China's "Document No. 42" and RWA's Regulatory Restructuring

China has long maintained a highly cautious attitude regarding the changes and regulatory issues surrounding digital assets over the years. Risk warnings and regulatory documents concerning virtual currencies have primarily focused on "preventing financial risks." However, the wording appearing in relevant policies and regulatory documents dated February 6, 2026, is sparking industry discussion: Is RWA entering a new regulatory framework?



The so-called "Document No. 42" is widely interpreted as a continuation of efforts to strengthen risk prevention and control of virtual assets. However, it's worth noting that the regulatory logic is shifting from simple "prohibition" to a more refined classification and differentiation. The regulatory objectives remain unchanged, but the methods are maturing.

In the current context, it is essential to distinguish between three concepts: cryptocurrency speculation, on-chain asset trading platforms, and asset tokenization financial structures. In the past, these three were often conflated. Now, regulators are emphasizing that their risk sources, structural attributes, and governance methods differ accordingly.

This provides a practical basis for discussing the RWA pathway for assets within China. Direct token issuance within China is virtually impossible, but the possibility of cross-border structuring is being re-examined. The key is not "issuing tokens," but rather how assets can be compliantly transformed into financial modules that can be understood by international capital.

Several feasible paths can be observed at present:
First, the offshore SPV structure. After domestic assets have undergone compliant registration and auditing, an offshore special purpose vehicle is established, and issuance and trading are completed in a regulatory-friendly jurisdiction. The core challenge of this structure lies in foreign exchange compliance and cash flow transparency.
Secondly, Hong Kong serves as a bridge. Hong Kong possesses VASPs and a securities regulatory framework, enabling it to act as a transit and custodian. However, the pathway must be clear and the legal coverage comprehensive; otherwise, the risks are extremely high.
Third, commodity-based or supply chain finance assets. Compared to pure financial assets, assets with a physical basis or trade attributes are easier to understand and accept from a regulatory perspective.

It is important to clarify that RWA is not a tool for circumventing regulation, but rather a structural engineering project that must be embedded within the regulatory system. Asset ownership verification, audit disclosure, investor suitability, and anti-money laundering mechanisms are prerequisites for all such approaches.

Recent policy documents from the China Securities Regulatory Commission (CSRC) emphasize serving the real economy and controlling risks. This means that, theoretically, there is room for regulation in structures that genuinely serve industry and are supported by real cash flow. However, speculative token financing will still not be legalized.



Over the next three years, the key variables for Chinese RWAs going global will focus on three points: foreign exchange coordination mechanisms, Hong Kong regulatory details, and legal classification standards for digital assets.

The industry should neither be blindly optimistic nor overly pessimistic. Institutional evolution is often slow, but once the direction is determined, structural windows will gradually open.

The real opportunity lies not in high-profile publicity, but in the structural details and understanding of systems. If RWA is to become a bridge for Chinese assets to enter the global capital market, it must be a compliance project, not a financial narrative.

A sober assessment suggests that it is too early to talk about "full liberalization".
However, it is not accurate to say that it is "completely closed off".
The author is more inclined to believe that:
China will allow the existence of offshore RWA pathways that are "structured, auditable, and have controllable risks".
But disorderly financing will never be allowed.
This is a kind of institutional balance.

Interactive discussion: What do you think is the biggest challenge in the overseas expansion path for Chinese RWAs?
A. Foreign exchange supervision
B. Confirmation of Asset Ownership
C. Investor Protection
D. Policy uncertainty: Feel free to leave a comment and tell us your judgment.

GFM RWA Service System - Focusing on RWA Compliance Issuance and Cross-border Structure Design. In the current regulatory environment, RWA is no longer a "technology project" but a cross-border financial compliance project.
The GFM RWA service team possesses comprehensive end-to-end compliance capabilities, including:
• Due diligence and risk assessment of underlying assets
• Review of asset ownership and cash flow structure
Overseas SPV structure design
• Preparation of filing materials and regulatory coordination with the China Securities Regulatory Commission (CSRC)
• Legal compliance coverage and cross-border audit coordination
• On-chain issuance architecture design
• Connecting primary market offerings with investors

We understand regulatory language, capital market logic, and the practical implementation of on-chain clearing and token structures.

GFM Reminder : This article is a compilation of industry research findings based on publicly available information and interim observations. It does not constitute legal or investment advice. Regulations in different regions are updated rapidly, and implementation guidelines may change depending on the regulatory body. For specific business applications, please conduct further due diligence, in conjunction with legal advice and local licensing requirements.