risk, same rules.” The market generally views this as the official launch of a trillion-dollar wave of digital asset globalization.

Faced with this gradually opening “main door,” all domestic institutions aiming to issue RWA are seeking a safe, compliant, and efficient overseas “landing point.” At this moment, market attention is unanimously focused on Hong Kong. As one of the first jurisdictions globally to explicitly permit licensed virtual asset trading platforms (VATPs) to engage in “tokenized securities” activities, Hong Kong’s role has evolved from a mere “channel” or “window” into an indispensable comprehensive hub in the new chain of “domestic assets, overseas issuance, compliant trading.”

1. From “Optional Channel” to “Mandatory Hub”: Upgrading the Role of Hong Kong VATPs

In the past, outbound pathways for domestic assets relied heavily on traditional financial centers. However, the essence of RWA tokenization is the deep integration of finance and blockchain technology, requiring new infrastructure for issuance, custody, trading, and settlement. Hong Kong happens to fill this gap.

The regulatory framework of the Hong Kong Securities and Futures Commission (SFC) has explicitly included “tokenized securities” within the scope of tradable assets for licensed VATPs. This means a compliant Hong Kong VATP can not only facilitate trading matching like traditional exchanges but also handle the entire on-chain asset lifecycle. Hong Kong platforms will serve as “comprehensive hubs” capable of managing “listing, custody, trading, secondary trading, and liquidity matching.”

Legal practitioners confirm this judgment. Mao Jiehao, a partner at Mankun Law Firm, pointed out that from the perspective of domestic assets issued abroad, Hong Kong should be the “preferred choice for domestic asset tokenization,” including packaging assets into suitable structures in Hong Kong, conducting tokenization there, and listing and trading on compliant Hong Kong exchanges. With its extensive experience in virtual asset regulation, Hong Kong can serve both as a trading terminal for asset-backed tokens and as a core hub for future Web 3.0 applications.

This “hub” role stems from Hong Kong’s unique “dual advantages”: on one side, it benefits from China’s vast pool of high-quality assets and clear policy windows; on the other, it holds internationally recognized compliant licenses and has established a mature common law financial legal environment. An EX.IO Group spokesperson described Hong Kong as a “super connector” and “super value creator,” acting as a two-way bridge for mainland industries “going out” and overseas capital “coming in.” This role is difficult for other financial centers like Singapore or Dubai to replicate.

2. The First Wave of “Global Players”: Pioneers in Securities and Digital Assets

The new regulations categorize RWA into equity, asset securitization, and external debt types, clarifying their respective regulatory authorities. Which assets will be the first to go overseas via Hong Kong VATPs on a large scale?

Digital assets with successful precedents are also promising. Mao Jiehao noted that “highly digitized assets like new energy” will be prioritized because they already have complete structural chains and are within Hong Kong’s regulatory scope. This points to the success of Hong Kong’s government in issuing the world’s first government-backed tokenized green bonds in 2023 and 2024. The success of these projects not only validated the technical approach but also facilitated regulatory coordination, paving the way for digital overseas expansion of similar assets such as infrastructure revenue rights and ESG-related assets.

Practitioners observe that assets with high standardization and clear regulatory logic are most suitable. An EX.IO Group spokesperson said that most RWA projects they engage with are “securities-type assets.” These assets have mature issuance and trading mechanisms, and recent mainland policies specify that activities based on domestic asset ownership and income rights are regulated by the CSRC. This clarifies the regulatory framework for related RWA and provides relatively certain expectations for cross-border compliant issuance. Therefore, securities-type assets are most likely to be the first and largest-scale assets to go overseas via Hong Kong VATPs.

Whether traditional securitized assets or emerging digital assets, they share common features: clear underlying assets, predictable cash flows, and relatively explicit compliance requirements. These will form a solid “foundation” for Hong Kong VATP’s initial product offerings and attract the first wave of international professional investors seeking stable returns.

3. The “Foundation” of the Hub: Infrastructure Completeness and Shortcomings

The anticipated influx of massive assets poses practical challenges to Hong Kong’s VATP system and financial infrastructure. Currently, Hong Kong has laid a good foundation. As of July 2025, the Hong Kong SFC has officially licensed 11 digital asset trading platforms and is processing an additional nine applications. The SFC continues to optimize regulations; in a circular issued in November 2025, it relaxed the 12-month operational record requirement for professional investors’ tokens and clarified regulatory requirements for tokenized securities to promote product innovation.

Mao Jiehao pointed out a more proactive regulatory step: “The current need is to clarify that such tokens can be traded on compliant exchanges.” While policy direction is clear, specific operational details and listing standards for various asset categories, especially equity-type assets, still require regulatory agencies to finalize promptly to provide market certainty.

However, to scale and mass-accept RWA assets from the mainland, infrastructure must be further strengthened. An EX.IO Group spokesperson highlighted key areas: first, cross-border compliance review capabilities need to be enhanced, including detailed, standardized rules for asset rights confirmation, valuation, information disclosure, and KYC/AML processes. Second, specialized systems for virtual asset custody and RWA issuance must be established to ensure a legal and operational “closed loop” between on-chain tokens and off-chain assets, avoiding any “decoupling” risks. Third, global liquidity connectivity requires improved market-making mechanisms to attract international capital, enabling Hong Kong to develop a deep and vibrant RWA secondary market.

4. “Compliance Leverage” Meets “Real Assets”: Catalyzing a Liquidity Revolution

The upcoming approval for margin trading on Hong Kong VATPs is widely regarded as a “key catalyst” for activating the hub’s value. Against the backdrop of compliant RWA inflows, the combination of “compliant assets” and “compliant leverage” will generate profound effects.

Leverage’s significance varies with asset type. Mao Jiehao provided a sharp distinction: for bonds and tokens supporting future cash flows, which are stable in value, introducing leverage could foster an active collateral lending market, focusing on capital efficiency. For equity tokens, combined with 24/7 trading and efficient clearing and settlement, compliant leverage can unlock price discovery and capital appreciation potential, attracting hedge funds, high-frequency traders, and other professional institutions.

For trading platforms, this means a qualitative leap in service capabilities. If VATPs can offer margin trading, they can provide prime brokerage services. In the past, prime brokerage in crypto faced regulatory uncertainties. Now, under a compliant framework, traditional financial institutions can enter this ecosystem via VATPs, bringing substantial traditional capital and liquidity into Web 3, significantly increasing asset onboarding scale and efficiency.

This layered, refined financial toolset reflects the maturity of traditional finance. It will enable Hong Kong’s RWA market to evolve beyond a simple “hold-to-maturity” model into a multi-tiered capital market including spot, leverage, and derivatives (potentially in the future), greatly attracting global asset management institutions.

5. Navigating the Regulatory Corridor: The Most Complex Practical Nodes

The new policy establishes a “domestic regulation, overseas issuance” framework, but how to ensure compliant cross-border fund flows and product integration between the two jurisdictions remains the most challenging operational aspect.

Repatriation of funds is a core challenge. The new regulation clarifies that the repatriation of raised funds is managed by the foreign exchange authorities. Mao Jiehao pointed out that in practice, fund repatriation mainly relies on existing channels such as QFLP (Qualified Foreign Limited Partnership), FDI (Foreign Direct Investment), and QFII (Qualified Foreign Institutional Investor). The key is that different repatriation methods require matching different legal asset structures, and policy differences across provinces and cities may exist, necessitating “finding suitable local solutions.” This demands issuers to have deep cross-border financial practical experience.

For issuers, another major difficulty is efficiently aligning with both domestic and foreign requirements. Collaborating with licensed VATPs familiar with Hong Kong regulations and with dedicated RWA project teams is a pragmatic approach. For example, establishing standardized checklists and timelines, clarifying document requirements, deadlines, responsibilities, and setting up regular communication mechanisms can effectively coordinate among issuers, trading platforms, and regulators, facilitating successful project implementation.

It is worth noting that token issuance may not necessarily occur directly on VATPs but could be completed through other compliant structures. Therefore, Hong Kong VATPs’ role extends beyond providing trading venues; they also serve as bridges, offering compliant foreign records and transaction proofs for domestic filings, building trust between the two regulatory regimes.

6. Future Competition and Cooperation: Building Trust as the Ultimate Challenge

Standing at a new starting point, Hong Kong leverages its “China policy window” and “international compliance licenses” to occupy a unique high ground in Asia’s RWA ecosystem. Mainland China possesses a large pool of high-quality assets in the Asia-Pacific region, while Hong Kong boasts a mature financial environment and leading virtual asset regulation. The combination offers enormous potential.

However, opportunities come with challenges. Competition from other financial centers, such as Singapore with its advantages in private equity and wealth management, and Dubai with its aggressive policies to attract global crypto capital, pose threats. But perhaps the greatest challenge is internal.

As Mao Jiehao emphasized, the most critical challenge is “how to establish a transparent, trustworthy, and worry-free real asset chain that overseas funds can understand.” This involves more than technology or rules; it is a systemic trust-building project. It requires:

• Extreme transparency: disclosure standards for underlying assets must meet or exceed those of traditional financial markets.

• Robust legal closure: ensuring every rights mapping step from off-chain assets to on-chain tokens is solid and withstands cross-border judicial scrutiny.

• Professional ecosystem collaboration: involving lawyers, auditors, asset evaluators, custodians, and other traditional financial intermediaries to fully understand and integrate into this new system.

The CSRC’s move to “open the main door” for domestic RWA overseas issuance is a landmark regulatory innovation. It does not reinvent the wheel but incorporates new concepts into the existing framework, embodying the wisdom of “steady progress.” In this historic process, Hong Kong has stood out among many candidates due to its unique balance of compliance and innovation, elevating its role from a mere “transit station” to an indispensable “comprehensive hub.”

The value of this hub lies not only in providing a trading venue but also in building a complete ecosystem covering asset packaging, compliant issuance, pricing and trading, leverage financing, and cross-border settlement. Whether Hong Kong can successfully embrace this wave depends on its ability to quickly strengthen its financial infrastructure and whether market participants can work together to build a “real asset chain” that global capital can understand, trust, and dare to participate in.

The successful construction of this chain will not only mark a victory for Hong Kong’s virtual asset market but also symbolize the deep integration of traditional finance and blockchain technology under regulatory protection, entering a new stage of expansive development. The RWA Research Institute will continue to monitor this integration process, documenting and promoting the market’s steady and innovative growth.