On August 1, 2025, the (Stablecoin Regulation) officially came into effect, marking the transition of Hong Kong's virtual asset regulation from framework construction to practical implementation. This regulation not only sets clear entry thresholds for stablecoin issuance but also provides the payment settlement infrastructure for the on-chain mapping of real-world assets (RWA) through the standardization of fiat-backed tokens' settlement finality, promoting Hong Kong's advancement towards becoming a global tokenized financial center.
Coincidentally, the US (GENIUS Act) was almost simultaneously implemented, indicating that major global economies are shifting their perception of crypto infrastructure from 'speculative digital assets' to 'components of the financial system,' initiating the evolutionary path from on-chain payments to on-chain credit. According to OKG Research, if development proceeds smoothly, the global supply of stablecoins is expected to exceed $3 trillion by 2030, with annual transaction volume potentially approaching the current global GDP scale.
In addition, the recently highly anticipated global first RWA registration platform (initiated by the industry self-regulatory organization 'Hong Kong Web 3.0 Standardization Association') will also go live today (August 7), aiming to facilitate the entire process service system of data, asset, and financialization for RWA asset tokenization, marking the beginning of a new era of large-scale on-chain real assets.
In this race for infrastructure reconstruction, Hong Kong is striving to gain an advantage in the development of stablecoins and asset tokenization, leveraging its financial infrastructure heritage and policy responsiveness. This article aims to review Hong Kong's virtual asset regulatory framework, outline the evolution of RWA policies, and focus on the technological and institutional logic, key pilots, and future trends under their collaboration.
Note: This article references RWA projects that do not include on-chain ecosystems or concept projects not approved by the Hong Kong Securities and Futures Commission/Hong Kong Monetary Authority's Ensemble sandbox pilot.
Stablecoins and RWA: The Integration of Payment Systems and Value Systems
Tokenization of Real World Assets (RWA) refers to the digital representation of physical assets (such as real estate, commodities), financial assets (such as bonds, stocks), or other property rights (such as intellectual property, carbon emission rights) in the real world through blockchain technology, smart contracts, and compliance frameworks, forming tokenized certificates that can be recorded, traded, and managed on-chain. Currently, many mature RWA tokenization cases internationally (such as BlackRock's BUIDL government bond tokenization fund, Dubai Land Department tokenization platform, etc.) are mostly based on Ethereum standards for smart contract construction.
From the perspective of tokenization, stablecoins and RWA essentially stem from the same technological paradigm - that is, through blockchain's digital bookkeeping, smart contract programmability, and decentralized verification, reconstructing the ways of holding, trading, and managing traditional assets. The two respectively represent the extension of this technological paradigm across different functional dimensions: stablecoins focus on creating on-chain circulation media, while RWA focuses on constructing a value anchoring system.
Generally speaking, stablecoins (such as USDT, USDC) anchor fiat currencies or commodities, becoming 'bridge assets' that connect traditional finance with the crypto economy, sacrificing asset diversity for the stability of high-frequency trading; while RWA transforms various real assets or complex rights into programmable, divisible on-chain certificates, providing 'real support' for digital currencies. Together, they create a complete closed loop of on-chain finance, fundamentally addressing pain points in traditional financial transaction processes, such as inefficiencies (like cross-border settlements) and high thresholds (like real estate investments).
RWA Regulatory Framework: Parallel Dual-Track, Penetrative Regulation
The effectiveness of the (Stablecoin Regulations) and a series of previously implemented virtual asset regulatory policies create a synergistic effect. According to attorneys Chen Mingjie and Tang Weijia from Zhonghao Law Firm, the overall principles and framework for RWA regulation in Hong Kong include:
1. The principle of 'substance over form' (See-Through):
First, determine the underlying asset properties, focusing on the physical asset attributes behind tokenization, which do not change due to their 'on-chain' status:
Based on the Hong Kong Securities and Futures Commission's 'same business, same risk, same rules' regulatory principle, security tokens (STOs) are clearly defined as securities, subject to the (Securities and Futures Ordinance) and requiring licensed operations (such as licenses 1, 4, and 9), limited to professional investors (the mandatory requirement will be lifted in November 2023); non-security RWAs (such as carbon credits, real estate income rights) will be included in the (Anti-Money Laundering Ordinance) framework, innovating and exploring compliance paths through sandbox pilots.
Note: Although STOs and RWAs both fall under the category of asset tokenization, the primary differences, aside from regulatory compliance paths (whether recognized as securities), lie in design philosophy and underlying asset ownership structure: STOs focus on the securities field, typically representing equity or debt, with holders enjoying partial ownership and control rights over the asset, including dividends, voting rights, liquidation rights, and other statutory interests; whereas RWAs (securities/non-securities) are more focused on bringing various real-world assets onto the blockchain and are more centered on mapping the rights to income on-chain, where investors typically do not own the underlying assets but share future cash flows (such as rental income, energy revenue, etc.), thus providing more liquidity and exchange methods.
2. Collaboration and Complementarity between the Monetary Authority and the Securities and Futures Commission.
The Hong Kong Monetary Authority focuses on financial stability and payment function regulation, promoting tokenization technology trials through the Ensemble sandbox (launched in March 2024, officially entering the testing phase in August 2024) to accumulate experience and improve business processes in a controlled environment; the Hong Kong Securities and Futures Commission is responsible for capital market and investor protection regulation, clarifying product safety, information disclosure, and risk management requirements based on the 'same business, same regulation' principle.
3. Stablecoin Legislation Completes Payment Loop
The implementation of stablecoin regulations not only provides a legal basis for the application of stablecoins in the RWA ecosystem but also fills the compliance gap on the funding side of the RWA financing chain, making the flow of funds between the traditional financial system and the blockchain world smoother and safer, laying the foundation for the large-scale promotion and application of RWA projects.
Hong Kong RWA Industry Policy Context: Three-Stage Advancement, System and Pilot in Parallel.
1. Preliminary Exploration Stage (2017–2022)
September 2017: The Hong Kong Securities and Futures Commission published a statement (on Initial Coin Offerings), clearly incorporating digital token businesses that meet the definition of 'securities' into the regulatory scope, requiring licensing/registration for related businesses.
In December 2020, the Hong Kong Securities and Futures Commission officially issued the first virtual asset trading platform license, with the licensee being OSL Exchange under BC Technology Group, whose trading platform only allows services to professional investors, being Hong Kong's first compliant platform under the virtual asset regulatory framework.
October 2022: The Hong Kong government released the (Virtual Asset Policy Declaration), proposing the idea of asset tokenization and a green bond tokenization pilot program, initiating the exploration of asset on-chain and compliance.
2. Improve Regulatory System (2023–2024)
In June 2023, the Hong Kong Virtual Asset Service Provider (VASP) system was officially implemented, with platforms operating in Hong Kong before June 1 having a 12-month transition period to obtain licenses, thus laying the compliance foundation.
In November 2023, the Hong Kong Securities and Futures Commission released two important circulars - the (Circular on Tokenized Securities Approved Investment Products) and the (Circular on Intermediaries Engaging in Tokenized Securities Related Activities), emphasizing that tokenized securities are still essentially traditional securities and must comply with existing securities regulations such as the (Securities and Futures Ordinance), and the 'professional investor only' restriction was lifted.
In March 2024, the Hong Kong Monetary Authority launched the Ensemble project sandbox, focusing on exploring application scenarios of tokenization technology, with various RWA tokenization pilot projects in green bonds, supply chain finance, carbon credits, real estate, etc. successively landing.
November 2024: The Hong Kong Monetary Authority launched a digital bond funding program to encourage more financial institutions and issuers to adopt tokenization technology in capital market trading.
December 2024: The (Stablecoin Regulation Draft) was submitted to the Legislative Council for review, clarifying that issuers of fiat-backed stablecoins must obtain a license.
3. Deepen Innovative Applications (2025 to Present)
February 2025: The Hong Kong Securities and Futures Commission released the 'A-S-P-I-Re' (Access, Safeguards, Products, Infrastructure, Relationships) regulatory roadmap and 12 specific action plans, covering a new regulatory framework for virtual asset over-the-counter trading and virtual asset custody services.
On May 2025, the Hong Kong Legislative Council passed the (Stablecoin Regulations), clarifying that stablecoin issuers must be licensed institutions, ensuring full reserves, capital adequacy requirements, compliance with sales channel restrictions, etc.
In June 2025, the Hong Kong government released (Hong Kong Digital Asset Development Policy Declaration 2.0) and launched the LEAP framework, clearly identifying RWA tokenization as a core driving direction, with government bonds tokenization, self-owned assets, and financial instruments tokenization receiving policy support, emphasizing various physical asset areas such as precious metals and renewable energy.
On August 2025, the (Stablecoin Regulation) officially came into effect, with the first batch of stablecoin licenses expected to be issued as early as early 2026, and the number of initial licenses will be limited.
Hong Kong RWA Landmark Pilot and Market Cases
February 2023: The Hong Kong government issued the world's first government green bond tokens, amounting to approximately HKD 800 million, integrating the Hong Kong Bond Custody System (CMU) with Goldman Sachs GS DAP blockchain tokenization platform to enhance settlement efficiency (T+5 → T+1).
September 2023: Taiji Capital and Prince Property issued the first real estate STO in Hong Kong, opening the way for tokenization of real estate assets in Hong Kong.
In December 2023, China Asset Management successfully issued Hong Kong's first tokenized fund, aimed solely at professional investors, investing in highly rated US treasury bonds. The fund is managed by the Hong Kong subsidiary of China Asset Management, with Meta Lab HK providing tokenization solutions.
In March 2024, HSBC officially launched a tokenized gold product, being the first RWA product in Hong Kong to obtain a retail license from the Securities and Futures Commission, with the underlying asset being physical gold bars certified by the London Bullion Market Association (LBMA).
August 2024: Longxin Technology and Ant Group, based on the Hong Kong Monetary Authority's Ensemble sandbox, launched the country's first RWA based on new energy physical assets, verifying the path for cross-border asset tokenization.
February 2025: Huaxia Fund (Hong Kong) launched the Asia-Pacific's first retail tokenized fund (in HKD), supporting subscriptions and redemptions in HKD, USD, and RMB, with immediate settlement.
March 2025: Taiping Asset Management and HashKey Chain jointly launched the first on-chain money market fund by a Chinese institution, 'CPIC Estable MMF,' with subscriptions reaching $100 million on the first day.
July 2025: Delin Holdings plans to tokenize assets with a total value of up to HKD 500 million, including several rights in 'Delin Building' at 92 Wellington Street, Central, and fund asset rights.
Hong Kong-listed companies layout RWA, capital market actively responds.
Delin Holdings invests in RWA fintech company Asseto.
On August 1, 2025, Delin Holdings invested $1.2903 million in Asseto Holdings Limited, a company focusing on RWA tokenization across asset classes such as funds, bonds, stocks, and real estate. As a strategic partner of HashKey Group, Asseto's strategic industry cooperation network also includes two companies preparing to submit applications for a stablecoin license in Hong Kong.
Huajian Medical collaborates with BGI to establish an RWA fund.
On July 30, 2025, Huajian Medical and BGI CoWin jointly established the world's first innovative pharmaceutical intellectual property tokenization fund (IVD-BGI CoWin), focusing on the digital circulation of medical assets. This fund will invest in Huajian Medical's Web 3.0 exchange ecosystem projects in Hong Kong and the United States.
Fosun International's Star Road Technology completed nearly $10 million in Series A financing.
On July 30, 2025, Star Road Technology announced it received investments from Solana Foundation and other Web3 institutions to build the RWA platform (FinRWA Platform), integrating fiat currencies, stablecoins, and digital assets to provide connection solutions between traditional finance and digital assets.
Alibaba's LionCity Holdings enters the stablecoin and RWA market.
On July 28, 2025, LionCity Holdings announced the establishment of a digital finance group, led by former Standard Chartered Bank executive Zeng Jingxuan, planning to develop multi-currency stablecoins and RWA tokenization solutions, and collaborate with traditional financial institutions to build and deploy a new generation of digital payment infrastructure.
Guofu Quantum Strategy invests in RTree, deepening RWA layout.
On July 28, 2025, Guofu Quantum Strategy invested $489,000 in RTree Tech Service to promote the tokenization process of its assets, including self-owned artworks, trade receivables, letters of credit, and other supply chain assets.
Huaxing Capital plans to expand its digital asset business.
On June 26, 2025, Huaxing Capital announced an investment of $100 million to enter the Web 3.0 and cryptocurrency fields, planning to apply for an expansion of existing Securities and Futures Commission licenses (1, 4, 9) to digital asset business and increase investment in RWA assets, to support Hong Kong in becoming a global digital asset center.
