Tokenized funds open for secondary market circulation! How is Hong Kong SFC’s new policy driving global on-chain finance development?
- Core Viewpoint: Through the Stablecoin Ordinance and the SFC’s new framework, Hong Kong has pioneered a compliant secondary circulation channel for RWA (Real World Asset tokenization) products, advancing the implementation of on-chain financial markets. Its progress leads major economies such as the US and Europe in terms of speed and execution.
- Key Elements:
- Hong Kong issued new regulations on April 20, 2026, allowing, for the first time, SFC-recognized tokenized investment products to be traded on the secondary market on licensed platforms, granting them financial product attributes.
- As of the end of March 2026, Hong Kong had 13 tokenized products available for public sale, with total assets under management reaching HKD 10.7 billion, a year-on-year increase of approximately seven times.
- The Hong Kong Monetary Authority (HKMA) has issued stablecoin issuer licenses to Dingdian Financial Technology and HSBC, providing a compliant foundation for RWA settlement.
- The Digital Currency Institute of the People's Bank of China and the HKMA jointly tested real-time exchange between the digital yuan and stablecoins, reducing cross-border transaction time from 2 hours to 3 minutes and lowering costs by over 20%.
- A joint statement from the US SEC and CFTC clarified that tokenized assets fall under the category of securities and divided them into five asset classes; the EU's MiCA Act took effect in December 2024, providing unified licensing and market access rules.
- Regulatory practices in the US and EU (such as the OCC's licensing causing dissatisfaction among banks, and the risk of regulatory arbitrage in MiCA's cross-border operations) serve as a caution for Hong Kong, requiring a balance between institutional compliance costs and risk monitoring.
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 concerning RWA, stablecoins, etc. It does not constitute any proposal or offer. Please be aware that issuing or investing in Tokens is subject to varying degrees of stringent legal requirements and restrictions in different countries and regions. Specifically, issuing Tokens in Mainland China may constitute "illegal issuance of securities," and providing services associated with cryptocurrency transactions, such as token matching, is also considered "illegal financial activity." (Readers in Mainland China are strongly advised to read "Compilation and Key Points of Laws and Regulations Related to Blockchain and Virtual Currencies in Mainland China"). Therefore, please do not use this information for any relevant decisions and strictly comply with the laws and regulations of your country or region, refraining from any illegal financial activities.
RWA (Real World Assets Tokenization) refers to the process of converting traditional financial assets such as bonds, funds, and real estate into digital certificates that can be circulated and settled on-chain using blockchain technology. This mechanism can not only provide more efficient paths for issuing and circulating traditional financial assets but also introduce these assets into the Web3 financial system, forming new product combinations with stablecoins and on-chain finance. Consequently, the market potential inherent in the RWA sector is attracting significant attention from industry participants.
However, there are significant differences between traditional financial systems and Web3 financial systems in terms of trading mechanisms, clearing models, and regulatory structures. This means that the large-scale implementation of RWAs requires not only solving general infrastructure-level problems but also highly depends on the refinement of regulatory frameworks and the improvement of institutional norms.
Against this backdrop, the pace of overall regulatory advancement in Hong Kong SAR, China, has noticeably accelerated since the submission of the "Stablecoin Ordinance Bill" at the end of 2024.
On May 30, 2025, Hong Kong SAR, China, officially passed the "Stablecoin Ordinance," establishing a clear regulatory framework for the issuance and operation of stablecoins. On one hand, this framework establishes a licensing regime for stablecoin issuers. On the other hand, it imposes systemic requirements on licensed institutions regarding capital adequacy, reserve asset management, risk control, and operational compliance, laying the regulatory foundation for stablecoins to become trusted settlement instruments for on-chain transactions (Further reading: Hong Kong Passes the Stablecoin Ordinance Bill: What Impetus Will It Provide for Global Stablecoin Compliance and the RMB Internationalization Strategy?).
On April 10, 2026, the Hong Kong Monetary Authority, under the Stablecoin Ordinance, granted stablecoin issuer licenses to Anchor Point Fintech Limited and The Hongkong and Shanghai Banking Corporation Limited. [1]
On April 20, 2026, the Securities and Futures Commission of Hong Kong (SFC) further issued a new regulatory framework, explicitly allowing, for the first time, the secondary market circulation of tokenized investment products. The core directions of this framework are: permitting the circulation of SFC-authorized open-ended tokenized funds; allowing related products to be traded on SFC-licensed trading platforms (with over-the-counter forms potentially allowed in specific cases). This means that tokenized products recognized by the SFC have, for the first time, obtained a compliant secondary circulation channel, signifying that they now possess the attributes of financial products.
On the product front, Duncan Chiu, a member of the Legislative Council of the Hong Kong Special Administrative Region, mentioned in a speech at the 2026 Hong Kong Web3 Carnival that HashKey has already piloted an on-chain silver RWA token, HSBC has published its tokenization business roadmap, and institutions like Franklin Templeton have also issued tokenized funds in Hong Kong. [2] Furthermore, according to SFC disclosures, as of the end of March 2026, 13 tokenized products had been offered to the Hong Kong public. The total value of assets managed by these tokenized products increased approximately sevenfold over the past year, reaching a total value of HKD 10.7 billion, indicating rapidly growing market acceptance. [3] Judging from these data changes, the opening of circulation for tokenized assets can also be seen as an important practice towards realizing a 24/7 on-chain financial market.
Looking globally, regulatory systems in the United States and the European Union are also gradually becoming clearer.
In the United States, the "Guiding and Establishing National Innovation for US Stablecoins Act of 2025" (GENIUS Act) was formally signed in July 2025. This act aims to establish a comprehensive framework for stablecoin issuance and regulation, setting clear rules on issuer qualifications, asset reserve requirements, and compliance standards. Meanwhile, the "Digital Asset Market Clarity Act" (Clarity Act) is currently under Senate review, seeking to provide standardized market guidance through unified on-chain asset classification and regulatory rules. (Further reading: US Senate Passes GENIUS Stablecoin Act: What Major Changes Await Web3 and RWAs?, The US CLARITY Act Under Review: Are DeFi-Friendly Measures, Asset Classification, and SEC-CFTC Power Division Becoming a Turning Point for Crypto Regulatory Clarity?)
In March 2026, the U.S. 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, Digital Collectibles (NFTs), Digital Instruments (Utility Tokens), Stablecoins (Payment Tokens), and Digital Securities. It clearly states that tokenized assets fall under the securities category. This provides a reference for further defining the regulatory boundaries of various asset types.
In the European Union, 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 such as trading platforms, custody services, and stablecoin issuance. The latest Digital Asset Tax Transparency Act (DAC8 Directive) also took effect on January 1, 2026, requiring on-chain asset service providers to disclose detailed user asset and transaction information to national tax authorities and share it. This means tax authorities can oversee the holding, trading, and transfer of Web3 assets with the same transparency as traditional Web2 bank accounts.
Thus, regulatory frameworks for on-chain assets in major global economies have begun to take shape, showing a trend towards greater clarity and more specific classification.
Comparison of On-Chain Financial Regulatory Frameworks: Hong Kong SAR, the United States, and the European Union. Produced by ShirleyLi, Researcher at Web3Caff Research.
However, overall, the regulatory frameworks in the US and EU primarily focus on standardizing on-chain financial market operations, clarifying asset nature and classification, whereas Hong Kong SAR places greater emphasis on promoting the practical implementation of the on-chain financial market. This direction aligns closely with the "Fixed Income and Money Market Development Roadmap" previously issued by the SFC and HKMA. This roadmap highlights Hong Kong's strategic positioning as a "global fixed income and money center," and the regulatory strategies related to stablecoin licenses and RWA asset issuance and circulation are naturally integral parts of Hong Kong'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 Hong Kong Monetary Authority jointly launched a special pilot test for cross-border RWA settlement using the digital yuan (e-CNY). Using agricultural trade and cross-border infrastructure projects as use cases, the test verified the real-time exchange and clearing capabilities between the e-CNY and stablecoins pending licensing in Hong Kong (two companies have now received official licenses). It successfully reduced the processing time for traditional cross-border transactions from 2 hours to 3 minutes, with a cost reduction of over 20%. [4] This breakthrough further demonstrates the feasibility of synergistic operation between the e-CNY and compliant stablecoins. (Further reading: Market Pulse Analysis: Interpreting the "Digital RMB International Operations Center" Signal for Cross-Strait Integration - Mainland China as the Base, Hong Kong as the Market)
Nevertheless, the regulatory experiences of the US and EU also offer valuable lessons for Hong Kong SAR. For example, the U.S. Office of the Comptroller of the Currency (OCC) granted trust bank charters to five Web3 companies, including Circle, Ripple, and BitGo, at the end of last year, allowing them to legally participate in on-chain financial activities. This move, however, sparked dissatisfaction from the traditional banking sector, [5] which argued that the compliance responsibilities and costs borne by traditional banks and licensed Web3 institutions are not equivalent, and that they are also business competitors. Meanwhile, the EU's MiCA regulation allows on-chain asset service providers to operate across the entire EU once licensed in a single member state, potentially creating risks of license abuse or regulatory arbitrage.
For Hong Kong SAR, these cases provide important references and cautionary tales. On one hand, as Hong Kong vigorously promotes the implementation of the on-chain financial system, it needs to clearly define the responsibilities and boundaries between traditional financial institutions and Web3 entities to avoid imbalances in compliance obligations and costs. On the other hand, it needs to strengthen supervision over the actual operations of licensed institutions and establish effective risk monitoring mechanisms to ensure the safety of user assets and achieve sustainable market development. However, overall, the current global regulatory framework for on-chain finance remains in an exploratory phase, and its integration with traditional finance requires long-term observation.
Key Points Diagram:
References
[1] Hong Kong Monetary Authority Issues Two Stablecoin Issuer Licenses
[4] Are Hong Kong Stablecoins and Digital RMB the "Fast Track" for Mainland Assets Going Global?
[5] Slicing the Banks' Pie? US Banking Industry Plans to Sue OCC over Crypto Licenses
[6] Understanding the SFC's New Rules: Tokenized Funds Can Now Be Bought and Sold Like Stocks
[7] Circular on Secondary Market Trading of Tokenized SFC-Authorized Investment Products
[10] 88EX Insight: European Regulation Escalates: ESMA Aims to Become the Sole Crypto Market Regulator
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 strategies. The terminology used and views expressed in this report are intended to help understand industry trends and foster the responsible development of the Web3 and blockchain sectors. They should not be construed as definitive legal opinions or the views of Web3Caff Research. The opinions in this report reflect only the author's personal views 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 opinions contained in this report are derived from proprietary and non-proprietary sources deemed reliable by Web3Caff Research but are not necessarily all-inclusive 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 way (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 solely 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 comply with the relevant laws and regulations of your country or region.
