The value of this hub lies not only in providing a trading venue but also in building a complete ecosystem covering asset securitization, compliant issuance, pricing and trading, leveraged financing, and cross-border settlement.

On February 6, 2026, the China Securities Regulatory Commission (CSRC) issued the \”Regulatory Guidelines on Overseas Issuance of Asset-Backed Security Tokens for Domestic Assets\” (CSRC Announcement [2026] No. 1), which for the first time provided a clear official path for domestic assets to go overseas to issue Real World Asset (RWA) tokens.

This document, known as \”opening the front door,\” not only clearly defines RWA but also incorporates it into the existing regulatory system based on the principle of \”same business, same risk, same rules.\” The market generally believes that this marks the official launch of a trillion-dollar wave of asset digitization going overseas.

Faced with this slowly opening \”front door,\” finding a safe, compliant, and efficient overseas \”landing point\” has become a common topic for all domestic institutions intending to issue RWA. At this time, the market’s attention has focused on Hong Kong.

As one of the jurisdictions in the world that clearly allows licensed Virtual Asset Trading Platforms (VATP) to engage in \”tokenized securities\” related businesses, Hong Kong’s role is far from the past \”channel\” or \”window,\” but in the new chain of \”domestic assets, overseas issuance, and compliant trading,\” it has been upgraded to an indispensable comprehensive hub.

I. From \”Optional Channel\” to \”Essential Hub\”: The Role Upgrade of Hong Kong VATP

In the past, the path for domestic assets to go overseas mostly relied on traditional financial centers. However, the essence of RWA tokenization is the deep integration of finance and blockchain technology, and its issuance, custody, trading, and settlement all require new infrastructure. Hong Kong happens to fill this gap.

The regulatory framework of the Hong Kong Securities and Futures Commission (SFC) has clearly included \”tokenized securities\” in the scope of tradable assets of licensed VATP. This means that a compliant Hong Kong VATP can not only provide transaction matching like traditional exchanges but also has the full-process capabilities to handle on-chain assets.

Hong Kong platforms will play the role of a \”comprehensive hub for the entire chain,\” with the full-process capabilities from \”listing, custody, trading to secondary trading and liquidity matching.\” This judgment has been confirmed by the legal practice community.

Lawyer Mao Jiehao, a partner at Munckin Law Firm, analyzed that from the perspective of overseas issuance of domestic assets, Hong Kong should be the \”preferred choice for domestic asset tokenization,\” which includes packaging assets into Hong Kong with a suitable structure, tokenizing them in Hong Kong, and then listing and trading them on compliant exchanges in Hong Kong.

Hong Kong, with its rich experience in virtual asset regulation, can serve as both the trading terminal for asset-backed tokens and the core hub for more Web3.0 application scenarios in the future. The establishment of this \”hub\” role stems from Hong Kong’s unique \”dual advantages\”: it is backed by the huge pool of high-quality assets in mainland China and has a clear policy window; it also holds a compliant license widely recognized by the international capital market and has established a mature common law financial judicial environment.

A spokesperson for EX.IO Group described it as a \”super connector\” and \”super value-added person,\” a two-way springboard for mainland industries to \”go global\” and overseas capital to be \”brought in.\” This role is difficult for other financial centers such as Singapore and Dubai to replicate.

II. Portrait of the First Batch of \”Going Overseas\” Entities: Securitized Assets and Digital Pioneers

The new regulations divide RWA into equity, asset securitization, and foreign debt, and clarify the corresponding regulatory jurisdiction. So, which type of assets will be the first and largest to go overseas through Hong Kong VATP?

Digital assets with successful precedents are also favored. Lawyer Mao Jiehao pointed out that \”new energy, a highly digitized asset,\” will be given priority because it \”has had a complete structural link and has already entered the regulatory field of vision in Hong Kong.\”

This points to the world’s first batch of government tokenized green bonds issued by the Hong Kong government in 2023 and 2024. The success of these projects not only verified the technical path but also completed regulatory coordination, paving the way for the digital overseas expansion of subsequent similar assets (such as infrastructure revenue rights and ESG-related assets).

The observations of market practitioners point to assets with a high degree of standardization and clear regulatory logic. A spokesperson for EX.IO Group pointed out that the RWA projects they have contacted are mostly \”securities-type assets.\”

This type of asset has a mature issuance and trading mechanism, and the mainland policy clearly states that asset securitization activities based on the ownership and income rights of domestic assets are regulated by the CSRC, which makes the regulatory framework for related RWA clear and provides relatively certain expectations for cross-border compliant issuance. Therefore, securities-type assets are likely to be the first and largest to go overseas through Hong Kong VATP.

Whether it is traditional securitized assets or emerging digital assets, their common point is that the underlying assets are clear, the cash flow is predictable, and the compliance requirements are relatively clear. They will provide a solid \”basic foundation\” for Hong Kong VATP’s initial product line and attract the first batch of international professional investors seeking stable returns.

III. The \”Base\” of the Hub: The Completeness of Infrastructure and Shortcomings to be Addressed

The expected influx of massive assets poses a realistic test to Hong Kong’s VATP system and financial infrastructure. At present, Hong Kong has laid a good foundation.

As of July 2025, the Hong Kong Securities and Futures Commission (SFC) has formally licensed 11 digital asset trading platforms and is processing another 9 applications. The Hong Kong SFC is also constantly optimizing the system. In the circular in November 2025, it relaxed the 12-month operating record requirement for professional investor tokens and clarified the relevant regulatory requirements for tokenized securities to promote product innovation.

Lawyer Mao Jiehao pointed out a more forward-looking regulatory link: \”What needs to be supplemented or strengthened at present may mainly be that the Hong Kong SFC clearly opens up the possibility for such tokens to be traded on compliant exchanges.\” Although the policy direction is clear, the specific operating rules and listing standards for each type of asset (especially equity) still need to be finalized by the regulatory authorities as soon as possible to provide the market with undisputed certainty.

However, to undertake mainland RWA assets on a large scale and in batches, the current infrastructure still needs to be strengthened. A spokesperson for EX.IO Group pointed out several key links:

The first is the ability to conduct cross-border compliance reviews, which requires the establishment of more refined and standardized docking rules for the confirmation of rights, valuation, information disclosure, and KYC/AML processes of mainland underlying assets.

The second is the construction of special systems such as virtual asset custody and RWA issuance, which must ensure that on-chain tokens and off-chain assets form a perfect closed loop in law and operation to prevent any form of \”de-anchoring\” risk.

The last is global liquidity connection, which requires improving the market-making mechanism and attracting global capital so that Hong Kong can truly form a deep and dynamic RWA secondary market.

IV. \”Compliant Leverage\” Meets \”Real Assets\”: Catalyzing a Liquidity Revolution

The margin trading that Hong Kong VATP is about to be approved to carry out is generally considered to be a \”key catalyst\” for activating the value of the hub. Against the background of the influx of RWA compliant assets, the combination of \”compliant assets\” and \”compliant leverage\” will produce a profound chemical reaction.

For RWA assets with different characteristics, the meaning of leverage is also very different. Lawyer Mao Jiehao gave a brilliant distinction: if it is a bond or a token supported by the future cash flow of assets, its value is stable. After the introduction of leverage, it is more likely to create an active collateral lending market, focusing on the efficiency of capital utilization.

If it is an equity token, combined with 24/7 uninterrupted trading and efficient clearing and settlement of compliant leverage, it can truly release its price discovery and capital appreciation potential and attract more professional institutions such as hedge funds and high-frequency traders to enter the market.

For trading platforms, this means a qualitative change in service capabilities. If VATP can carry out margin trading, it will have the opportunity to provide Prime Broker (PB) services.

In the past, in the crypto world, PB business was difficult to develop due to the lack of a stable regulatory path. Now, under the compliant framework, traditional financial institutions can enter this ecosystem through VATP, bringing huge traditional funds and liquidity to the Web3 world, significantly increasing the scale and efficiency of asset on-chaining.

The introduction of this layered and refined financial instrument is a reflection of the maturity of traditional finance. It will enable Hong Kong’s RWA market to get rid of the single \”hold to maturity\” model and form a multi-level capital market including spot, leverage, and derivatives (possibly in the future), thereby generating huge attraction for global asset management institutions.

V. Crossing the Regulatory Corridor: The Most Complex Practical Nodes

The new policy has constructed a framework of \”domestic regulation and overseas issuance,\” but how funds can compliantly cross borders and how products can be connected between the two places has become the most challenging practical link.

Fund repatriation is one of the core challenges. The new regulations clearly state that the repatriation of relevant raised funds is managed by the State Administration of Foreign Exchange. Lawyer Mao Jiehao pointed out that in practice, the methods of fund repatriation mainly rely on existing channels such as QFLP (Qualified Foreign Limited Partner), FDI (Foreign Direct Investment), and QFII (Qualified Foreign Institutional Investor).

The key is that different repatriation methods need to be matched with different asset legal structures, and there may be policy differences in the implementation level of different provinces and cities, which requires \”finding a suitable place for design.\” This requires the issuing entity to have deep cross-border financial practical experience.

For the issuing entity, another major difficulty is how to efficiently connect the dual requirements at home and abroad. Cooperating with a licensed VATP that is familiar with Hong Kong regulatory rules and has a dedicated RWA project team is a pragmatic choice for rapid launch.

For example, by establishing a standardized docking list and timetable, clarifying the documents, time limits, and responsible entities for each link, and establishing a normalized communication mechanism, it can effectively coordinate issuers, trading platforms, and regulatory agencies in both places to promote the successful implementation of the project.

It is worth noting that the issuance of tokens does not necessarily take place directly on VATP and may be completed through other compliant structures. Therefore, the role of Hong Kong VATP in this process, in addition to providing a trading venue, is more reflected in providing overseas compliance certificates and transaction records that meet international standards for domestic filing, becoming a bridge connecting regulatory trust between the two places.

VI. The Future Competitive Landscape: Trust Building is the Ultimate Challenge

Standing at a new starting point, Hong Kong has occupied a unique commanding height in the Asian RWA ecological competition with its dual advantages of \”China policy window\” and \”international compliance license.\” The mainland has a large number of high-quality assets in the Asia-Pacific region, while Hong Kong has a mature financial environment and leading virtual asset regulatory capabilities. The combination of the two has great potential.

However, opportunities always coexist with challenges. The challenges come from the competition from other financial centers, such as Singapore’s traditional advantages in private equity and wealth management, and Dubai’s aggressive policies in attracting global crypto capital. But the bigger challenge may come from itself.

As Lawyer Mao Jiehao said, the most critical challenge is \”how to build a real asset chain that overseas funds can understand, trust, and have no concerns about.\” This is far more than just technology or rules, but a systematic trust project.

It requires: Extreme transparency: The information disclosure standards of underlying assets must reach or even exceed the level of traditional financial markets. Sound legal closed loop: Ensure that every right mapping link from off-chain assets to on-chain tokens is solid and can withstand cross-border judicial tests. Professional ecological collaboration: Lawyers, auditors, asset appraisal agencies, custodian banks, and other traditional financial intermediaries need to fully integrate and understand this new system.

The China Securities Regulatory Commission’s \”opening the front door\” for domestic RWA to go overseas is a landmark regulatory innovation. It did not choose to start anew but incorporated new things into the existing regulatory framework, reflecting the wisdom of \”seeking progress while maintaining stability.\”

In this historic process, Hong Kong has stood out from many candidate locations due to its unique balance between compliance and innovation, and its role has been upgraded from a \”transfer station\” in the past 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 securitization, compliant issuance, pricing and trading, leveraged financing, and cross-border settlement.

Whether it can successfully undertake this wave depends on whether Hong Kong can quickly strengthen the shortcomings of financial infrastructure, and more on whether all parties in the market can work together to build a \”real asset chain\” that global capital can understand, trust, and dare to participate in.

The completion of this chain will not only be a victory for Hong Kong’s virtual asset market but will also mark the deep integration of traditional finance and blockchain technology under the escort of regulation, entering a new and imaginative stage of development.

RWA Research Institute will continue to pay attention to this integration process, record and promote the market to move forward steadily and far in compliance and innovation. (The views in this article are a combination of interviews with spokespersons of EX.IO Group and Lawyer Mao Jiehao, a partner at Munckin Law Firm, and cite publicly available authoritative information. There are risks in the market, and investment needs to be cautious.)

[RWA Research Institute]