Global RWA Regulatory Landscape: A New Financial Competition Driven by Institutional Logic

The wave of tokenization of real-world assets (RWA) is impacting the boundaries of traditional finance with unprecedented force. This is not only a technological innovation but also a profound game of national strategy and regulatory philosophy. From Singapore's collaborative ecosystem to Thailand's inclusive bonds, from Switzerland's wholesale digital money to Dubai's fragmented real estate, countries around the world are drawing regulatory blueprints through distinct paths. A multi-centered competition led by the state, coordinated by institutions, and driven by the market has already begun, and its outcome will reshape the flow of global capital and the future landscape of finance.

I. Overview of Global RWA Regulatory Models

Real World Asset (RWA) tokenization, as a key area for the integration of blockchain technology and TradFi, is drawing widespread attention from global regulatory agencies. Depending on the economic environment, characteristics of financial markets, and regulatory philosophies of different countries, the current global RWA regulatory landscape has mainly formed three differentiated models: state-led, institutional collaborative, and market-oriented. These models reflect the different trade-offs made by various jurisdictions between promoting innovation and maintaining financial stability.

Table 1: Major Regulatory Models for Global RWA and Representative Countries

The formation of these three regulatory models is deeply influenced by the financial traditions, legal systems, and industrial policies of various regions. The state-led model is common in areas where the government has strong guiding capabilities in the financial market; the institutional collaborative model is often found in open economies that highly rely on international trade and financial cooperation; the market-oriented model usually exists in jurisdictions with highly developed financial markets and mature regulatory systems.

It is worth noting that these models are not mutually exclusive, but rather reflect the spectrum of different jurisdictions in their regulatory strategies for RWA. As the market develops, some countries are also adjusting their regulatory posture, such as Japan, which in recent years has transitioned from a high-intensity comprehensive taxation to a separate taxation system through tax rate reforms, marking a shift in its policy direction from risk control to market incentives.

2. Nationally Dominated Regulatory Model

The fundamental characteristic of the government-led RWA regulatory model is that the government and regulatory agencies play a core role in the development of the RWA ecosystem, guiding the RWA market to develop in a direction that aligns with national strategies through policy guidance, infrastructure construction, and even direct participation. This model is common in countries where the government has a strong willingness and capability to guide the financial market.

1. Mainland China: Balancing Cautious Prevention and Control with Pilot Innovations

The regulation of RWA in mainland China shows a clear dual characteristic of cautious prevention and control, as well as pilot innovation. At the macro policy level, China maintains a strict prohibition on activities related to virtual currency. The “Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation” issued by the People's Bank of China and ten other ministries in 2021 clearly defines activities related to virtual currency as illegal financial activities. This strict regulatory stance creates institutional barriers for the issuance of RWA products with financial attributes domestically. However, while prohibiting financial speculation, China is also promoting compliant pilot projects through local governments and industry associations, exploring non-financial and scenario-based application paths for RWA.

In China's exploration of tokenization of real-world assets (RWA), the digital yuan (e-CNY) plays a crucial core role, serving as a key bridge connecting technological innovation and financial compliance under a state-led model. Unlike many other countries that directly perform on-chain tokenization of various assets, China's prudent strategy manifests as: while strictly restricting private crypto assets, it fully commits to building and promoting a central bank-backed legal digital currency, aiming to lay a secure and controllable underlying infrastructure for the potential large-scale digitalization of assets in the future.

The strategic positioning of the digital renminbi goes far beyond that of a simple electronic payment tool. It is explicitly regarded as a national-level financial infrastructure and a core cornerstone of the digital finance era. Its strategic significance lies in, first, in the context of the rapid development of global stablecoins, the digital renminbi is a key measure to reinforce national currency sovereignty and ensure the dominant position of the renminbi in the digital economy. Second, through its “payment as settlement” and programmable features, the digital renminbi opens up technological space for the future exploration of high-efficiency, low-cost compliant financial transactions. For example, in theory, it can provide more efficient clearing and settlement solutions for bond issuance, trade financing, or the circulation of specific asset rights.

In practical terms, the promotion of the digital renminbi is extending from retail scenarios to broader fields. The authorities are committed to expanding its applications from everyday small payments to include “large-scale inclusive” scenarios such as corporate payments, government payments, and supply chain finance. This expansion is essentially building a rich application ecosystem for the digital renminbi, enabling it to support more complex financial activities in the future. A landmark development is the establishment of the Digital Renminbi International Operations Center by the People's Bank of China in Shanghai in 2025. This move clearly sends a signal: China is actively exploring the optimization of settlement processes for cross-border trade and investment financing using the digital renminbi, enhancing the efficiency of cross-border capital flows. This is a forward-looking layout for the future digital flow of cross-border assets under national leadership.

At the same time, Chinese regulatory authorities maintain strict and clear boundaries regarding unofficial digital asset forms. There is a sustained high-pressure stance on activities such as virtual currency trading and ICOs domestically, creating an undisturbed internal environment for the development and pilot testing of the digital yuan. This regulatory philosophy of “opening the front door while blocking the back door” ensures that the leading role in financial innovation is firmly in the hands of the state and the central bank. Even innovative pilot projects conducted by local governments or state-owned enterprises, such as digital vouchers for agricultural assets or advertising rights, are strictly confined to the scope of consumer rights or specific services, avoiding involvement in financialization and securitization. Their technological paths and potential future synergy with the digital yuan ecosystem are all under the watchful eye of national regulation.

The development path of RWA in China exhibits distinct characteristics of “centered around Digital RMB, based on national credit, and bounded by prudent compliance.” The current focus is not on encouraging the free tokenization of various assets, but rather on prioritizing the solidification of state-led digital financial infrastructure. By vigorously promoting Digital RMB, China is building a safe, efficient, and fully regulated core payment and settlement track for the potentially larger wave of asset digitization that may come in the future.

2. Hong Kong, China: A Regulatory Model of Openness and Stringent Entry Requirements

Hong Kong, leveraging its status as an international financial center, has built a more inclusive and innovative RWA regulatory framework while maintaining strict entry standards, reflecting a compromise model of “open + strict entry.” The Hong Kong SAR government has established a “dual regulatory agency” system centered around the Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA) to implement differentiated regulation for RWA.

Hong Kong has established a coherent advancement system in the realm of Real World Assets (RWA), where the regulatory sandbox mechanism serves as an important foundation. For instance, platforms like the “Ensemble project” allow enterprises to test cross-border RWA issuance models, with cases such as CSG Energy and Xunying Technology successfully completing issuances through this mechanism. Building on this, the Hong Kong Monetary Authority will further launch the “Digital Bond Financing Scheme” in November 2024, aiming to encourage the widespread application of tokenization technology in the capital market with policy support. Eligible enterprises can receive up to HKD 2.5 million in funding, thereby creating a policy environment that incentivizes innovation. The effectiveness of this series of measures is reflected in specific cases—In August 2025, Guotai Junan International partnered with Ant Group to successfully issue the first batch of structured product tokens based on AntChain technology, and achieved cross-chain circulation to Ethereum through the “Two Chains One Bridge” structure, effectively connecting mainland Chinese assets with the global trading market, showcasing Hong Kong's practical achievements in promoting asset digitization and cross-border flow.

3. Thailand and Vietnam: Inclusive Financial Practices Backed by National Credit

Southeast Asian countries show unique national characteristics in the RWA field, especially Thailand and Vietnam, leveraging national credit to promote RWA towards inclusive finance.

The G-Token project in Thailand is a typical example of a state-led model. Led by the Thai Ministry of Finance, G-Token is the world's first tokenized government bond aimed at retail investors, with an initial issuance amount of 5 billion Thai Baht (approximately 153 million USD) and a minimum investment threshold of only 100 Thai Baht, significantly lowering the investment threshold for ordinary citizens. This project not only enhances the liquidity of government bonds but also effectively promotes the legalization and maturation of Thailand's local digital asset market.

Vietnam is promoting the on-chain accounting, bills, and cross-border trade data through the cooperation between the Ministry of Finance and the Vietnam Postal Savings Bank, applying RWA technology to the modernization process of national governance rather than purely financial innovation.

3. Institutional Collaborative Supervision Model

The core feature of the collaborative regulatory model is the close cooperation between government agencies, financial institutions, and technology companies. Through mechanisms such as regulatory sandboxes and the establishment of industry standards, the RWA framework is tested and refined in a controlled environment. This model is commonly found in open economies that heavily rely on international trade and financial cooperation.

1.Singapore: A Model of Global Collaboration and Mutual Recognition of Standards

The regulatory path for RWA implemented by the Monetary Authority of Singapore (MAS) is regarded as a model of institutional collaboration. Its core project, Project Guardian, has attracted over 40 international financial institutions, forming a highly cooperative global financial ecosystem. This project is not only a technical testing platform but also aims to address the interoperability issues in the RWA market by establishing a shared industry framework, avoiding fragmentation in the early stages of technology application.

Singapore has launched a series of innovative measures in RWA regulation, with the triple licensing system forming an important foundation of its regulatory framework— for example, DigiFT, as the world's first RWA platform to obtain a triple license for capital market services, has successfully crossed the three regulatory thresholds required for securities trading platforms, including the trading venue license, capital market services license, and custody service qualification.

On a technical level, the platform deeply integrates the DPoS (Delegated Proof of Stake) mechanism built on Ethereum with compliance requirements, leveraging an on-chain transparent ledger to achieve regulatory penetration capabilities, ensuring that every transaction generates an audit trail compliant with the standards of the Monetary Authority of Singapore (MAS). Furthermore, DigiFT constructs a “Iron Triangle” business closed-loop model, integrating a liquidity engine based on the AMM mechanism, a compliance firewall that automatically executes KYC/AML verification through smart contracts, and a technology platform that protects privacy using zero-knowledge proofs, systematically addressing the three core pain points of liquidity challenges, compliance obstacles, and technical thresholds that the RWA field has long faced.

2. EU: Regional Coordinated Regulation under a Unified Framework

The EU adopts a regulatory strategy to promote policy coordination among member states through a unified framework, gradually achieving standardized regulation through the “Digital Finance Package,” MiCA (Markets in Crypto-Assets Regulation), and a DLT pilot regime, while maintaining compliance consistency within the region. EU regulatory bodies have clearly stated that tokenized securities are still securities, and market participants must consider and comply with securities laws when trading these instruments.

The European Union demonstrates a systematic approach to regulating Real World Assets (RWA), with its core focus on providing clear legal certainty. By establishing clear classifications and regulatory requirements for tokenized assets, it effectively reduces compliance uncertainty in the market. On this basis, the EU emphasizes cross-border coordination, facilitating regulatory mutual recognition among member states through a unified rule system, which provides convenience for the cross-border expansion and operation of RWA projects. At the same time, the EU has introduced an innovative testing mechanism, with its dedicated DLT testing system offering temporary regulatory exemptions for innovative projects, allowing companies to test their new products and technologies in a real market environment. This series of initiatives collectively forms a regulatory framework that is normative, open, and encourages innovation.

3. Switzerland and South Korea: Collaborative Practices of Precise Legislation

Project Helvetia in Switzerland is one of the most influential RWA projects globally. This project is jointly initiated by the Swiss National Bank (SNB) and the Innovation Hub of the Bank for International Settlements (BIS), with the core objective of testing how central bank money can be used for the settlement of tokenized assets on a Distributed Ledger Technology (DLT) platform. Project Helvetia has entered its third phase, using wholesale Central Bank Digital Currency (wCBDC) for real-time pilots, providing a solid technological and regulatory foundation for the digitalization of the financial system.

South Korea is advancing the legal integration of on-chain securities through specialized legislation and exploring payment scenarios in conjunction with stablecoins in its local currency. The financial regulatory authorities in South Korea are actively constructing a mainstream framework system based on prudent regulation. Although maintaining relatively tight policy constraints in terms of regulatory intensity, they have basically completed the regulatory restructuring for RWA assets, ensuring that key aspects such as Token issuance, rights confirmation, circulation, and custody have clear guidelines.

4. Market-Oriented Regulatory Model

The fundamental characteristic of a market-oriented regulatory model is a greater reliance on the self-regulation and innovation of market participants, with regulatory agencies primarily ensuring market compliance through ex-post enforcement rather than setting detailed regulatory frameworks in advance. This model is typically seen in jurisdictions with highly developed financial markets and mature regulatory systems.

1. United States: A Complex Balance of Law Enforcement Regulation and Market Drivers

The regulatory landscape for RWA in the United States presents a typical dual-level differentiation between federal and state levels, as well as a strong tendency towards enforcement regulation. The U.S. Securities and Exchange Commission (SEC) has clearly stated that Tokenized Securities are still securities, and market participants must consider and comply with federal securities laws when trading these instruments. This regulatory stance of “the law already exists” forces market entities to explore feasibility in a gray area.

The United States exhibits significant market-oriented regulatory characteristics in the realm of Real World Assets (RWA), with its development primarily driven by private institutions and market demand, as reflected in several landmark cases. In March 2024, the world's largest asset management company, BlackRock, launched the first tokenized fund BUIDL issued on a public blockchain, marking the formal recognition and participation of TradFi giants in the RWA model.

Further at the local government level, Bergen County, New Jersey, plans to digitize and record real estate contracts valued at up to $240 billion across the county in collaboration with private technology company Balcony on the Avalanche public blockchain. This initiative is expected to improve contract processing efficiency by over 90%, showcasing the deep transformation of traditional asset registration processes by blockchain technology. At the same time, market innovation remains active, as cryptocurrency exchange Kraken collaborates with asset tokenization firm Backed Finance to promote stock tokenization in Europe, attempting to achieve 7×24 hour uninterrupted trading through virtual asset exchanges. These practices led by enterprises and local governments together outline a development path for RWA in the U.S. that prioritizes market exploration with regulatory follow-up.

2. The UK and Japan: A Gradual Path to Market Liberalization

The RWA regulatory path in the UK is closer to the European continent, with its stablecoin, market infrastructure, and tokenization of securities regulation rapidly taking shape. The Financial Conduct Authority (FCA) and the Bank of England have clear divisions of labor, allowing for a relatively unified logic in institutional development. The Digital Securities Sandbox launched in the UK allows companies to test tokenized securities in a controlled environment, reflecting the UK's regulatory approach that supports innovation while ensuring financial stability.

In recent years, Japan has undergone a significant shift in its regulatory stance, using tax rate reform as a breakthrough to transition from high-intensity comprehensive taxation to separated taxation, marking a change in its policy direction from risk prevention to market incentives. This shift has enhanced Japan's attractiveness in the global RWA market competition while maintaining financial stability.

3. UAE: Institutional Dividends Attract Global Innovation

The UAE, particularly Dubai, has become a representative of a market-oriented model due to its regulatory certainty and market openness. Dubai has established a comprehensive framework covering tokenization, digital assets, and cross-border capital flows through institutions such as DIFC and VARA (Virtual Asset Regulatory Authority). The real estate tokenization project in Dubai is led by the Dubai Land Department (DLD) and aims to enhance the liquidity and accessibility of the real estate market by dividing property ownership into digital tokens.

The development of the United Arab Emirates in the Real World Assets (RWA) sector demonstrates its unique comprehensive advantages. Its low tax environment, through a systemically designed zero tax policy, has created a testing platform with significant cost advantages for the global migration of RWA assets. At the same time, the country also excels in regulatory certainty; for example, DAMAC Properties collaborates with Securrency to advance a $1 billion tokenization project for real estate and data centers on the Avalanche blockchain, providing institutional investors with a clear compliance entry point.

On this basis, the market-driven innovation model further strengthened its competitiveness by lowering the investment threshold for real estate tokenization to 2000 dirhams (approximately 545 USD), greatly broadening the investor base and attracting participation from around the world, thus forming a comprehensive advantage pattern from the institutional environment to specific practices.

Five, Key Dimensions of RWA Regulation and Future Outlook

1.The Five Key Dimensions of RWA Regulation

With the continuous expansion of the RWA market, the core dimensions of regulation have gradually been clearly defined. From the establishment of compliance frameworks to the regulatory collaboration of cross-border flows, each dimension is directly related to the legality, transparency, and global liquidity of RWA assets.

• Compliance Framework and Market Standards: The compliance framework is the foundation of RWA regulation. Several global financial centers, such as Singapore and Switzerland, have established clear regulatory frameworks that provide market participants with clear rules. These countries not only ensure market safety through a rigorous compliance system but also promote the development of industry standards and global mutual recognition, ensuring the liquidity of cross-border RWA assets. For example, DigiFT's “Triple License” model sets a clear compliance benchmark for the industry, and its DPoS mechanism built on Ethereum achieves regulatory transparency through an on-chain transparent ledger, generating an audit trail compliant with MAS standards for each transaction.
• Tax Policies and Accounting Standards: Tax policies and accounting standards are another key element of RWA regulation. There are differences in the tax treatment and accounting standards for RWA assets among countries worldwide, which directly affects the feasibility and market activity of cross-border asset transactions. Singapore, Hong Kong, and the UAE have designed systemically zero-tax frameworks to build relatively low-cost experimental platforms amid the global RWA asset migration trend; Japan, on the other hand, has taken tax rate reform as a breakthrough, transitioning from high-intensity comprehensive taxation to separate taxation, marking a shift in its policy direction from risk prevention to market incentives.
• Asset Auditing and On-Chain Disclosure: With the rapid development of the RWA market, ensuring the transparency and authenticity of assets has become a top priority for regulators. Countries require third-party institutions to conduct independent audits and mandate the public disclosure of on-chain data to ensure market transparency. In the Langxin Group charging pile RWA project, operational data such as electricity usage and status are collected in real-time through Ant Group's AIoT module, and combined with blockchain technology to quickly upload data to the chain. The on-chain data is verified by a third-party independent rating agency. This transparent data disclosure mechanism provides a reliable basis for income calculation and asset valuation.
• Investor Protection and Risk Management: As the RWA market expands, investor protection has become a key issue. Regions such as Singapore and Hong Kong ensure that market participants understand potential risks and avoid excessive market speculation through stringent investor suitability assessments and risk education. For example, Longxin Technology's RWA issuance in Hong Kong is restricted to professional investors (PI) with risk recognition capabilities, limiting the participation of retail investors. The Hong Kong Securities and Futures Commission imposes strict compliance requirements on platforms providing securities token trading services, including various regulations on asset custody, cybersecurity, and market conduct.
• Cross-border regulatory collaboration and standardization: Cross-border regulatory collaboration is key to the effective operation of the global RWA market. Countries need to address compliance issues in cross-border transactions through international cooperation and regulatory standardization. Countries like Singapore and Switzerland have played an important role in promoting the establishment of global standards for RWA. For example, the cooperation agreement between Finloop and 1exchange specifically targets cross-border compliance challenges, aiming to optimize the RWA product structure and enhance cross-border compliance capabilities under the regulatory frameworks of Hong Kong and Singapore.

2. Future Development Trends of Global RWA Regulation

Looking ahead, the global RWA regulation will present the following development trends:

Regulatory integration accelerates: The compliance interface between DeFi (Decentralized Finance) and TradFi (Traditional Finance) is taking shape, with regulatory technology (RegTech) becoming a new infrastructure. Regulatory agencies in major financial centers will continue to deepen cooperation, promoting mutual recognition and unification of regulatory standards. Hong Kong and Singapore have clearly stated that they will strengthen coordination in RWA regulation and jointly promote the standardized development of the RWA market in the Asia region.

Technical regulation upgrade: As the complexity of RWA projects increases, regulatory agencies will increasingly utilize blockchain technology itself for regulation. Balancing transparency and privacy protection will become a key issue. The application of privacy protection technologies such as zero-knowledge proofs will meet regulatory transparency requirements while ensuring data security.

Diversification of asset types: Expanding from current government bonds, real estate, and private credit to a wider range of asset classes, including new types of assets such as intellectual property, data assets, and carbon credits. Regulators need to design differentiated rules for different asset classes, such as the RWA pilot in China, which clearly distinguishes between financial assets and consumer rights assets.

Cross-border regulatory competition and cooperation coexist: Countries compete to attract RWA innovation and investment, but they also recognize the necessity of cross-border regulatory cooperation. International collaborative projects like Project Guardian indicate that future RWA regulation will place greater emphasis on cross-border coordination.

The global RWA regulatory landscape is undergoing rapid evolution, with three models: state-led, institutional collaborative, and market-oriented, each adapting to the economic environment and regulatory traditions of different jurisdictions. As technology continues to mature and the market expands, the regulatory framework will further refine and improve. In the foreseeable future, regulatory compatibility, technical standardization, and cross-border collaboration will become key factors driving the healthy development of the RWA market. According to a forecast by the Boston Consulting Group, the global asset tokenization market size will reach $16.1 trillion by 2030. This enormous potential signifies the critical strategic importance of building an efficient and secure RWA regulatory framework.

Source of some information:

·“The Norwegian Central Bank is building a CBDC sandbox on Ethereum and has developed an infrastructure prototype”

· “The Bank of England Launches Consultation on Regulating Systemically Important Stablecoins”

· “Vietnam Launches Pilot Work for Crypto Asset Market”

Author: Liang Yu Editor: Zhao Yidan