China's RWA regulatory stance has been officially set: the true compliance path behind "domestic ban, overseas registration".

On February 6, 2026, Chinese regulators released a clear yet complex signal. The China Securities Regulatory Commission (CSRC) issued the "Guidelines for the Supervision of Domestic Assets Issuing Asset-Backed Securities Tokens Overseas," and on the same day, the People's Bank of China, together with eight other ministries, issued Document No. 42 of 2026. Many might simply interpret the title as "another crackdown on virtual currencies." However, a thorough reading reveals that this is not a simple containment, but rather a restructuring of the regulatory framework. More precisely, this marks the first time China has formally separated RWA (Real-World Asset Tokenization) from the "gray area" of virtual currencies and incorporated it into the securities regulatory system. The significance of this event is far more profound than the market has discussed.



I. The core shift in regulatory logic: from "complete rejection" to "categorized management"
Over the past few years, China's stance on crypto assets has been very clear: virtual currency trading, token issuance financing, and stablecoin activities are all strictly prohibited. Document No. 42 continues this stance: virtual currencies still lack legal tender status, and domestic trading activities remain completely banned.

But the key change is that RWA is now defined separately. The document explicitly states for the first time:
Real-world asset tokenization refers to the activity of converting asset ownership, income rights, etc. into tokens or rights certificates with token attributes through encryption technology or distributed ledger technology, and then issuing and trading them.

This represents a significant breakthrough in regulatory language. It means that regulators no longer simply categorize "all on-chain assets" as cryptocurrencies, but rather acknowledge the reality of RWA as a financial structure. This is not a policy loosening, but rather a refinement of regulation.

II. The dual-track system is officially established: domestic prohibition and overseas filing. The most crucial sentence in this policy can be summarized as follows:
Unauthorized RWA activities are prohibited within China; the issuance of tokens by domestic assets overseas is subject to a registration system.
This is the "dual-track system".

Track 1: Domestic RWA activities must rely on "specific financial infrastructure" and obtain legal approval from the relevant regulatory authority. In other words, finance is a licensed industry. RWA is not prohibited in China, but it must be conducted on a regulatory-approved platform. Any activity without approval or compliant infrastructure is considered illegal financial activity.

The second track: The real breakthrough lies here overseas. For domestic assets issuing asset-backed securities tokens (RWAs) overseas, the regulatory approach is a "registration system," not an approval system. As long as the conditions are met and complete materials are submitted, the China Securities Regulatory Commission (CSRC) will complete the registration process and make it public. This means that for the first time, Chinese assets have a clear institutional path for tokenizing RWAs through overseas structures. It's no longer a gray area, but an institutionalized exit.

Three or four red lines: Compliance boundaries are clearly defined. The regulatory guidelines also set four inviolable red lines:
1. Assets that are prohibited by law from being financed through the capital market.
2. Involves national security risks
3. There are significant ownership disputes.
4. Included in the negative list for domestic asset securitization

These four red lines are essentially consistent with the logic of traditional securities regulation. In other words, RWA is not an "innovation privilege," but rather it is incorporated into the traditional securities regulatory framework. This is a prerequisite for regulatory approval.

IV. Where is the real path to compliance?
Combining the two documents, a practical path can be clearly identified:

1. Asset side
· Clear ownership
• Real cash flow
Not on the negative list
• Not involving national security sensitive industries

2. Structural end
• Establish an overseas SPV
• Clarify the legal correspondence between the right to income and the law.
• Establish an audit and disclosure mechanism

3. Regulatory End
• File with the China Securities Regulatory Commission
Submit complete issuance materials
• Clarify the domestic controllers and their joint liability.

4. On-chain issuance
• Compliant Custody
• The liquidation structure is legal
• Investor suitability management
Anti-money laundering system

This is a complete securities-level compliance project. It's not as simple as "issuing a cryptocurrency".

V. The real signal the policy is sending is not that China is embracing cryptocurrencies. It's that China is embracing "asset tokenization" in its own way. The crackdown on virtual currencies continues. Speculative financing continues to be banned. Unapproved RMB stablecoins are still not permitted. But the key is that regulators are willing to provide institutional channels for genuine assets, securities logic, and compliance structures.

VI. Practical implications for the industry: For asset owners: The gray era is over. Without registration, there is no legal path.
For the market: RWA is moving from narrative to institutional engineering.
For industry professionals: the future competition won't be about concepts, but rather:
• Asset screening capabilities
• Compliance structure capabilities
• Cross-border regulatory understanding
• On-chain issuance and execution capabilities



VII. GFM RWA Service System: From Asset Review to Issuance and Implementation. Under 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.

The rules of the game for RWA in China are clear: the gray areas are disappearing, and a compliant structure is the only way out. RWA is no longer about conceptual arbitrage, but rather an institutional engineering project within the regulatory framework. When regulations become clear, the real opportunities are just beginning.


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.