Article by Lulu
At the start of 2026, the Hong Kong Securities and Futures Commission (SFC) launched a series of major moves in the compliant digital asset space, directly reshaping the industry landscape of RWA (Real-World Asset Tokenization).
On February 23, the SFC announced that on February 13, it granted Esperanza Securities, a subsidiary of Yisheng Financial Technology, a license to conduct compliant tokenized securities for entertainment assets—such as the 40th anniversary Red Pavilion concert of Huang Kaichen, and offline entertainment assets like the South Korea tour of a Malaysian boy band—officially bringing them into the regulated digital securities issuance category. Qualified investors can participate in concert investments by purchasing security tokens in small amounts, sharing industry dividends.
Just one day later, on February 26, Delin Holdings announced that its projects, including Central Delin Tower, had received approval from the Hong Kong SFC to issue RWA securities.
Within seven days, two major physical asset RWAs received approval—covering entertainment IP and core commercial real estate—marking a significant breakthrough across different scenarios.
This is not just product innovation but a clear strategic signal from Hong Kong regulators: compliant RWAs are transitioning from a financial asset game exclusive to institutions to an inclusive era covering full physical industry scenarios.
For countless mainland traditional enterprises and practitioners eager to enter Web3, understanding the regulatory logic, pitfalls to avoid, and transformation pathways behind this entertainment RWA breakthrough is essential to seize the digital asset era’s opportunities in 2026.
Breaking into Cultural and Tourism RWAs: Not an Isolated Case, but a Strategic Shift in Hong Kong Regulation
The approval of Esperanza Securities’ entertainment asset tokenization has caused industry-wide震动 because it completely breaks the traditional boundaries of compliant RWAs in Hong Kong, validating a replicable path for digitalization of real assets within compliance.
Looking back at the development of RWAs in Hong Kong:
This regulatory evolution clearly demonstrates Hong Kong’s strategic core: to be a “super connector” linking Mainland China and the global market, traditional finance and digital assets, and to serve as a “gateway” for non-standard physical assets to go global.
From real estate and new energy to concerts, the core regulatory standard remains unchanged: as long as the underlying assets generate real cash flow and have clear ownership, they can be tokenized, issued, circulated, and realized within the framework of Hong Kong SFC regulation.
For mainland traditional enterprises, this signals a new era:
Your tourism scenic spots, consumer brands, agricultural assets, IP copyrights, and supply chain rights—regardless of size or sector—can leverage this compliant model to reconstruct asset value, broaden financing channels, and enhance liquidity.
Lessons from Industry Pitfalls: 3 Core Dead Ends to Avoid in Transformation
While entertainment RWAs open new doors, we must also face the painful lessons of 2025—particularly the collapse of pure financial fixed-income debt models, exemplified by some new energy RWAs, which ultimately failed due to business model issues.
These lessons are critical pitfalls that all traditional enterprises must avoid when transitioning to Web3.
The core paradox of pure fixed-income debt models lies in the mismatch between Mainland China and Hong Kong interest rate environments.
Assets acquired in low-interest Mainland China and financed in high-interest Hong Kong require projects to deliver a 9%-12% overall return to attract qualified investors. However, infrastructure assets like charging stations and photovoltaic projects typically yield only about 7% annually. After deducting on-chain audits, IoT maintenance, legal compliance costs, and other rigid expenses, the interest margin nearly disappears, making the business model fundamentally unviable.
A complete Hong Kong compliant RWA issuance process costs over HKD 2.5 million just for legal, technical, and licensed underwriting setup.
This means that if the underlying asset scale is below RMB 300 million, the “cost reduction and efficiency” strategy is a false proposition. After the cross-border filing system is implemented in 2026, cross-border RWA business with securities attributes must be operated by licensed financial institutions. The service threshold will focus on enterprises with annual revenue of RMB 100 million to RMB 1 billion and stable cash flows. Small and medium-sized enterprises rushing in blindly will only be overwhelmed by high costs.
All RWAs deeply tied to physical infrastructure face an ultimate growth dilemma: the mismatch between online consensus explosion and offline rights realization.
When community user numbers grow from 10,000 to 100,000, you cannot instantly build 10,000 charging stations. The slow pace of traditional infrastructure deployment fundamentally stifles asset explosive potential.
Moreover, the fixed-income debt model for RWAs primarily appeals to holders who want to hold until maturity for principal and interest, with no secondary trading demand. Even with 12 licensed trading platforms in Hong Kong, effective liquidity cannot be formed, and these assets often become exclusive wealth management tools for institutional clients.
2026 Transformation Path: 4 Compliant Tracks for Different Enterprises
The breakthrough in entertainment RWAs points us toward the core direction for traditional enterprise Web3 transformation in 2026: shifting from virtual to real, from “financial gambling” to “consumer engagement,” and from “fixed income” to “user rights.”
Based on asset attributes and regulatory logic, we categorize four detailed compliance tracks. Different enterprises, depending on size and sector, can precisely choose their transformation path.
This is the only core battlefield where consumer goods companies, cultural IP holders, and tourism projects can participate compliantly with low barriers. It is also the most replicable logic of this entertainment RWA.
The core idea is “selling usage rights without selling equity,” avoiding securities regulation red lines, with no high compliance thresholds, no need for licensed underwriters, and allowing market entities to operate compliantly. Especially suitable for consumer brands, cultural IP, and tourism projects with annual revenues in the tens of millions.
Mainland China model: “Buy products, get digital assets”—a de-financialized approach that strips away financial attributes, strictly prohibiting promises of returns or dividends. Digital assets only represent consumption rights or scarce rights (e.g., blind boxes, fan rights, IP merchandise). Secondary trading is limited to licensed cultural exchange platforms. Examples include digital assets for Brain Platinum’s ear coffee, Miao Ke Lando’s consumer rights, and Shaanxi “Qin Xiaoguo” fruit purchase with digital assets—proven successful cases. New gameplay includes external incubation of subsidiaries and token-stock linkages with listed companies.
Overseas model: Designed for cultural/brand/consumer going global, centered on “selling digital rights,” with usage rights tokens (Utility Tokens) issued and traded on compliant platforms with high liquidity. Through a “profit buyback and burn” deflationary model, assets appreciate, cleverly avoiding the “Howey Test” for securities regulation, while also cultivating private domain brand users and increasing overseas revenue.
This track corresponds to the traditional fixed-income RWA model, most affected by the new cross-border filing regulations in February 2026, representing the “mainstream” arena.
The core is earning cash flow dividends from the assets themselves. Cross-border securitization of domestic assets must undergo SFC approval, suitable only for enterprises with annual revenue of RMB 100 million to RMB 1 billion and stable cash flows. High compliance costs and interest rate environments make this a game for giants; small and medium enterprises should avoid rushing in.
Examples include Ant Financial’s new energy RWA, Hong Kong private equity fund RWA, and early 2026 Deli Real Estate RWA and Esperanza entertainment asset tokenization RWA—each approved by the Hong Kong SFC as compliant financial investment RWAs.
Represented by digital RMB, USD stablecoins, and gold tokenization, this track’s core functions are as a payment tool and value measure, aiming for 1:1 stability anchoring, with no promises of dividends. It forms the valuation foundation of the entire RWA sector.
Only licensed financial institutions can participate; ordinary enterprises and individuals have little room to enter.
The upcoming Hong Kong stablecoin license in March 2026 will be a licensed institution’s exclusive domain, difficult even for internet giants.
Relying on Mainland data asset policies, only state-owned and listed companies can participate, tokenizing high-quality internal data assets, establishing rights on-chain, and valuing them. After collateralization, they can apply for low-interest loans from banks.
This track is essentially a strategic showcase of industrial digital transformation, with market-based institutions and individual entrepreneurs rarely involved—an archetypal “national team” track.
The continuous compliance initiatives by the Hong Kong SFC in 2026 have thoroughly opened the era of digitalization for physical assets.
The breakthrough of entertainment RWAs is not about traditional companies blindly investing in concerts but understanding a core logic: Web3 is not a magic wand but an amplifier; the core value of RWAs is not just putting unprofitable assets on-chain to raise money but transforming valuable physical assets into digital forms to connect users, amplify value, and increase liquidity.
For traditional enterprises, the opportunity in 2026 is not to follow the hype around RWA concepts but to find compliant paths suited to their asset attributes, avoiding pitfalls experienced by giants, and achieving from zero to one with minimal costs.
Bailu Conference and many partners, both in Hong Kong and Mainland China, will accompany every physical enterprise owner holding real assets and sustainable cash flows, as well as every aspiring Web3 practitioner, to navigate each step of compliant transformation in Web3.
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