Token化ファンドがセカンダリ市場での流通を開放！香港SFCの新政策が、どのようにしてグローバルなオンチェーン金融の発展を促進するのか？
- 核心的な見解：香港は「ステーブルコイン条例」とSFC（証券先物取引委員会）の新たな枠組みを通じて、RWA（現実資産のトークン化）商品に対し、初めてコンプライアンスに則ったセカンダリ流通チャネルを提供し、オンチェーン金融市場の実現を推進しています。その進捗は、スピードと実行の面で米国や欧州などの主要経済国をリードしています。
- 重要な要素：
- 香港は2026年4月20日に新たな規制を発表し、SFCが認可したトークン化投資商品の、認可取引プラットフォームにおけるセカンダリ市場での取引を初めて許可し、それらに金融商品としての属性を与えました。
- 2026年3月末時点で、香港では13のトークン化商品が一般公開され、運用資産総額は107億元に達し、前年同期比で約7倍の増加となりました。
- 香港金融管理局（HKMA）は、碇点金融科技（Anchor Point FinTech）と匯丰銀行（HSBC）に対し、ステーブルコイン発行事業者ライセンスを発行し、RWAの決済にコンプライアンス基盤を提供しています。
- 中国人民銀行デジタル通貨研究所と香港金融管理局は、デジタル人民元とステーブルコインのリアルタイム交換に関する共同テストを実施し、クロスボーダー取引の時間を2時間から3分に短縮、コストを20%以上削減しました。
- 米国SECとCFTCの共同声明では、トークン化資産は証券の範疇に属すると明確に定義し、5つの資産カテゴリに分類。EUのMiCA法案は2024年12月に発効し、統一されたライセンスと市場参入ルールを提供しています。
- 米国とEUの規制実務（OCCのライセンス発行が銀行の不満を招いた事例、MiCAにおける越境運営の規制裁定取引リスクなど）は、香港にとって教訓を提供しており、機関間のコンプライアンスコストとリスク監視のバランスを取る必要があります。
Original Author: ShirleyLi, Researcher at Web3Caff Research
Compliance Note: The following content is solely an objective analysis of the latest regulatory strategies in Hong Kong SAR, China, and globally regarding RWA, stablecoins, and other areas. It does not constitute any proposal or offer. Please be aware that issuing or investing in Tokens involves varying degrees of stringent legal requirements and restrictions in different countries and regions. Notably, issuing Tokens in mainland China may constitute "illegal issuance of securities," and providing cryptocurrency trading-related services such as matching orders is also considered "illegal financial activity" (Readers in mainland China are strongly advised to read Summary and Key Points of Laws and Regulations Related to Blockchain and Virtual Currencies in Mainland China). Therefore, please refrain from making relevant decisions based on this information and strictly adhere to the laws and regulations of your country or region, refraining from any illegal financial activities.
RWA (Real World Assets) refer to the process of tokenizing traditional financial assets like bonds, funds, and real estate onto the blockchain, creating digital certificates that can be transferred and settled on-chain. This mechanism not only provides more efficient paths for the issuance and circulation of traditional financial assets but also introduces these assets into the Web3 financial system, forming new product combinations with stablecoins and on-chain finance. Consequently, the market potential of the RWA track is drawing significant attention from industry participants.
However, there are significant differences between the traditional financial system and the Web3 financial system in terms of trading mechanisms, settlement models, and regulatory structures. This means that the large-scale implementation of RWA requires not only solving universal issues at the infrastructure level but also heavily relies on the refinement of regulatory frameworks and the improvement of institutional norms.
Against this backdrop, since Hong Kong SAR submitted the "Stablecoin Ordinance Bill" at the end of 2024, the overall pace of regulatory advancement has noticeably accelerated.
On May 30, 2025, Hong Kong SAR officially passed the "Stablecoin Ordinance," establishing a clear regulatory framework for the issuance and operation of stablecoins. This framework, on one hand, establishes a licensing system for stablecoin issuers, and on the other hand, sets forth systemic requirements for licensed institutions regarding capital adequacy, reserve asset management, risk control, and operational compliance, laying a regulatory foundation for stablecoins to become trusted settlement tools for on-chain transactions (Further reading: Hong Kong Passes Stablecoin Ordinance Bill: What Impetus Will It Provide for Global Stablecoin Compliance and the Internationalization Strategy of the RMB?).
On April 10, 2026, the Hong Kong Monetary Authority (HKMA) granted stablecoin issuer licenses to Anchorpoint Digital Finance Technology Limited and The Hongkong and Shanghai Banking Corporation Limited under the Stablecoin Ordinance. [1]
On April 20, 2026, the Securities and Futures Commission of Hong Kong SAR (SFC) further announced a new regulatory framework, explicitly allowing for the first time the circulation of tokenized investment products in the secondary market. The core direction of this framework includes: allowing SFC-authorized open-ended tokenized funds to circulate; permitting related products to be traded on SFC-licensed trading platforms (over-the-counter forms may be allowed in specific cases). This means that SFC-recognized tokenized products have obtained a compliant secondary market circulation channel for the first time, signifying that they possess the attributes of financial products.
On the product front, Hong Kong SAR Legislative Council Member Duncan Chiu mentioned in a speech at the 2026 Hong Kong Web3 Carnival that HashKey has already piloted an on-chain silver RWA token, HSBC has released a tokenization business roadmap, and institutions like Franklin Templeton have also issued tokenized funds in Hong Kong SAR. [2] According to SFC disclosures, as of the end of March 2026, 13 tokenized products had been offered to the public in Hong Kong SAR. The total value of assets under management for these tokenized products has grown approximately sevenfold over the past year, reaching a total value of HKD 10.7 billion. This indicates rapidly increasing market acceptance for such products. [3] Observing these data changes, the opening of circulation for tokenized assets can also be seen as a significant practice towards realizing a 24/7 on-chain financial market.
Looking globally, the relevant regulatory systems in the US and EU are also progressively becoming clearer.
In the US, the "Guiding and Establishing National Innovation for US Stablecoins Act of 2025" (GENIUS Act) was officially signed in July 2025. This act aims to establish a comprehensive framework for stablecoin issuance and regulation, clearly defining requirements for issuer qualifications, asset reserves, and compliance standards. Meanwhile, the "Clarity for Digital Assets Act" (Clarity Act) is under Senate consideration, which seeks to provide standardized guidance for the market through unified on-chain asset classification and regulatory rules. (Further reading: US Senate Passes GENIUS Stablecoin Act: What Major Changes Await Web3 and RWA?, US CLARITY Act Under Scrutiny: Are DeFi-Friendly Approaches, Asset Classification, SEC-CFTC Power Sharing, etc., Becoming a Turning Point for Clearer Crypto Regulation?)
In March 2026, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) issued a joint statement classifying on-chain assets into five types: digital commodities (Cryptocommodities), digital collectibles (NFTs), utility tokens, payment tokens (stablecoins), and digital securities. It explicitly stated that tokenized assets fall under the securities category. This provides a reference for further establishing regulatory boundaries for various asset types.
In the EU, the "Markets in Crypto-Assets Regulation" (MiCA) came into effect in December 2024. By establishing a unified regulatory framework, MiCA provides clear licensing regimes and market access rules for businesses like trading platforms, custody services, and stablecoin issuance. The latest Digital Asset Tax Transparency Act (DAC8 Directive) also took effect on January 1, 2026. It requires on-chain asset service providers to disclose detailed information about users' assets and transactions to national tax authorities and share this information. This means tax authorities can exercise open and transparent supervision over the holding, trading, and transfer of Web3 assets, similar to how they treat Web2 bank accounts.
It is thus evident that the on-chain asset regulatory frameworks of major global economies are taking initial shape, showing a trend towards greater clarity and more specific classification.
Comparison of on-chain financial regulatory frameworks across Hong Kong SAR, the US, and the EU. Created by ShirleyLi, Researcher at Web3Caff Research.
However, overall, the regulatory frameworks in the US and EU primarily focus on standardizing the operation of on-chain financial markets, clarifying asset nature, and classification. In contrast, Hong Kong SAR places greater emphasis on promoting the practical implementation of on-chain financial markets. This direction is highly consistent with the previously released "Fixed Income and Money Market Development Roadmap" by the SFC and HKMA. This roadmap emphasizes the strategic positioning of "Hong Kong SAR as a global fixed income and money center." Naturally, the regulatory strategies concerning stablecoin licenses, RWA asset issuance, and circulation are also integral parts of Hong Kong SAR's asset regulatory framework.
Notably, at the end of February this year, the Digital Currency Research Institute of the People's Bank of China and the HKMA jointly launched a special test for cross-border RWA settlement using the Digital RMB (e-CNY). Using agricultural product trade and cross-border infrastructure as contexts, this test validated the real-time exchange and settlement capability between the Digital RMB and stablecoins licensed (or pending license) in Hong Kong SAR. It successfully reduced the time for traditional cross-border transactions from 2 hours to 3 minutes, with cost reductions exceeding 20%. [4] This breakthrough further reveals the feasibility of synergistic operation between the Digital RMB and compliant stablecoins. (Further reading: Market Pulse Analysis: Interpreting the Cross-Strait Integration Signal via the "Digital RMB International Operations Center" – Mainland China Provides the Foundation, Hong Kong Provides the Market)
However, the regulatory practice journeys of the US and EU also offer valuable references for Hong Kong SAR. For instance, at the end of last December, the US Office of the Comptroller of the Currency (OCC) granted trust bank charters to five Web3 companies, including Circle, Ripple, and BitGo, allowing them to legally participate in on-chain financial activities. This move, however, sparked dissatisfaction from the traditional banking sector. [5] Traditional banks argued that the compliance responsibilities and costs borne by them and licensed Web3 institutions are not equivalent, and there exists a competitive relationship between them in business. The EU's MiCA regulation stipulates that on-chain asset service providers only need a license in one member state to operate across the entire EU. This cross-border passability could lead to risks of license misuse or regulatory arbitrage.
For Hong Kong SAR, these cases provide important lessons and caution. On one hand, as Hong Kong SAR vigorously promotes the implementation of its on-chain financial system, it needs to clearly define the boundaries of responsibilities between traditional financial institutions and Web3 institutions to avoid issues of unbalanced compliance obligations and costs. On the other hand, it needs to strengthen supervision over the actual operations of licensed institutions while establishing effective risk monitoring mechanisms to ensure the security of user assets and achieve sustainable market development. Nonetheless, overall, the global regulatory system for on-chain finance is still in an exploratory phase, and its integration process with traditional finance requires long-term observation.
Key Points Structure Diagram:
References
[1] HKMA Issues Two Stablecoin Issuer Licenses
[4] Hong Kong Stablecoins + Digital RMB: A “Fast Lane” for Mainland Assets Going Overseas?
[5] Traditional Banks' Turf Under Threat? US Banking Sector Plans to Sue OCC Over Crypto Licenses
[6] Understanding the New SFC Rules in One Article: Tokenized Funds Can Be Bought and Sold Like Stocks
[7] Circular on Secondary Market Trading of Tokenized SFC-Authorized Investment Products
Disclaimer
This report is prepared by Web3Caff Research. The information contained herein is for reference purposes only and does not constitute any forecast, investment advice, proposal, or offer. Investors should not rely on such information to buy or sell any securities, cryptocurrencies, or adopt any investment strategy. The terminology used and views expressed in this report are intended to help understand industry trends and promote the responsible development of the Web3 and blockchain industry. They should not be interpreted as definitive legal opinions or the views of Web3Caff Research. The views in this report reflect only the personal opinion of the author as of the stated date, are independent of the position of Web3Caff Research, and are subject to change based on subsequent circumstances. The information and views contained in this report are derived from proprietary and non-proprietary sources deemed reliable by Web3Caff Research, but do not purport to be comprehensive, and their accuracy is not guaranteed. Therefore, Web3Caff Research makes no warranty, express or implied, regarding their accuracy or reliability, and assumes no liability for errors or omissions arising in any other manner (including liability for negligence towards any person). This report may contain "forward-looking" information, which may include predictions and forecasts. This document does not constitute a guarantee of any forecast. Whether to rely on the information contained in this report is entirely at the reader's own discretion. This report is for reference only and does not constitute investment advice, a proposal, or an offer to buy or sell any securities, cryptocurrencies, or adopt any investment strategy. Please strictly adhere to the relevant laws and regulations of your country or region.
