Tokenized funds open secondary market circulation! How is Hong Kong SFC's new policy driving the development of global on-chain finance?
- Core Viewpoint: Through the Stablecoins Ordinance and the SFC's new framework, Hong Kong has pioneered a compliant secondary circulation channel for RWA (Real World Asset tokenization) products, accelerating the implementation of on-chain financial markets. Its progress surpasses major economies like the US and Europe in speed and execution.
- Key Elements:
- On April 20, 2026, Hong Kong issued new regulations, for the first time allowing SFC-recognized tokenized investment products to be traded on the secondary market through licensed platforms, granting them the status of financial products.
- As of the end of March 2026, Hong Kong had 13 tokenized products offered to the public, 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 Digital Finance 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 conversion between e-CNY and stablecoins, reducing cross-border transaction times from 2 hours to 3 minutes, and cutting costs by over 20%.
- A joint statement by the US SEC and CFTC clarified that tokenized assets fall under the securities category and classified them into five asset types; the EU's MiCA framework took effect in December 2024, offering unified licensing and market access rules.
- Regulatory practices in the US and EU—such as dissatisfaction from banks over OCC licensing and risks of regulatory arbitrage in MiCA's cross-border operations—serve as warnings for Hong Kong, highlighting the need to balance institutional compliance costs with 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 in areas such as RWA and stablecoins. It does not constitute any proposal or offer. Please be aware that issuing or participating in the investment of Tokens is subject to varying degrees of strict regulatory 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 like token matching also falls under "illegal financial activities" (Mainland Chinese readers 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 decision-making and strictly adhere to the laws and regulations of your country or region; do not participate in 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 issuance and circulation paths for 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 track 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 adoption of RWA requires not only solving infrastructure-level interoperability issues but also heavily depends on the refinement of regulatory frameworks and improvement of institutional norms.
Against this backdrop, Hong Kong SAR, China's overall regulatory pace has been noticeably accelerating since the submission of the "Stablecoin Ordinance Bill" in late 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. This framework establishes a licensing system for stablecoin issuers on one hand, and imposes systematic requirements on licensed institutions regarding capital adequacy, reserve asset management, risk control, and operational compliance on the other, laying a regulatory foundation for stablecoins to become trusted settlement tools 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 (HKMA) granted stablecoin issuer licenses to Anchor Point Financial 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 (SFC) further released a new regulatory framework, explicitly allowing for the first time the secondary market circulation of tokenized investment products. The core direction of this framework is: permitting the circulation of SFC-authorized open-ended tokenized funds; allowing related products to be traded on platforms licensed by the SFC (with OTC forms possible in specific cases). This means that SFC-recognized tokenized products have obtained a compliant secondary circulation channel for the first time, also signifying they have acquired the attributes of financial products.
On the product level, Hong Kong SAR Legislative Council Member Duncan Chiu mentioned in a speech at the 2026 Hong Kong Web3 Carnival that HashKey has 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. [2] Furthermore, according to SFC disclosures, as of the end of March 2026, 13 tokenized products were offered to the public in Hong Kong. The total value of assets under management for these tokenized products increased approximately sevenfold over the past year, reaching HKD 10.7 billion, indicating rapidly growing market acceptance for such products. [3] Judging from 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.
Globally, relevant regulatory systems in the United States and the European Union are also gradually becoming clearer.
In the US, the "Guiding and Establishing National Innovation for US Stablecoins Act of 2025" (GENIUS Act) was formally signed in July 2025. This act aims to build a comprehensive framework for stablecoin issuance and regulation, clearly specifying the qualifications of issuing entities, asset reserve requirements, and compliance standards. Meanwhile, the "Digital Asset Market Clarity Act" (Clarity Act) is under Senate review, seeking to provide standardized market guidance through unified on-chain asset classification and regulatory rules. (Further reading: The US Senate Passes the GENIUS Stablecoin Act: What Major Changes Will Web3 and RWA See?, The US CLARITY Act Under Review: Are DeFi-Friendliness, Asset Classification, and SEC-CFTC Power Division Becoming a Tipping Point for Crypto Regulatory Clarity?)
In March 2026, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) issued a joint statement categorizing on-chain assets into five types: Digital Commodities, Non-Fungible Tokens (NFTs), Utility Tokens, Payment Tokens (Stablecoins), and Digital Securities. This statement explicitly clarifies that tokenized assets fall under the securities category, providing 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 systems 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, requiring on-chain asset service providers to disclose detailed user asset and transaction information to tax authorities of respective member states and share it. This means tax authorities can conduct open and transparent oversight of Web3 asset holdings, transactions, and transfers, similar to how they treat traditional Web2 bank accounts.
Thus, the on-chain asset regulatory frameworks of major global economies have taken initial shape, showing a trend towards greater clarity and more detailed classification.
Comparison of On-Chain Financial Regulatory Frameworks in Hong Kong SAR, the US, and the EU. Source: Researcher ShirleyLi, Web3Caff Research
Overall, however, the US and EU regulatory frameworks primarily focus on regulating 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 aligned with the "Fixed Income and Currency Market Development Roadmap" previously issued by the SFC and HKMA. This roadmap emphasizes Hong Kong's strategic position as a "global fixed income and currency center," and the regulatory strategies concerning stablecoin licenses and RWA asset issuance and circulation naturally form a crucial part of Hong Kong's asset regulatory framework.
Importantly, in late February this year, the Digital Currency Institute of the People's Bank of China and the Hong Kong Monetary Authority 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 use cases, this test verified the real-time exchange and clearing capability between the e-CNY and Hong Kong's pending-license stablecoins (with two companies having obtained official licenses). It successfully reduced the typical cross-border transaction time from 2 hours to 3 minutes and lowered costs by 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 'e-CNY International Operations Center' Signal of Cross-Strait Integration: Mainland Provides the Infrastructure, Hong Kong Provides the Market)
However, the regulatory experiences of the US and EU also offer valuable references for Hong Kong SAR. For example, the US Office of the Comptroller of the Currency (OCC) granted trust bank charters to five Web3 companies like Circle, Ripple, and BitGo in late last year, allowing them to legally participate in on-chain financial activities. This move, however, sparked dissatisfaction from the traditional banking sector. [5] Traditional banks argue that the compliance responsibilities and costs they bear are not comparable to those of licensed Web3 institutions, and they also see competitive overlaps in business scope. Meanwhile, the EU's MiCA stipulates that an on-chain asset service provider licensed in one member state can operate across the entire EU. This cross-border pass-through might pose risks of license abuse or regulatory arbitrage.
For Hong Kong SAR, these cases provide important lessons 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 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. Overall, however, the global regulatory framework for on-chain finance remains in an exploratory phase, and its integration process with traditional finance requires long-term observation.
Key Points Structure Diagram:
References
[1] Hong Kong Monetary Authority Issues Two Stablecoin Issuer Licenses
[4] Hong Kong Stablecoins + Digital RMB: A 'Fast Lane' for Mainland Assets Going Global?
[5] Bankers' Turf Invaded? US Banking Industry Plans to Sue OCC to Block Crypto Charters
[6] Understanding the SFC's New 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 prediction, 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 aimed at helping understand industry trends and promoting the responsible development of Web3, including the blockchain industry. They should not be interpreted as definitive legal opinions or the views of Web3Caff Research. The views expressed in this report reflect the personal opinions of the author as of the stated date, are independent of the position of Web3Caff Research, and are subject to change based on subsequent developments. The information and opinions contained in this report are derived from proprietary and non-proprietary sources deemed reliable by Web3Caff Research but may not cover all data, and their accuracy is not guaranteed. Accordingly, 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 to any person for negligence). This report may contain "forward-looking" information, including forecasts and projections, which do 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 informational purposes 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.
